JimGant

22 minutes ago, stat said:

I am suggesting that there is a real possibility of that happening i.e. unremitted income will be taxable and remitted income will be taxfree.

That makes no sense. If the worldwide taxation scenario is implemented, then the "remitted income" scenario is replaced, and goes away. There won't be any parallel taxation schemes. And if the 'powers that be' wanted LTR visa holders to have a special tax break, then there will have to be some rewording of the Royal Decree to accomodate such a tax break. Meanwhile, BoI is as clueless as the rest of us.

On 6/28/2024 at 3:42 PM, Tonyfarang said:

and I've decided to move away immediately once they officially announce it

Out of curiosity, what country are you from? And, how much will your taxes increase, under either the new remittance system, or under the potential worldwide income method? Or will they increase at all?

1 minute ago, Presnock said:

yeah, 72-73 but mostly then upcountry, 76-79 78-2000 and 2003-2005 at the main bldg.  When was your wife there?

70-72. Her boyfriend then was Phil Mayhew, economics guy, then consul general for a year at Udorn, in 1972. He later returned to Thailand, and was DCM in, I believe, the years you mentioned. We attended his funeral at Arlington a few years back. Obviously, you were State Dept, which means you get no Social Security, which most readers probably don't understand. Also there in 72-73 was Victor Tomseth, who married another embassy worker, Wallapa. Victor was later DCM in Iran, when the hostage crisis hit. And later ambassador to Laos. Wife and Wallapa still keep in contact. Small world, eh?

1 hour ago, Presnock said:

Life goes on, first came here in 1972

Did you then work in the US Embassy, as you alluded to in an earlier post? My wife worked there then, before PanAm hired her away, to serve coffee and give blow-job demos in life jackets.

4 hours ago, jaideedave said:

JG,Eh? 555,

"Eh" was said with a wink and a smile. Love Canadians. My finest five year tour in the Air Force was at McChord AFB, in Tacoma, Wash, in a NORAD unit, where 30% of us pilots and controllers were Canadians. Never met a bad egg Canadian. And they all played golf, and carried a jug of Rye in their bags -- meaning, by the time of the triple bet 18th hole, they were easy pickings. Good times, good memories. Hope to see more here in Chiang Mai.

1 hour ago, jaideedave said:

Interesting. I always struggle with legal jargon, whats your take?

Two of my pensions are gov't and one is private (work related)

I'd appreciate your opinion...

The Canada-Thai tax treaty does not have separate Articles for private and govt pensions -- unlike most treaties, including that of your cousins to the south. Thus, all your Canadian pensions, private and govt, are taxable ONLY by Canada. The "ONLY" word, per OECD definitions, gives exclusionary taxation rights to the referenced country. If "ONLY" was omitted from the language, then, in this example, Thailand would have secondary taxation rights. And if their taxation of these pensions was higher than Canada's -- then you pay full fare to Canada, plus the Thai taxes that exceed the Canada tax credit that Thailand has to absorb. But, this is not the case , as Thailand does not, per treaty language, have secondary taxation rights.

I don't know if I can say congrats on this treaty language -- 'cause if the treaty gave exclusionary taxation rights of all Canada pensions (private and govt) to Thailand -- and Thailand tax rates were below Canada's, well, then, you'd be in a better position in this situation. I don't know -- you'd have to run the comparative numbers.

But, for Canadians, nothing has changed when it comes to this new Thai taxation language -- you still file your Canadian taxes, with your pension data, per normal -- with no need to consider or file a Thai tax return. Eh?

5 minutes ago, JohnnyBD said:

I was just pointing out that if I remitted the principle & capital gains, I get to choose the cost basis method I use, not TRD.

I guess switching to worldwide taxation will finally shut down all these remittance based discussions. I have no doubt that that's where we're headed.

1 hour ago, Mike Lister said:

I keep referring to savings because the issue that was raised is whether stock ownership is considered to be the same as savings accounts,

Raised by whom?

28 minutes ago, Mike Lister said:

Then we were told repeatedly, as a matter of fact, that there is no downside to not filing a tax return, when no tax is due. Eventually we found out there is a significant downside.

And what was that again?

9 hours ago, Mike Lister said:

This is where we disagree big time. An unrealised Capital Gain is not savings in any of my books

Why do you keep referring to savings? The one-time good deal exemption refers only to "foreign source income." Savings, of course, are a form of income, namely, after-tax income. But unrealized gains can also be considered income, and, as such, can be reported on income statements:

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Securities that are held for trading are recorded on the balance sheet at their fair value, and the unrealized gains and losses are recorded on the income statement.

https://www.investopedia.com/terms/u/unrealizedgain.asp

Anyway, TRD's one-time good deal exemption is only interested in a number you can use as your total exemption for post 2023 remittances. This number should be obtained by the balance sheet of the value of all your financial assets on 31 Dec 2023. And this number would include fair market value of your securities, which, of course, would include those unrealized gains. But so what -- there are no taxable events going on here interested in capital gains. The only taxable event of interest is -- how much of your post 2023 remittances can be exempted from Thai tax -- by that number obtained in your 31 Dec 2023 balance sheet.

Mike Lister has his interpretation -- and I have mine. Take your pick.

22 minutes ago, Mike Lister said:

That all sounds very like you don't know and are guessing and suggesting you impose your own rules once again, is that the case?

Sigh. I'm just suggesting there's enough wiggle room on how to interpret the nature of your pre 2024 portfolios to give yourself maximum advantage on amount of remittance exempt from tax. To include unrealized capital gains. That you don't agree, to include savings that turn into investments, no longer being exempt from remittance taxation -- well, that's your opinion. And an opinion I'm sure the TRD would welcome, since it's to their advantage.

Where you get that I'm imposing my "own rules" is a mystery. I'm just looking at all the data, and choosing all the arguable ones that have credence. Should it come to a chat with TRD, I would feel very confident -- based on what we know now -- in my position. No different than when I went across the Potomac to chat with the IRS; just know there are different interpretations of the same data -- and yours may come out second best.

1 hour ago, Mike Teavee said:

Have to say the examples I've seen from the likes of Expat Tax say very clearly that the Capital Gain is based on the initial costs of the assets & not the value as at 31/12/2023. 

So what if the value on 31/12/2023 includes the unrealized gain from initial purchase. That unrealized gain, I maintain, can be considered "income" -- as can be shown in many scenarios from different countries. Thus, it can be considered part of the "foreign source income" from before 2024 that is given an exemption from remittance taxation. That certainly could result in a spirited discussion with a TRD official -- who, sadly, probably wouldn't have a clue. But, hey, why would you not give yourself every financial advantage, particularly if you've got several examples from the internet to support your position. Plus, you've got probably a 1% chance of being called in for a chat about the validity of remitted pre 2024 income.

51 minutes ago, Mike Lister said:

Even the property portfolio that you own, you know, those financial investments that would incur capital gains when sold but are really only savings in disguise? Or is that because the gain is not realised until the investment is sold, that no income exists, ergo ,it cannot be exempt under Por 161/162

That was all explained in a post you had removed -- that included two important links to discussion on income. Possibly, in the interest of an important discussion on savings vs investments, you might repost that removal.

1 hour ago, Ben Zioner said:

But if I lost my LTR exemption I 'd be liable for 800K IT a year,

Wow, that sounds ominous. Must be cap gains. Can you elaborate? Thanx.

1 hour ago, Ben Zioner said:

So, why not being "non resident" the year you make such conversion?

Sounds like a lot of trouble, for an action that's really not very critical to your financial planning -- particularly for those of us who now have pretty extensive roots here.

24 minutes ago, OneZero said:

Jerk weed??  Thanks.  My TM95 is not due yet, but when the time approaches I will go to CM Immigration to ask If someone else hasn't already reported.

My apologies. I interpreted that you had already done a TM95 at CM Imm -- and thus were surprised that, per Star Visa's dialogue with me, that there might be a problem.... Thus, I didn't take kindly to the, "go find out for yourself." Sorry.

2 hours ago, OneZero said:

Just go to CM Immigration and ask.

Hey, jerk weed, can you save me a trip and just report on how it went for you....? Or, is that too much to ask?

5 hours ago, OneZero said:

I am not aware that Chiang Mai Immigration may have refused to process the TM95 report.

Am I missing something?

Oh, did you have TM95 success at CM Imm? If so, how about a trip report  -- would like to know the ropes for next year, as I don't like using an agent.

Anybody reading this have TM95 success (or not) at their Imm office? Thanx.

4 hours ago, OneZero said:

I am not aware that Chiang Mai Immigration may have refused to process the TM95 report.

Am I missing something?

Star Visa just said I was their first TM95 customer, and possibly there could be a speedbump at Immigration -- they didn't know. Will know Monday.

3 hours ago, koolkarl said:

I happen to be a CPA.  And you?

Take a deep breath, and seek professional help. You're giving our profession a bad name.

15 hours ago, Lacessit said:

Where it gets fuzzy is the definition of savings. I could not find a question which specifically asked the status of shares, peer-to-peer lending accounts, or term deposits in terms of whether they are regarded as savings, or not.

Of course they're savings, regardless of how they're dressed up.  The headliner on this thread says:

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Posts made by individuals reflect their own opinions and should not be taken as fact.