Hi ndfansince53,
First of all, if someone is applying for a VIPER Permanent Visa, based on retirement they are required to set up a Brazilian bank account and have those funds, USD $2000 per month (retiree and up to 2 dependents), plus USD $1000 per month for each additional dependent transfered. So the CPMF would be charged on ALL transactions. As if that isn't bad enough you would also be required to pay yet another tax on the transfer of funds into the account from abroad (international transfer) the IOF - Imposto sobre Operações Financeiras, which is 3.8% of the value of the transaction.
You are NOT required to transfer all of your pension to the Brazilian account, just the minimum required amount, and I'm sure that your US bank will gladly arrange to transfer ONLY that amount automatically each month. The legislations for the VIPER application itself only requires that the US bank confirm your ability to transfer that amount, you must set up the account upon arrival.
NOTE: Neither the CPMF or IOF have anything at all to do with one's income taxes, they are charged OVER AND ABOVE income taxes for both Brazilians and expats.
For US citizens it's complicated, since there is no bilateral Tax Treaty between the USA and Brazil.
You will be required to file your annual 1040 Income tax in the USA and pay tax on your pension.
As a permanent resident of Brazil you will also be required to file a DIRF - Declaração de Impostos de Renda Pessoa Física each year and you will need to report your pension income (all of it, not just what was transfered) as world income. You may or may not end up taxed on that in Brazil as well that's completely up to the Receita Federal as there is no Treaty. If you are taxed in Brazil you may qualify for a reduction of taxes payable on your US return, I don't know how your tax laws work.
You WILL NOT be charged CPMF or IOF on any ATM withdrawals
You WILL be charged CPMP and IOF on any transfers/deposits to your Brazilian account from abroad.
You WILL be chared CPMF on any and all transactions you make on your Brazilian account, paying bills, withdrawals, cheques, transfers, etc.
I'm quite fortunate, being a Canadian and in that I got permanency based on a Brazilian child and not retirement. Canada and Brazil have a bilateral Tax Treaty and it is clearly stated that my pension income is taxable only in Canada unless I naturalize as a Brazilian citizen and only then taxable in Brazil. I clearly would not naturalize for that and a whole host of other reasons. My pension is NOT transfered to a Brazilian account and I don't have one. I withdraw those funds from an ATM here and thus I do not pay IOF, won't need to pay CPMF if it comes back in either. Since my "income" is not taxable in Brazil I don't need to file a DIRF either because I fall under the exempted taxable income minimum.
Cheers,
James
expat.com Experts Team