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Securities held in nominee name (USA brokerage customers)

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Anyone missing out on refunds of Thai corporate tax because they use an offshore broker (offshore from here) to hold Thai securities (and thus are held in nominee name not in your own name in which you could/do file a Thai tax return under)?

Example, an American with a US brokerage account, it could even be an old law IRA account possibly, holding Thai stocks. (And can't file a complete Thai return as a 180 day or more Thai resident).

I chickened out after being fielded a potentially unfriendly question, instead of an answer, from Chiangmai Revenue (Thai Revenue) on this. Years ago. But maybe there are other Americans in the same situation, and if so, we do something as I am quite certain the US-Thai Double Tax Treaty is in our favor.

It's a clear issue with the Nondiscrimination Clause because a Thai national would never have the same issue, but only because Thai securities regulations ensure it is like that, but those other Thai laws (regs) are not enforceable by a non-Thai (notwithstanding that under Thai revenue laws, a resident is a resident even if they are not Thai).

I am ex-enrolled and have an MST from Golden Gate. I'm very solid on this.

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