Latest news with #NRAs
Belfast Telegraph
2 days ago
- Entertainment
- Belfast Telegraph
Belfast eatery named ‘best restaurant in NI' and ranked among top 100 in UK awards
©Evening Standard The Muddlers Club in Belfast has been named one of the UK's 100 best restaurants – for the second year running. The restaurant in the Cathedral Quarter was placed number 76 on the list of the best places to dine in the UK in the National Restaurant Awards (NRAs). It was also named as the Best Restaurant in Northern Ireland. The Michelin starred restaurant led by chef Gareth McCaughey, is tucked away between Waring Street & Exchange Place in the city with a focus on modern dining using local produce. Meanwhile, The Ritz in London was named the UK's best restaurant at the National Restaurant Awards. Four months after executive chef John Williams steered the restaurant to two Michelin stars — many believed the accolade to be long overdue — the glamorous Mayfair dining room has climbed to the top of the list for the first time. Founded in 1906, the restaurant predates the title behind the awards, Restaurant magazine, by almost a century. It is arguably London's most glamorous place to dine and serves a menu of French haute cuisine, inspired in part by the dishes of the legendary Auguste Escoffier. It is also now the only one where men must wear a jacket and tie, while women are asked to arrive in evening wear. 'As a bastion of fine French food served in unashamedly refined surroundings, the Ritz stands alone in the UK,' said Restaurant editor Stefan Chomka. 'The top 100 restaurants list reflects the diverse nature of our eating out scene and the changing trends within it, whether they be less formality, more farm to fork menus, or embracing new cuisines, but it's also wonderful to see a restaurant unwavering in its focus finally get the recognition it merits. The Ritz is an exemplary restaurant.' Watch: Popular Belfast entry gets insta-worthy summer makeover In second place this year is Mark Birchall's Moor Hall in Lancashire, the most recent restaurant in the UK to be awarded three Michelin stars. In third place is the Ledbury, which was last year's winner. The list shows the continuation of the capital's dominance in the country's dining scene, with a total of 56 restaurants from London in the top 100 list. Other big London winners include Trinity (4), Bouchon Racine (5), Oma (6), Anglothai (7) and Dorian (10). The restaurateur of the year was named as David Carter, the man behind Oma, 2025's highest new entry, and Agora, the more casual restaurant below it, which is at 51. Restaurant group Super8's continued success is reflected in the list, with Mountain at number 11, Kiln at 13, and Brat at 54 — meaning only one of their operations, Smoking Goat, did not make the cut. Claude Bosi, meanwhile, achieved similar success with Bibendum re-entering the list at 39; his restaurant at the Peninsula hotel, Brooklands, made 20, and Chelsea's Josephine — formerly Josephine Bouchon — was announced at number 23. Bosi owns the latter with his wife Lucy. A restaurant now closed also features on the list: Lyle's, James Lowe's former restaurant in Shoreditch that ran for 11 years, sits in 21st place. Skye Gyngell, the Aussie chef behind Spring at Somerset House, was given the lifetime achievement award, recognising her contribution not just to the British culinary scene but also her work tapping into the confluence of food and culture, all the while overcoming a battle with rare skin cancer. The winners were announced at a lively ceremony at Magazine London in Greenwich on June 9. The National Restaurant Awards is Restaurant's annual countdown of the top 100 restaurants in the UK as voted for by the UK's leading chefs, restaurateurs, critics and food writers. Awards in full The full list of the UK's top 100 restaurants The Ritz Moor Hall The Ledbury Trinity Bouchon Racine OMA AngloThai Osip Ynyshir Dorian Mountain The Devonshire Kiln Restaurant Gordon Ramsay Woven by Adam Smith Ikoyi Lyla A Wong Da Terra Brooklands by Claude Bosi Lyle's Kitchen Table Josephine Bouchon Endo at the Rotunda Paul Ainsworth at No.6 Restaurant Pine Canteen The Unruly Pig Sabor Row on 5 Restaurant Sat Bains BiBi Kolae The Sportsman L'Enclume Higher Ground Camille Core by Clare Smith Claude Bosi at Bibendum Chishuru The Glenturret Lalique Frog by Adam Handling JÖRO Grace & Savour Updown Farmhouse Dongnae Le Manoir aux Quat'Saisons Opheem Restaurant Interlude KOL AGORA Akoko Chez Bruce Brat The Forest Side Gorse Humble Chicken Cornus Morchella Skof Sollip Cedar Tree by Hrishikesh Desai Starling Plates Wilson's The Kinneuchar Inn Solstice Annwn The Clove Club Wildflowers The French House Mýse Restaurant Hjem Sola The Angel at Hetton The Muddlers Club Heft Inver The Little Chartroom The Fordwich Arms The Black Swan at Oldstead Upstairs by Tom Shepherd The Grill by Tom Booton Hide The Parkers Arms Solo Fallow Forge at Middleton Lodge Lita The Quality Chophouse Planque Gymkhana Lisboeta Crocadon Luca The Seahorse The Palmerston Trivet St. John Maison François
Mint
07-05-2025
- Business
- Mint
How strategic estate planning can help Indians with US ties save big on taxes
Indians typically view the US as a land of opportunity. In today's interconnected world, in which global mobility is the norm, more Indians then ever before have ties to the US – not just through family, but business, financial, and other interests as well. Indians with relatives who are US citizens or based on the US face unique and complex US estate and tax planning rules, and ignorance around these often leads to high taxes and penalties. Careful planning is thus essential to minimise potential tax liabilities. That's because Indians who own US assets may be subject to US estate taxes regardless of their citizenship or residency status, even if they live outside the US. 'US persons' (i.e., US citizens and resident aliens) are subject to gift, estate, and generation-skipping transfer taxes on their assets worldwide. Those who aren't US citizens first have to determine whether they are considered a resident alien or a nonresident alien. This depends on factors such as time spent in the US, visa status, personal connections and so on. This is important since nonresident aliens are only subject to gift and estate taxes on assets located in the US (called 'US situs assets'). Also read | Block assessment 2.0: A sharper, fairer tax enforcement framework Non-resident aliens (NRAs) are typically Indian citizens who temporarily live in the US and do not intend to make it their permanent home. Typically, most of their wealth is located outside the US. However, they are subject to specific gift and estate taxes on their US-based assets such as real estate, stocks in US companies, etc. There is a generous US gift and estate tax exemption of $13.99 million (as of 2025), which is not available to NRAs. The exemption for NRAs is limited to $60,000. This is a very insignificant sum for high-net-worth individuals who own US stocks and real estate. Without adequate planning, they may end up paying high taxes in the US. India does not have an estate tax treaty with the US, so such are not creditable back in India. While appropriate planning and structuring can help mitigate gift and estate taxes (and one must consult a tax expert for this), it's important to note that for life insurance policies issues to NRAs by US companies, any transfers during their lifetime and the payment of death benefits are generally exempt from US estate taxes. Also read: Why do some stockbrokers want to access your contacts, calendar and other apps? There are some Indian exchange control nuances that need to be met before buying such policies, but using US life insurance to address estate tax disparities is worth exploring. Life insurance offers several advantages in estate planning for NRAs: Unlike US citizens and residents, who often transfer policy ownership to an irrevocable trust, NRAs can directly own a US life insurance policy without triggering estate taxes on the death benefit. Nonetheless, Indian nationals in the US whose family members, especially children, elect or aspire to be US citizens can make an irrevocable life insurance trust (ILIT) the owner and beneficiary of their US life insurance policy. Also read: This Pune resident saved ₹ 10 lakh in tax by transferring pension fund to NPS
Forbes
07-05-2025
- Business
- Forbes
Taxation Of Stock Options For Foreign Nationals Working In The U.S.
Stock options can be a lucrative form of compensation, but for foreign nationals who work in the ... More U.S., they present unique tax challenges. The U.S. retains taxing rights over income derived from U.S. employment, even after a person becomes an NRA. Understanding how the U.S. sources stock option income, potential double taxation risks, foreign tax credits and tax treaty possibilities are all critical for minimizing tax liability. getty Many foreign persons are employed in America and are given stock options as an incentive by the companies for which they work. When a foreign national works in the U.S. and is granted stock options, the taxation of these options can become complex, especially if the individual later leaves the U.S. and becomes a nonresident alien for tax purposes. This article examines how the U.S. taxes foreign individuals on stock options received for work carried out in America and the tax issues they face after leaving the U.S. and becoming NRAs. This article discusses non-statutory stock options , which are more commonly granted since they involve fewer restrictions and are easier to administer. When a taxpayer working in the U.S. is granted NSOs, there is typically no immediate tax liability. NSOs are not taxed at grant because these options generally lack a "readily ascertainable fair market value." As a result, taxation is deferred until the options are exercised. It is worth noting that problems can arise if the option strike price is set below the fair market value of the shares at the time of grant or if the plan otherwise runs afoul of Internal Revenue Code Section 409A, which governs deferred compensation. In those cases, the employee might owe tax and penalties immediately, even without having exercised the options. This is why it is important that the compensation package be reviewed by a tax professional. Options generally vest over time. A common schedule is four years with a one-year cliff. This means that no options vest until the employee has completed one year of employment. After that, 25% of the options vest, with the remainder vesting monthly or quarterly over the next three years. The right to exercise the options is tied to this vesting schedule. Once vested, exercising the options triggers taxation on the difference between the fair market value of the shares at the time of exercise and the option strike price. The difference is treated as ordinary compensation income. For example, if an individual pays $30 per share to exercise the option and the FMV at that time is $100, they must report $70 per share as ordinary compensation income. For the foreign national, the key issue is whether the U.S. still has the right to tax this income if the individual is no longer a tax resident when the option is exercised. The general rule is that compensation for services performed in the U.S. remains U.S.-sourced income. Since stock options are considered deferred compensation, the IRS applies specific income sourcing rules to determine how much of the income is taxable in the U.S. regardless of where the individual is living at the time of exercise. This 'grant-to-vesting' sourcing rule determines how much of the income should be treated as having a U.S. source. This sourcing rule compares days worked in the U.S. and outside the U.S. during the period between the date the options were granted and the date the stock options became exercisable (the vesting date). If, for instance, half of the vesting period occurred while the individual was working in America Youtube, then half of the income would be treated as having a U.S.-source and would be taxable by the U.S., even though the option was exercised after the individual became a nonresident alien. Thus, even after leaving the U.S., foreign nationals may owe tax on stock option income tied to services performed while they were in the U.S. Income treated as U.S.-sourced would be subject to withholding by the U.S. employer, typically at a flat 30% rate, unless a tax treaty applied providing a reduced rate or exemption. Double Taxation Is Possible A foreign country may also tax the stock option income. This means when the taxpayer leaves the U.S. and resides abroad, there is a risk of double taxation. Some countries tax stock options at exercise (in the same manner as the U.S.), while others impose tax only when the stock is sold. Using foreign tax credits or treaty benefits can reduce the tax impact, but when U.S. law and foreign law are involved, it becomes complex and is best examined with an international U.S. tax professional. U.S. Tax Upon Later Sale Of The Stock Once the taxpayer has purchased the stock by exercising the option, any future gain upon a later sale will be treated as capital gain. It is no longer taxed as ordinary income. If the stock is sold while the foreign individual is still a U.S. tax resident, the gain is taxed as either short- or long-term capital gain. If the stock was held for over 1 year it is long-term gain and taxed at preferential rates of 15% or 20%. The holding period starts on the day after the stock was acquired by exercising the option. If an individual is an NRA when selling the stock, the gain is generally not taxed by the U.S. pursuant to a special tax rule for foreign investors without significant physical presence. This difference in tax treatment makes it crucial to know one's U.S. tax residency status at the time of sale. For those with green cards, it is critical to properly sever U.S. tax resident status. Taxation on worldwide income will continue until U.S. tax residency is severed according to specific and detailed tax rules. Many green card holders do not realize that it is possible to have lost the right to live in the U.S. under the immigration rules, but still be subject to U.S. taxation under the tax laws. Example of Tax Savings Elena, a foreign national living and working in America was granted 10,000 NSOs in January 2022 with a strike price of $10 per share, which matched the fair market value of the shares at the time. The options vested over four years; 25% vested in January 2023 and the rest vested monthly thereafter. In 2025, while she was still a U.S. resident, Elena exercised 7,500 of her vested options when the shares were valued at $30. This resulted in a $150,000 spread between the price at which the shares were trading at the time of exercise and the strike price (7500 x $30 = $225,000 MINUS 7500 x $10 = $75,000). This amount is treated as ordinary compensation income on which Elena will pay U.S. tax at her marginal tax rate. Later that year, assume Elena leaves America and becomes an NRA. In 2026, assume she exercises her remaining 2,500 options at a time when the fair market value had gone up to $35 per share. Under the 'grant-to-vesting' source rule, the portion of income attributable to Elena's services performed while in the U.S. remains taxable. If half of the vesting occurred during her performance of services in the U.S., then half of the $62,500 gain is treated as U.S.-sourced compensation. As an NRA, Elena will be subject to 30% withholding on that portion, unless a tax treaty applies to reduce it. By exercising her remaining options after she became an NRA, Elena avoided U.S. taxation on the portion of the income tied to her non-U.S. service. This results in significant tax savings that would not have been available had she exercised everything while still living in the U.S. Stock Options And State Taxation State taxation is a crucial consideration when employees receive stock options, particularly if they have lived or worked in multiple states before exercising the options. Many U.S. states allocate stock option income based on where the employee performed services during the vesting period. Even if an individual moves to another state, or becomes an NRA, they may still owe state taxes on the portion of the income tied to the work performed in that state. The Tax Rules Are Complex Stock options certainly offer the possibility of great returns and can incentivize an employee. When stock options are granted to foreign nationals who work in the U.S., they present unique tax challenges. The U.S. retains taxing rights over income derived from U.S. employment, even after a person leaves America and becomes an NRA. Simply leaving the U.S. does not make the tax issues disappear. In order to minimize tax, the taxpayer must understand how the U.S. sources stock option income, the potential double taxation risks, and whether any tax treaty provisions can apply. Proper planning such as use of foreign tax credit strategies and treaty benefits, can help reduce the tax burdens and avoid compliance problems. Given the complexity, an experienced U.S. tax professional should be consulted. Stay on top of tax matters around the globe. Reach me at vljeker@ Visit my US tax blog It is an invaluable guide in all areas of U.S. international tax, keeping you ahead of US tax changes impacting your life, family or business, including tax developments on stock options. NO ATTORNEY-CLIENT RELATIONSHIP OR LEGAL ADVICE This communication is for general informational purposes only. It is not intended to constitute tax advice or a recommended course of action. Professional tax advice should be sought as the information here is not intended to be, and should not be, relied upon by the reader in making a decision.
