[swx]

Hello Pat Jac –
Postfinance: to my knowledge, for a non-resident to open an account, the following three conditions must currently be met:
– Receive a Swiss income: such as AVS or Pension Fund, or a salary
– Special ties with Switzerland – (From what I understood from the family for example)
– Be able to prove that you have enough regular income yourself to live on –

[swx]

Hi Sokaris, Thanks for your research.
Spanish REITs Question:
Bloomberg wrote about these two REITs??? Sorry, it's a bit long - would it be worth looking at them as part of diversification??

Merlin Properties SA plans to become Spain's largest real estate investment trust by selling shares to the public by the summer, a person with knowledge of the matter said.
Merlin, a Madrid-based company managed by former directors of RREEF, will be more than double the size of Hispania Activos Inmobiliarios SA (HIS), an externally managed Spanish REIT that listed its shares earlier this month, said the person, who asked not to be named because the information is private. Hispania has a market value of about 530 million euros ($728 million).
Merlin's management will include David Brush, former head of Europe for Brookfield Property Group, who will be chief investment officer, the person said. The team will also include Ismael Clemente and Miguel Ollero, former directors of RREEF Spain and founders of Magic Real Estate, an asset manager and investment company with 2.8 billion euros of assets under management.
The planned share sale follows a stream of investors including Pacific Investment Management Co.'s Bill Gross, Quantum's George Soros and billionaire John Paulson who have invested in Spanish REITs betting on a rebound after a six-year property slump. Spain accepted a European bailout of its financial system and formed a bad bank in 2012 to take soured real estate assets off of lenders' books.
No one at Merlin Properties or Magic Real Estate was available to comment on the planned initial public offering.
Credit Suisse Group AG will coordinate the sale and will be joint bookrunner along with UBS AG (UBSN) and Deutsche Bank AG (DBK), the person said. RREEF is the former name of Deutsche Bank's real estate investment unit.
Merlin will invest in prime commercial real estate assets primarily in Spain and may invest to a lesser extent in property in Portugal, the person said. The company will take the form of a Socimi, the Spanish equivalent of a REIT.
Hispania Activos is one of two Spanish property companies that have listed their shares on the Madrid exchange this month. The other, Lar Espania Real Estate Socimi SA (LRE), has a market value of 417 million euros.
To contact the reporter on this story: Sharon Smyth in Madrid at ssmyth2@bloomberg.net

[swx]

Stock market transaction cost: Hello,
For the sake of rationality, I only use 3 currencies for my transactions – CHF/EUR/USD, each with their respective stock exchange: Swx, Xetra, New York Stock Exchange:
I sometimes make transactions in other currencies, but using only one of these exchanges:
Finnish stock type, traded at XETRA,
Canadian stock on the New York Stock Exchange.

The shares I buy are also traded on one of the exchanges mentioned
Does doing this result in high bank charges that would be a deterrent?

[swx]

Good morning :
Reit Spanish or Portuguese??
Does this kind of product exist? I imagine that we can conceive of a real estate capital gain in the medium term
In my case, I have to rule out buying an apartment - you would have to do some research on site yourself, which is not possible for me -
and to my knowledge, until recently at least the Notary, is responsible for registering the transfer deed, but not for
ensure that the seller is the owner of the property he is selling –

[swx]

Tax statement:
As far as I'm concerned, it clearly indicates that a real estate fund has REIT status, i.e. no wealth tax or income tax, which is the case, for example, with CS LIVING PLUS, etc.
or on the other hand those who do not benefit from this status: FIR real estate fund Romand, ANFOS – etc.
Otherwise, I don't see where to find this kind of information.
It clearly states the 5 data to indicate for an American title which pays quarterly income –
The collection of a quarterly coupon must be recorded at the conversion rate of the day, + at the end the rate fixed by the federal administration of Contributions, in respect of the assets it represents.
I am waiting for the response from the tax authorities to find out if the tax statement would be accepted, given that it provides all the information requested on their securities statement form.

[swx]

Thanks Jérôme for all the references indicated:
Declaration of securities
POSTFINANCE provides on request and for 200. chf the tax statement of Values and returns as of December 31, classified into 5 headings. I suppose that we can do the same with other banks.
As for the request for reimbursement of the additional US withholding tax, it must reach a certain amount.
If you can tell me on which form it says: Gross yield not subject to withholding tax, I'm interested...

[swx]

Hello J@L
I'm not an expert, but it was stated on a forum that non-recoverable 15%s are not a discount:
As for the US recovery, this must reach a certain amount –
My tax experience on the subject: a headache unless you have a detailed statement from your manager at the end of the year –
In fact, quarterly incomes are at different rates, the value of wealth at the end of the year is also different –
I had been interested in three highly recommended stocks, but unfortunately no account had been taken of a less promising financial future.
because it should be taken into account that in Europe
Coca-Cola – Anti-Obesity Campaigns –
Lorillard: Anti-smoking programs
VCO: Vino da Concha: Very important and profitable vineyards in Chile…but what about the health of their currency….

[swx]

Hello, I have a question:

– Constellium: this is a company that emerged from several others specializing in uranium processing:

– Dedicates a significant budget to research: self-packaging aeronautics - production sites in several countries –

US price 22 – Euro 14.50 – Turnover around 3.6 billion –

Title analysis, virtually none  

 

[swx]

Hospitality: thank you for your comment, I have removed this order: in fact, I had only retained the Health Building composition, whereas it is very much in the minority 

[swx]

Good evening, I would like to invest cash for the long term in CS REF: These products are not taxed. I study their reports and position myself on orders a few francs lower than their inventory value per share, which is currently the case for GREEN and HOSPITALITY – Is this a good approach? 

[swx]

Dividend taxation:

Rather than worrying about taxing French income, I dumped everything and invested the corresponding Euros in Northern European securities – Germany, Holland and Finland –

Bilateral tax recovery agreements with these countries are much clearer and less voracious.

 I just received my 2013 tax notice: includes full social security contributions for the years 2012 – 2013.

 (For French income, I had those from SCPI securities and shares which I have not yet managed to get rid of)

Switzerland not being a member of the European Community for 2 years, social security contributions are 66 % – approximately

I am obliged to advance it, until the judgment of the European Court is put into practice - then it will be some time before the reimbursements are made. Given the situation of the State's finances, I think

that I will have to wait several years – Given my age, it is unlikely that I will receive these reimbursements in my lifetime

so I will bequeath by will this amount to be recovered to my favorite nephew –

[swx]

Good morning

New York, May 22, 2013 – Constellium NV (NYSE: CSTM) (“Constellium” or the “Company”) announced today the pricing of its initial public offering of 22,222,222 Class A Ordinary Shares at a price of $ 15.00 per share. The Class A Ordinary Shares are expected to begin trading on May 23, 2013 on the New York Stock Exchange under the symbol “CSTM” and on or about May 27, 2013 on NYSE Euronext Paris under the symbol “CSTM”. The offering is expected to close on or about May 29, 2013, subject to customary closing conditions.

Constellium is offering 13,333,333 Class A Ordinary Shares and the selling shareholders are offering a total of 8,888,889 Class A Ordinary Shares (of which 5,037,037 shares are being sold by affiliates of Apollo Global Management, LLC (NYSE:APO) and 3,851,852 shares are being sold by affiliates of Rio Tinto Plc).

While its value had initially been estimated at 17 Euro, the issue of CONSTELLIUM: CSTM, at 15 USs, proved to be very laborious and on May 23 reached a low of US 13.26.

Can we estimate what its intrinsic value should be?

[swx]

Hello Chroom,
I thought this document might be of particular interest to you, if you were not aware of it.
If you find this copy-paste to be of no interest to your forum, please delete it – Swx

FRANCO SWISS TAX CONVENTION.

Federal Department of Finance (FDF)
The State Secretariat for International Financial Affairs SFI
August 2012
Questions and answers regarding the revision of the succession convention with France
Why is revision preferable to no agreement at all?
The convention guarantees legal certainty. Without a convention:
– risk of double taxation;
– France could apply its domestic law without restriction and there would therefore be no legal protection for taxpayers in the face of changes in French domestic law;
– no amicable procedure in case of doubt or in case of double taxation.
The revision obtained made it possible to extend the current agreement until the end of 2013.
Why is the review focusing on real estate companies?
– The revision closes a tax loophole. It will no longer be possible to avoid inheritance tax on real estate through a real estate company.
– Today, residents of Switzerland who own a property in their own name in France are at a disadvantage compared to owners domiciled in Switzerland who own a property in France indirectly via a real estate company.
– The revision is based on this point in principle on the CDI on income and wealth between France and Switzerland.
Is the nationality of the deceased and his heirs taken into account?
No. Only the domicile of the deceased and the place of residence of the heir are determining criteria. For example, a German domiciled in Switzerland and whose heirs reside in France is potentially affected by the revision.
Can we estimate the number of people affected on both sides of the border by this revision?
There are no statistics on this point. It should be noted that not all people who have ties in both countries are necessarily affected by the revision: everything depends on the structure of their assets (in particular real estate held directly or indirectly) and the place of residence of the heirs.
Is taxation at the heir's domicile contrary to international tax law?
This is not a legal anomaly:
– the comments to the 1982 OECD model succession convention provide for the possibility of inserting in this type of convention a subsidiary right of taxation (i.e. in the 2nd country, not that of the deceased) based on the nationality or domicile of the heir;
2/2
– heirs domiciled in France of a deceased resident in Germany are subject to treatment comparable to that provided for in the 2009 Franco-German convention on successions. The latter is even less favourable since it does not provide for a limitation on the duration of residence for heirs in France, unlike the Franco-Swiss project.
Is Switzerland's fiscal sovereignty being violated?
No. If a person dies in Switzerland and has heirs in France, Swiss cantonal law applies first (so-called primary tax law). Only then can the country of the heir, in this case France, exercise its right to tax the heirs (subsidiary tax law). In addition, France must credit any taxes that the heirs may have already paid in Switzerland.
If a deceased person domiciled in Switzerland owns shares in French companies (excluding shares in real estate companies), will his heirs have to pay taxes in France on these shares?
Yes, if his heirs are domiciled in France at the time of death and have been so for more than six years out of a ten-year period preceding receipt of the assets. No, if his heirs reside in Switzerland.
When can France and Switzerland denounce the current convention?
Both parties may terminate the agreement at the end of each year with six months' notice. The next deadline is therefore June 30, 2013 for December 31, 2013.
How many double taxation agreements on inheritances has Switzerland concluded?
Switzerland has concluded a total of ten conventions on successions (Germany, Austria, Denmark, United States, Finland, France, Great Britain, Norway, Netherlands and Sweden).
Are these conventions comparable?
A comparison of the various conventions concluded by Switzerland is not relevant. On the one hand, the inheritance tax law of the partner states differs, on the other hand these conventions were concluded

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