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2
Keir Starmer: Friends Say He Desperately Needs a Break
I'd fully support 2 Tier Keir having a break. May I suggest 3 decades as a suitable period? -
2,265
What Movies or TV shows are you watching (2024)
With Christmas looming, I decided to watch again my favorite Christmas movie: Die Hard 2. Does anybody have any recommendations for other Christmas movies woth watching? (Not It's a Beautiful Life, please) -
8
Village in Panic as Giant Python Swallows Wild Boar & Lies Motionless in Rubber Plantation
rubber plantation, so people have machetes and not one dare to just cut off the head? -
36
Thai Court Rules Traffic Fines Can't Block Vehicle Tax Renewal
how about i shove it right up yer ass..... where it belongs, cuz they do absolutely nothing for safety -
4
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41
I want to be a teacher
Go find a crazy homeless bag lady, the 2 of you will have lots to discuss in your future years together -
852
Introduction to Personal Income Tax in Thailand
Your description describes Roth IRA qualified distributions. Roth IRAs were established contemporaneously with the Thailand-U.S. tax convention so their special character was not addressed in the convention or the the technical explanation. In the model convention from 2006 (https://home.treasury.gov/system/files/131/Treaty-US-Model-TE-2006.pdf) Roth IRA (Section 408A) plans were noted on page 11 and treatment of them was discussed under the technical explanation of Article 17 paragraph 1 on pages 54-55: " However, the State of residence, under subparagraph (b), must exempt from tax any amount of such pensions or other similar remuneration that would be exempt from tax in the Contracting State in which the pension fund is established if the recipient were a resident of that State. Thus, for example, a distribution from a U.S. "Roth IRA" to a resident of the other Contracting State would be exempt from tax in the other Contracting State to the same extent the distribution would be exempt from tax in the United States if it were distributed to a U.S. resident. The same is true with respect to distributions from a traditional IRA to the extent that the distribution represents a return of non-deductible contributions. Similarly, if the distribution were not subject to tax when it was “rolled over” into another U.S. IRA (but not, for example, to a pension fund in the other Contracting State), then the distribution would be exempt from tax in the other Contracting State." I recognize that this treatment of a Roth IRA is not binding, but it would provide support for argument that Roth distributions are not assessible income but rather savings to the extent of their valuation as of December 31, 2023. -
5
UK: Jamaican Drug Offender Avoids Deportation After ECHR Appeal
The ECHR is a joke. It's a shame it's so difficult to leave.- 1
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