Reference no: EM133556148

Adriel's father in law Dennis is looking to acquire an investment property in Perth Western Australia. Based on information provided by the real estate agent in Perth the property will generate rent of $28,000 and rental expenses of $15,000. Dennis has been told that he will be liable to pay Australian income tax at the rate of 32% on the profit of $13,000.

The company needed additional staff from overseas to assist the company FTX. Kurt is a USA citizen who is based in the Bahamas. He is requested to go to Singapore to assist the company in business development. He is expected to spend 18 months in Singapore. He will arrive in Singapore on 17 August 1023. His role requires him to visit offices in Thailand, Malaysia, Indonesia and Philippines. He will spend 168 days each year outside of Singapore fulfilling that role. Singapore has a double tax agreement with Canada. Joshiah's brother Gregor is a gastroenterologist. He has been asked to undertake specialist research in Toronto for 18 months. He will be paid by the University of Toronto for his work approximately $150,000.

Issues they seek advice on:

1. Will Dennis be taxed on the profit of $13,000 in Singapore? Will he be able to claim a credit for the tax paid in Australia against his Singapore tax liability?

2. Advise Kurt whether he should be employed by the Delaware company or by FTX and which would be the better option tax wise for him.

3. Will he be required to pay tax in Singapore on all his income earned or only that portion for the work only actually done in Singapore.

4. For each basis period in Singapore will he be a tax resident or non-resident of Singapore?

5. Under the Singapore Canada Double Tax Agreement how will Gregor's income earned in Canada be taxed?

6. If the company FTX has a board meeting where the three directors in the Bahamas attend via zoom from the Bahamas, where is control and management of the company?