JimGant

Actually, if we go to a global tax system, Thailand still won't want to know about income it cannot tax -- like my US govt pension and Social Security. Those figures need not ever be introduced into a Thai tax return -- at least for now, where they're not interested in non assessable income. Incorrect -- and good intentions questionable.

If he self-assesses that the remitted income is non assessable -- why in the world would he have to assess if he's above or below the filing thresholds? Get a grip, man.

You mean up to the individual to self assess why he's omitting certain income from his tax return because he's determined that it is non assessable. Hard to reconcile that with your: I think you've lost the bubble. Maybe a good night's sleep might help.

Article 19 of the UK-Thai DTA: Any pension paid by the Contracting State or a political subdivision or a local authority thereof to any individual in respect of services of a governmental nature rendered to that State or subdivision or local authority thereof shall be taxable only in that State. Hopefully, you can equate "exempt" with "non assessable."

No! That there's no place to include it should be your first clue.

Ah, Section 40 has all 61 DTAs memorized.

The Revenue Code hasn't the foggiest what 61 DTAs define as income subject to Thai tax, thus assessable, or not assessable. Never mind.

Unless exempted by tax treaty. Treaties override domestic tax law, when push comes to shove. Now, domestic law *can* override treaty language. But the result is usually a betterment of the purpose of the treaty. An interesting example is Thailand's purported position that, if you pay income taxes to your home country, Thailand will give you a credit against the Thai taxes on same income -- if such income is deemed assessable by DTA. Now, most treaties say that private pensions may ONLY be taxed by Thailand. Meaning, Thailand has primary taxation authority, and thus gets to keep all the collected taxes. But, Thailand is saying: We'll change the treaty with our domestic override to make Thailand the secondary taxation authority, and thus absorb a tax credit for the taxes paid to the home country. Why they would want to do this, resulting in lost taxes -- is beyond me. But, it in no way jeopardizes the policy of 'no double taxation.' So, such an override has no apparent consequence, except to the decreased amount of taxes collected by Thailand. Another example is: domestic tax code being overriden to accommodate treaty language. The US tax code says no tax credit for foreign taxes on US income (only foreign income). But, US income remitted to Thailand, and taxed by Thailand, is protected by treaty from double taxation, in many cases, by the US absorbing a tax credit for these Thai taxes. Thus, a US tax filer needs to file a Form 8833 when he wants to override the US Tax Code, and accommodate treaty language for the avoidance of double taxation.

Model OECD treaty language has some general terminology which can be misleading, if not defined. For example, the tech explanation of the US-Thai treaty has the following explanation for Article 6, Rents of Immovable Objects: For tech explanation of Article 20, Private Pensions and IRAs: So, income ONLY taxable in home country definitely means it is non assessable for Thai tax purposes. Now, in the rental example, there is no ONLY stated -- so both the US and Thailand can tax this income: thus assessable income for Thai tax purposes. BUT, "may be taxed" by the US, gives the US primary taxation authority, and Thailand only secondary authority. Meaning: US keeps all the collected taxes, and Thailand has to absorb a credit for these US taxes. So, yes, assessable income for Thai tax purposes -- but heavily discounted by being second banana in a "both can tax" situation.

Did you mean "2023?" Which has year 2024 not protected by Por 162, or by the new proposed rule, whose protection begins with 2025 income.....

Sacrificing your young men in a war with absolutely no threat to your shores -- is insanity. The US learned this in WWI. I can only believe Canada, had they imitated the US in getting rid of the Crown, would have also imitated the US in not knowingly sacrificing their youth -- unless, and until, war was declared on them. "God save the King" has an interesting ring to it. But marching off to war, as a colony and not as an independent country, is madness.

Sure. If that money is not assessable income per the DTA, like govt pensions and Social Security. Or pre 2024 income, as found in savings accounts, CDs, IRAs, etc (exempt per Por 162 decree). Or a loan from your bank, or a loan from mortgaging your house or other assets. Inheritances. Gift from Aunt Agnes. Still short, 'cause you only have assessable income, like from a 2024 or later private pension? Instead of remitting it to Thailand (and thus subject to taxation), buy an asset you can collateralize, then take a loan and send that money to Thailand. By the way, no one is going to scrutinize the assessability of your remittances. It would be too resource intensive -- with few gains -- to talk to everyone with large remittances. Besides, BoI is doing all they can to encourage Foreign Direct Investment. And harassing potential investors ain't in the cards. Just curious: Why do you think the money you might forward to Thailand for a condo purchase -- would be assessable for Thai tax purposes? Are you cashing out a large chunk of IRA? If so, literal reading says Por 162 exempts all pre 2024 monies in this IRA -- just pay Uncle Sam.

Somehow I've lost the whole point of this discussion. Money remitted to Thailand from an IRA has lost any identity it may of had in the IRA. If it was a stock mutual fund, those stocks were sold, and it is now fungible cash, with no mutual fund identity. This cash is remitted to Thailand, and the DTA says Thailand has exclusive taxation rights on this remitted income -- because it represents IRA income. There's no mutual fund identity to this remittance -- it's strictly nondescript cash representing income deemed assessable, per DTA, for Thai tax purposes. So, how do you play the "mutual fund" card in this scenario, particularly if only a small percentage of your IRA withdrawal represents mutual fund holdings in your IRA?

Well, yeah. But because of the war you don't have the resources to maintain that infrastructure, and it falls down..... Nevermind.

Pretty much. They certainly didn't have the resources for rebuilding their depleted economies. Fortunately for Europe, the US was once again there to help them out. This time with the Marshal Plan, involving $13.3 billion in aid (equivalent to $135 billion in today's dollars). Not completely for altruistic reasons, as the US needed robust trading partners so that future presidents had a place to hang their tariffs on.