Legal Strategies to Reduce Thai Tax

[JohnnyBD]

22 minutes ago, Random8 said:

I apologize if I'm repeating information that has already been discussed, but I don't have the time or tenacity to go through 400 prior posts on this thread or other similar threads.

 

I am very appreciative of Mike's document explaining the tax situation.  My goal is to create documentation that readily supports that the funds I remit to Thailand are not "Assessable" (as defined in section 10 of Mike's document).

 

I hope to avoid the entire issue, by never remitting any funds other than savings.  If anyone sees any flaws in my methods, please let me know.

 

I suspect the biggest challenge will be to create a proper paper trail to demonstrate I am not remitting income earned in the same year.  My plan is to open two new bank accounts in the US in 2024.  I will stay out of Thailand for 190 days in 2024 even though I have a 1 year visa retirement extension.  One bank account will be for current year income deposits only.  The other will be only for cash disbursements to Thailand.  I will switch the functions of each account on January 1st of each year.

 

In 2025, all my income will be deposited into bank account "A".  Some time in late December 2024, I will deposit a large lump sum into bank account "B".  During the course of the year (2025) I will remit money to Thailand from bank account "B" while income accumulates in bank account "A".

 

In 2025, if the Thai government wants to have proof that the remitted funds came from savings, I will be able to supply them with an annual bank statement from account B which will show a large beginning balance on January 1st, no other deposits in the course of the year, only remittances to Thailand.  In 2026, if the Thai government wants to have proof that the remitted funds came from savings, I will be able to supply them with an annual bank statement from account A which will show a large beginning balance on January 1st, no other deposits in the course of the year, only remittances to Thailand.  I will alternate bank accounts functions annually.  The Thai government will never receive documentation demonstrating how much I actually earn (and pay taxes on) in the US.  I will only supply them with bank statements showing large beginning balances and remittances to Thailand for the year in question.

 

I hope to avoid the entire issue, by never remitting any funds other than savings.  I will structure my bank accounts and remittances to easily demonstrate the funds are from savings.  If anyone sees any flaws in my methods, please let me know.

 

Thanks in advance!

Are you going to stay less than 180 days every year? The problem I see is your 2025 income that you remit in 2026 will probably still be considered assessable income if you were a tax resident in 2025, even if you wait until 2026 to remit it.

Edited May 23 by JohnnyBD

[JimGant]

3 hours ago, Mike Lister said:

Nookie would have to declare that pension as assessable income and pay tax on it. Cyril could declare the payments were a gift but the frequency of them would likely come under suspicion and the TRD will probably ask for more information.

Huh? That's Cyril's pension, not Nookie's. Why would she be responsible for paying income tax on it? If this is a govt pension, whereby home country has exclusive taxation rights on it, well, the tax situation is handled by the home country, without any regard of that cash leaving for Thailand. And, once in Thailand, since DTA says it's non assessable income (govt pension, remember), that the money that ends up in Nookie's bank account is a non income taxable event. Nookie can do what she wants with this money, with no income tax obligation. Maybe she makes a deal with Dad to act as a funds intermediary, to pay out to him what he wants. Or maybe they classify it as a loan. Or maybe a gift. But as a gift, and being well down from the 20M baht threshold to pay a gift tax -- nobody will know, or care, that this was a gift. You don't just drop the RD a line that says, oh, I made a gift to my daughter. RD is only interested in those fat cat Thais, who would like to gift their estates away, so that no inheritiance tax with be owed. This is where gifts, and subsequent gift tax, become important.

 

Oh, yeah. If pension is a private pension, whereby DTA gives Thailand exclusive taxation rights on it -- then Cyril now has to pay income tax to Thailand, not the home country. Same result -- money arriving in Nookie's bank account is after tax money. And NO tax holiday for being a gift.

[Random8]

2 minutes ago, JohnnyBD said:

Are you going to stay less than 180 days every year? The problem I see is your 2025 income that you remit in 2026 will probably still be considered assessable income if you were a tax resident in 2025, even if you wait until 2026 to remit it.

I was hoping to stay the full year as of 2025.

 

I appreciate your comment.  You make a good point.  I suspect you are correct.  If the new tax law was written primarily to capture taxes previously avoided by rich Thais who earned income overseas but didn't remit until the following year, your concern make sense.

 

The definition of non-assessable income should be revised to state "prior year savings earned while not a tax resident.".

 

It would be great if more people commented on this.  I suspect the question of what savings is taxable is relevant for most expats.

 

[Dogmatix]

21 hours ago, Mike Teavee said:

Why would Thaksin's ex-wife make a defence that the shares she transferred were "Simply a gift & not taxable" if there wasn't scope to remit Gift's tax free? 

 

And why did the prosecution counter her claim with "It wasn't a gift it was a business deal" if the Gifts were taxable anyway. 

 

Ex-Thai PM’s wife guilty of tax evasion

The wife of former Thai Prime Minister Thaksin Shinawatra has been sentenced to three years in jail for tax evasion. Thailand’s criminal courts found Potjaman Shinawatra guilty of failing to pay $16.3 million in taxes. Her case relates to a transfer of 4.5 million shares in the family company, Shin Corporation. Mrs Shinawatra told the court that the share transfer was simply a gift and was not taxable. Prosecutors disagreed and said it was a business deal and therefore she should have paid tax on it. Shinawatra told the court she was completely innocent of any wrongdoing. The high-profile case was televised nationwide. Mrs Shinawatra’s husband and children looked on gloomily as the verdict was read out.

The judge’s decision could have serious consequences for Thaksin Shinawatra. He is accused of a series of offences including major fraud, corruption and abuse of political power. Prosecutors will charge the former Prime Minister of redirecting funds from an illegal $120-million loan to Burma into his own bank account, and of a shady transfer of government land into his wife’s name. Thais are split over whether Mr Shinawatra should face trial. He is still seen as a hero by millions of farmers and poor people. A lecturer from a top Bangkok university said the convictions of Mr and Mrs Shinawatra would be the “beginning of transparency, legitimacy and counter-corruption” in Thailand.

 

https://breakingnewsenglish.com/0808/080801-tax_evasion.html

 

 

This case predated the gift tax amendment to the RC.  Gifts were tax exempt without limitation then but the definition of gift in the RC but the prosecution case re the huge gift to her brother-in-law was this was not a gift because it wasn't made according to Thai traditional custom etc, based on the same definition that applies to gifts to non direct relatives today. Therefore the prosecution argued it was regular income.  Potjaman's defence was that it was a wedding gift two years after his wedding.  That was rejected by the court of first instance and the appellate court but finally accepted by the supreme court - money talks.  Potjaman's secretary was also convicted for organising all this but later acquitted.  Interestingly l can't recall any charges against the recepient of the gift.  Not sure what happened to these shares or the proceeds from them when Thaksin sold out to Temasek. .

[Mike Lister]

29 minutes ago, JimGant said:

Huh? That's Cyril's pension, not Nookie's. Why would she be responsible for paying income tax on it? If this is a govt pension, whereby home country has exclusive taxation rights on it, well, the tax situation is handled by the home country, without any regard of that cash leaving for Thailand. And, once in Thailand, since DTA says it's non assessable income (govt pension, remember), that the money that ends up in Nookie's bank account is a non income taxable event. Nookie can do what she wants with this money, with no income tax obligation. Maybe she makes a deal with Dad to act as a funds intermediary, to pay out to him what he wants. Or maybe they classify it as a loan. Or maybe a gift. But as a gift, and being well down from the 20M baht threshold to pay a gift tax -- nobody will know, or care, that this was a gift. You don't just drop the RD a line that says, oh, I made a gift to my daughter. RD is only interested in those fat cat Thais, who would like to gift their estates away, so that no inheritiance tax with be owed. This is where gifts, and subsequent gift tax, become important.

 

Oh, yeah. If pension is a private pension, whereby DTA gives Thailand exclusive taxation rights on it -- then Cyril now has to pay income tax to Thailand, not the home country. Same result -- money arriving in Nookie's bank account is after tax money. And NO tax holiday for being a gift.

Go back and read the post again, he doesn't mention it being a gift, only remitted to nookies account every month 

[JimGant]

9 minutes ago, Mike Lister said:

Go back and read the post again, he doesn't mention it being a gift, only remitted to nookies account every month 

So what? Does that make Nookie liable for the income tax on it?  It makes no difference what the characterization of the remitted money to Nookie's account is. The pension money remitted has had income taxes paid on it, by home country or Thailand, by Cyril. It you then want to characterize that remitted money as a loan, a gift, or just money I want my daughter's bank account to temporarily hold for me -- so be it. Only when you remitt money in excess of 20M baht does anybody care about the gift aspect. There's NO further income tax aspect to that money in Nookie's account, at least related to its remittance into the account.

 

Quote

Are international gift transfers between a married couple subject to the same generous tax free allowance of 20M baht given to domestic transfers?

This from: https://www.expattaxthailand.com/your-questions-answered/

 o

This observation points out the total misunderstanding about tax relief on gifts. The above observation assumes there's a 20M tax holiday on gifts -- taken as a tax credit against income given as a gift. This is baloney. The 20M tax exemption is just against the first 20M baht of gift -- given from proceeds AFTER INCOME TAX HAS BEEN PAID. 

 

Not sure why this is so hard to understand. Maybe, because it's not what tax-adverse folks want to hear.

[Yumthai]

20 minutes ago, JimGant said:

That doesn't square with this:

Quote

Cyril lives in Thailand year round with his lovely wife Nookie. He decides to give Nookie a present so he transfers 1,000 Pounds from his account with HSBC UK, to his wife's account in Thailand and says its a gift. Cyril's account at HSBC contains only savings that he earned a decade ago

 

We can agree to disagree. My view is the location of the gift and the way of transfer does not matter. The act of gifting occurs prior wire transfer/remittance.
 

[JimGant]

8 minutes ago, Yumthai said:

The act of gifting occurs prior wire transfer/remittance.

So, you're saying the act of gifting some how affects the taxability of the money being gifted? Don't think so.

[Mike Lister]

4 minutes ago, JimGant said:

So what? Does that make Nookie liable for the income tax on it?  It makes no difference what the characterization of the remitted money to Nookie's account is. The pension money remitted has had income taxes paid on it, by home country or Thailand, by Cyril. It you then want to characterize that remitted money as a loan, a gift, or just money I want my daughter's bank account to temporarily hold for me -- so be it. Only when you remitt money in excess of 20M baht does anybody care about the gift aspect. There's NO further income tax aspect to that money in Nookie's account, at least related to its remittance into the account.

 

Cyril is transferring his pension to Nookies account every month in Thailand, it's not said it's a gift, only that nookie is the beneficiary of those funds. It isn't said either whether UK tax is already paid on that money or not, presumably it has been UK taxed.

 

By transferring that pension monies to his wife's account, Cyril is avoiding remitting assessable income to Thailand in his own name and nookie is receiving overseas income that must be declared. Since it's not said it's a gift, only that it's recurring monthly payments (which doesn't look at all like a gift under current rules), Cyril is avoiding tax and nookie is avoiding tax on the income she receives. At a minimum, Cyril is guilty as charged because he's hiding his income from tax and has no other income on which to live, the TRD must presume that nookie returns at least some of that money to pay for his living expenses, ergo, it is not a gift and cannot be one.

 

Can nookie then argue that the income she received was not assessable, if so on what basis? It's not a gift, that much is clear because it's monthly payment. Is it a transfer of funds between husband and wife,  possibly, So is this escape clause valid or is Cyril trying to avoid Thai tax by remitting to his wife, his own income that requires assessment in Thailand.   

[Mike Lister]

3 minutes ago, JimGant said:

So, you're saying the act of gifting some how affects the taxability of the money being gifted? Don't think so.

We agreed yesterday to put this issue on the list of unknowns (which was done) and to move on.

[Yumthai]

1 minute ago, JimGant said:

So, you're saying the act of gifting some how affects the taxability of the money being gifted? Don't think so.

There could be (income) tax on the money and/or the gifting act itself depending on the country tax law where the gift occurs and the tax residence status of the gifter, but imo not in Thailand.

[Ben Zioner]

3 hours ago, Ben Zioner said:

Your answer is quite useful, I insert below a Q&A that seems says a lot about gift topic.

 

Probably shouldn't quote meeself, but in the Q&As there is also the answer about the use of plastic cards in and outside of Thailand.

[JimGant]

6 minutes ago, Mike Lister said:

Cyril is transferring his pension to Nookies account every month in Thailand, it's not said it's a gift, only that nookie is the beneficiary of those funds. It isn't said either whether UK tax is already paid on that money or not, presumably it has been UK taxed.

 

10 minutes ago, Mike Lister said:

Can nookie then argue that the income she received was not assessable, if so on what basis? It's not a gift, that much is clear because it's monthly payment. Is it a transfer of funds between husband and wife,  possibly, So is this escape clause valid or is Cyril trying to avoid Thai tax by remitting to his wife, his own income that requires assessment in Thailand.   

 

Geez, how'd you go so far adrift. Whether Cyril remits money to Nookie, to the builder of his new condo, to the soi dog foundation -- makes no matter. None of those are on the hook to pay income taxes on Cyril's remittance. Cyril is. Self-assessment. He goes to RD, says he remitted X amount of assessable income, so I am liable. RD doesn't care where the money ended up -- that's not a taxable event. Remember, that was an earlier argument, where we concluded, for sure, the final use of the money has no impact on its income taxation liability.

 

Quote

So is this escape clause valid or is Cyril trying to avoid Thai tax by remitting to his wife, his own income that requires assessment in Thailand.   

Huh? All along I've been saying Cyril is paying income tax to either home country, or Thailand. No attempt at avoid tax by remitting to wife. And no possible way of avoiding income tax -- by saying the remitted monies are a gift.

[Mike Teavee]

1 hour ago, JimGant said:

This observation points out the total misunderstanding about tax relief on gifts. The above observation assumes there's a 20M tax holiday on gifts -- taken as a tax credit against income given as a gift. This is baloney. The 20M tax exemption is just against the first 20M baht of gift -- given from proceeds AFTER INCOME TAX HAS BEEN PAID. 

 

Not sure why this is so hard to understand. Maybe, because it's not what tax-adverse folks want to hear

Perhaps people struggle to understand it because there is no evidence that it’s true & indicators that it’s not. 
 

Same with your stance on Credit Card usage, absolutely no facts to back up your stance but indicators from UK (only other country that I’m aware of which taxes on a remittance basis) & statements from ExpatTax to suggest your wrong. 
 

If you’re so sure that you’re right, share the proof with us all so we can put the matter to bed. 
 

[Mike Teavee]

1 hour ago, Ben Zioner said:

Probably shouldn't quote meeself, but in the Q&As there is also the answer about the use of plastic cards in and outside of Thailand.

Quote from the ExpatTax FAQ, go to https://www.expattaxthailand.com/your-questions-answered/# & search for Credit… 

 

Credit cards and debit cards are quite a grey area, as they are not specified in the Thai income tax law. Under audit, if it is seen that these are being used for day-to-day expenses and living, then credit card usage is likely to be classed as remittance. If you use your debit card, it depends on the source of the funds in the debit account. If it is classified as foreign-sourced income, then it is assessable income.
 

 

 

Edited May 23 by Mike Teavee

[Mike Lister]

1 hour ago, JimGant said:

 

 

Geez, how'd you go so far adrift. Whether Cyril remits money to Nookie, to the builder of his new condo, to the soi dog foundation -- makes no matter. None of those are on the hook to pay income taxes on Cyril's remittance. Cyril is. Self-assessment. He goes to RD, says he remitted X amount of assessable income, so I am liable. RD doesn't care where the money ended up -- that's not a taxable event. Remember, that was an earlier argument, where we concluded, for sure, the final use of the money has no impact on its income taxation liability.

 

Huh? All along I've been saying Cyril is paying income tax to either home country, or Thailand. No attempt at avoid tax by remitting to wife. And no possible way of avoiding income tax -- by saying the remitted monies are a gift.

 

70) The third scenario is not agreed by everyone and is contingent upon further input from the TRD. It suggests that if the foreigner gifts offshore assessable income, direct to a Thai resident, the foreigner must report that income as if they themselves had received it directly.

 

UNKNOWNS

 

S) -  If a foreigner gifts offshore assessable income, direct to a Thai resident, the foreigner must person report that income as if they themselves had received it directly.

 

 

[Mike Teavee]

41 minutes ago, Mike Lister said:

As said elsewhere, credit card usage is not defined in TRD law because it is only the transport layer, just as a TT, cash and a cheque is. 

I think the point is, if TRD Audit you & find that you’ve been using an overseas credit card for all of your living expenses then they’re going to class it as remitted income & a “Sniff Test” suggests they’re correct. 
 

Buy a new laptop/plane ticket on your OS CC & (IMHO) they’re not going to class it as a remittance. 
 

[JBChiangRai]

I think a strategy for a foreigner married to a Thai would be for the Thai spouse to open up a bank account in husband's country.

 

Farang to gift half his overseas taxed income to his wife, paying it into her overseas bank account which she remits to Thailand.

 

Farang brings his half to Thailand as assessable income and they both live respectively on their own half of that income, being careful to always take turns paying or split bills 50/50.

[redwood1]

7 hours ago, KhunHeineken said:

Wouldn't you agree that my example, and your reply, is the situation of thousands of expats across Thailand? 

 

This would mean, "gifting" is not an option for them. 

 

Section 37 of the Thai Revenue Code. 

 

https://www.rd.go.th/english/37746.html#:~:text=Section 37 Bis Any person,exceeding 1 year or both.

 

"Section 37 Bis Any person intentionally fails to file tax returns prescribed under this Title in order to evade or in an attempt to evade tax, shall be subject to a fine not exceeding 200,000 Baht or an imprisonment for a term not exceeding 1 year or both."

 

Pretty scary, Mike, but as you say, the law applies equally.  I'm surprised you allowed yourself to post it. 

 

 

And what about Thais?....Is there a reason almost every person in these tax threads willfully ignores the subject of Thais not having payed taxes? 

 

You say Section 37 Bis Any person that intentionally fails to file tax returns could get fines and maybe jail time .....Would that not also include Thais too?

 

This is a serious question......

 

Doesn't this new income tax also include Thais or is it just for retired expats who dont have a LTR visa..

 

I have yet to see any thing in the news educating and explaining to the Thais all their new income tax responsibilities that they will have starting in the year 2024..... 

[Mike Lister]

4 minutes ago, JimGant said:

If I send assessable income to my wife's bank account, my condo builder, my maid's bank account -- it's not logical that they would now be responsible for its income taxation. So, yeah, it's logical that I, the remitter am responsible for paying income tax on this remittance. Again, the purpose of that remittance -- build a condo, gift, loan, pass-thru to me -- doesn't affect who's responsible for paying the tax on that remittance.

 

But, hey, we're in a circle jerk on this, so let's give it a rest. 

The rules of the thread are that anything that goes onto the list of unknowns, doesn't get debated or argued, for or against, again.

[Yumthai]

8 minutes ago, Mike Lister said:

Regardless, whilst the new tax rule is new for Thais also, the subject of Thai income tax is not

Indeed Thai income tax is not a subject for Thais.

[Mike Lister]

3 minutes ago, Yumthai said:

Indeed Thai income tax is not a subject for Thais.

We had lunch with Thai friends today, she manages a hotel, he is a fitness instructor at a five star, both file returns every year. They had not heard anything about the new tax rule and said there's nothing in the Thai media about it.

[Mike Lister]

Just now, JimGant said:

For ever and ever? So the braintrust following this thread can never ever contribute to eventually solving the issue?

Until NEW information arises. I think it's self evident that we don't want the same players making the same stale arguments repeatedly, championing their pet causes, so let's not do that shall we!

[Ben Zioner]

2 hours ago, Mike Teavee said:

Quote from the ExpatTax FAQ, go to https://www.expattaxthailand.com/your-questions-answered/# & search for Credit… 

 

Credit cards and debit cards are quite a grey area, as they are not specified in the Thai income tax law. Under audit, if it is seen that these are being used for day-to-day expenses and living, then credit card usage is likely to be classed as remittance. If you use your debit card, it depends on the source of the funds in the debit account. If it is classified as foreign-sourced income, then it is assessable income.
 

 

 

There is also this interesting bit, which didn't surprise me though:

 

"Thailand signed up to the automatic exchange of information – Common Reporting Standards (CRS) – in 2020. They receive data from over 130 countries that are signed up to CRS. Thailand’s Revenue Department have links with other revenue department software, and they share information automatically every quarter for bank accounts, pensions, credit cards, as well as the account balances and transactions within that quarter for Thai tax residents. Therefore, the information is already being remitted and sent to the Thai Revenue Department."

[Mike Lister]

34 minutes ago, Random8 said:

Where can I find this "list of unknowns"?

It's at the end of the document linked below but you may only see the list, if you promise to read the entire document first. 

 

 

[Mike Lister]

6 minutes ago, Random8 said:

 

 

When I click the link, I get a screen that says :  "Oops! This content can no longer be edited. It may have been moved or deleted, or too much time may have passed since it was posted for it to be edited."

 

I'm not trying to edit it, just read it.  The same thing happened to me when I first tried to read it before writing my comments here.

 

Honestly, while I deeply appreciate your service to all of us in creating the document and participating in these long discussions, I don't want to read the entire document (pretty sure you were only joking anyway).  So much will not apply to me.  Marriage, pensions, gifts, etc.  I only read the US IRS tax code that applies to me.  Same should apply in Thailand.

 

That's weird. Try this link and tell me what happens, it works fine for me.

 

 

[KhunHeineken]

4 hours ago, JBChiangRai said:

I think a strategy for a foreigner married to a Thai would be for the Thai spouse to open up a bank account in husband's country.

 

Farang to gift half his overseas taxed income to his wife, paying it into her overseas bank account which she remits to Thailand.

 

Farang brings his half to Thailand as assessable income and they both live respectively on their own half of that income, being careful to always take turns paying or split bills 50/50.

My thinking is the same as some other members, and that is, if "gifting" if going to be such an easy way for the masses to avoid paying tax, the Thai government will change the laws. 

 

That said, I would think at a minimum, and I agree with you 100%, the Thai missus is going to need an offshore bank account at some stage, even if it's a Cambodian bank account, which is just next door, for any chance of either "gifting" or "splitting" tax liability as a possibility in the future. 

[Mike Lister]

I've decluttered some more....this time, the recent 11 post exchange about equality between foreigners and Thai's. Whilst indeed interesting, it doesn't have a lot to do with the topic.  My fault really since I encouraged it, Bad Mike!

[Presnock]

21 hours ago, Mike Lister said:

It depends what his tax position is at the end of the year, only that will determine what his tax position is, along with his TEDA. It also depends on whether he remitted assessible income or tax free income to pay for the medical emergency.  There is no yes/no answer to your question, it depends on a series of factors, including the point in the year when the emergency occurred and whether he is able to leave the country and not remain Thai tax resident.

 

I strongly suggest you read the tax guide I linked earlier and stop raising questions. You've posted over twenty times in the past two hours at a rate of over one post every eight minutes hence you have dominated my time and thread. Desist, now! This is not the Mike Lister/Kuhn Heineken chat show!

 

 

Yes, a lot of folks continue to ask questions of all kinds based on their individual situation and yes, many others may be in the same type situation but since readers of this forum come from a variety of countries, many with DTA's and totally different tax situations in other countries and several generous individuals have given freely of their time to try to answer as many as they can but in a majority of the cases over the last few weeks, I fail to see WHY folks don't seem to understand that Mike and the other generous folks can not predict the future nor can they be all-kowing in many tax situations - many haveadvised everyone using this forum or listening to tax agents, seminars etc, they are only guessing at what the final interpretation by the Thai Revenue Department/govt that might or might not affect all or none of us so we need to give these generous guys a hearty thanks and a break from the oft repeated and possibly off the wall tax questions.  Again, from the beginning I was totally ignorant of all the local tax laws...fortunately, I didn't break any Thai tax law as my pension is a government pension.  I didn't know that about the remitting funds, etc, gifts any of that stuff nor about the DTA but, shortly after this forum let us know about the new interpretation, I read what Mike and others put together for general reading and always the advice that has been passed on - NOTHING that anyone tells you is definite about the new interpretation until the final comes out...I researched the documentation of the Thai's, the DTA so that I learned entirely about my particular situation.  I know for sure I will not be affected unless everybody is affected and laws/treaties are changed so although I read this subjecet regularly, I am amazed that Mike and others have as much patience as they do, repeating over and over the same stuff.

Again Mike and Co. thanks for helping me out a long time ago! Take care be healthy and safe. Enjoy this lovely country and great available food.

[bamnutsak]

On 5/19/2024 at 3:08 AM, Lorry said:

Buy air tickets abroad,  don't buy them in Thailand (often cheaper abroad anyway)

 

Tickets are issued (SITI, Sold Inside, Ticketed Inside) in the country where travel begins. If you are flying THL-XXX-THL, then the ticket will be issued in Thailand in THB. And that cost/price would be assessable income.

 

Years ago you could utilize SOTI, Sold Outside, Ticketed Inside, but no longer possible.

 

Sucks when you drop 120,000 on a business-class ticket.