Author: ONF

China central bank approves offshore yuan investment programme

SHANGHAI: China’s central bank has approved a pilot programme allowing some domestic institutional investors to buy offshore yuan products, the official Shanghai Securities News said, as Beijing pushes ahead in internationalizing its currency. The People’s Bank of China (PBOC) has recently approved the so-called Renminbi Qualified Domestic Institutional Investor (RQDII)… – Continue reading

FATCA Update: Treasury Clarifies Obligations of Participating FFIs to Report Pre-Existing Accounts

Earlier today, Treasury and the IRS issued yet another correcting amendment to the previously-issued regulations implementing the Foreign Account Tax Compliance Act (FATCA).  FATCA become effective on July 1, 2014, and generally requires participating foreign financial institutions (FFIs) to begin reporting information regarding their U.S. account holders to the U.S…. – Continue reading

IP tax regimes to be abolished and replaced by new “nexus”- based regimes

On 11 November 2014, the UK and Germany made a joint announcement about a proposal they had developed to address some of the concerns raised over the OECD’s suggested approach to dealing with preferential IP tax regimes. These regimes will close to new entrants from June 2016, and will be… – Continue reading

HMRC needs freedom to settle tax claims to address case backlog, says expert

HM Revenue & Customs (HMRC) should be allowed to offer settlements to resolve existing disputes over alleged tax avoidance, an expert has said.18 Nov 2014 Litigation & International Arbitration Enforcement UK Europe Tax disputes expert James Bullock of Pinsent Masons, the law firm behind Out-Law.com, said the measure would help… – Continue reading

Spanish Tax Office clarifies anti-abuse rule applicable to dividend distributions benefiting from the EU Parent Subsidiary Directive

A recent binding tax ruling recognised that the historical background of a multinational group is a key factor in considering whether a non-EU ultimate parent should trigger the anti-abuse rule which applies to exemption from dividend withholding tax. In a nutshell, the Spanish Non Resident Income Tax Law (NRIT), provides… – Continue reading

US Corporate Giants Pay More to CEOs than in Federal Taxes

Seven of the biggest U.S. corporations received billions of dollars in tax refunds from the Internal Revenue Service, while dolling out an average of US$17.3 million to CEOs. While Congress is set to renew a slew of corporate tax breaks, new research published Tuesday found some of United States’ biggest… – Continue reading

Puerto Rico – Online reporting, payment of use tax by bonded importers reinstated and effective today

November 18:  A requirement for bonded importers to declare and pay use tax on goods imported into Puerto Rico has been reinstated and is effective today, November 18, 2014. These rules were reinstated by Administrative Determination No. 14-27 (November 6, 2014) as issued by the Puerto Rico Treasury Department. Background… – Continue reading

Final regulations – Failure to satisfy gain recognition agreements (GRAs) reporting requirements

November 18:  The Treasury Department and IRS today released for publication in the Federal Register final and temporary regulations (T.D. 9704) concerning the treatment of U.S. and foreign persons that fail to file gain recognition agreements (GRAs) or that fail to satisfy other reporting requirements associated with transfers of property… – Continue reading

29% Of Largest Corporations Pay More To CEO Than Uncle Sam

CEG says the U.S. corporate tax system is in desperate need of reform A recent report from the Center for Effective Government (Fleecing Uncle Sam) highlights that many large U.S. companies pay little to no corporate taxes, and a few even get tax rebates from the federal government. Moreover, in… – Continue reading

FATCA: Are Transnational Criminal Networks Influencing US Policy?

The New York Times’ report on prominent American think tanks receiving some $92 million from a minimum of 63 governments since 2011, prompted Rep. Frank Wolf (R-Va.) to ask Attorney General Eric Holder, a long overdue question: “Should think tanks be allowed to take undisclosed donations from foreign governments?” According… – Continue reading

Jean-Claude Juncker faces censure vote over Luxembourg tax schemes

Eureopean Union chief’s actions as prime minister of Luxembourg attacked over alleged role in creation of tax haven Jean-Claude Juncker is facing a vote in the European parliament to declare him unfit for his post as head of the EU executive because of his alleged role in turning Luxembourg into… – Continue reading

Cyprus: Cyprus India Relations – Cyprus May No Longer Be A Tax Haven For Funds Or May It?

A publication in the Economic Times has caused much debate in India since after blacklisting Cyprus for not sharing information on tax evaders, India is now looking to take away the favourable tax treatment available to investors from the European tax heaven under the bilateral tax treaty between the two… – Continue reading

FATCA – Form 1099-DIV reflects reporting requirements

November 18:  The IRS, by releasing a transmittal message, noted that final versions of Form 1099-DIV and the related instructions for 2015 reflect the FATCA filing requirements for certain foreign financial institutions (FFIs). The instructions [PDF 181 KB] to Form 1099-DIV note that beginning in 2014, an FFI with a… – Continue reading

Swiss Seek Better Image in Germany After Tax-Cheat Cases

Switzerland’s ambassador to Germany said his country is working to improve its image after years of revelations that Germans used Swiss banks to avoid taxes. Ambassador Tim Guldimann pointed to Switzerland’s support of an international agreement on automatic tax-data sharing in Berlin in October as a sign of his country’s… – Continue reading

Lebanese Offshore Companies: Why it is so difficult to open a bank account in Lebanon?

Beirut, November 17, 2014: All-inclusive offshore solutions provider ‘Lebanon Offshore’ and auditing and consulting firm ‘Majzoub & Partners CPAs-Nexia International’ organized a conference titled “Why is it so difficult for Lebanese offshore companies to open a bank account in Lebanon?” on November 14, 2014 in Badaro, Beirut. Attended by a… – Continue reading

Barbados and US sign FATCA agreement

THE GOVERNMENT of Barbados is committed to the implementation of global standards for the supervision and regulation of the international business and financial services sector. This affirmation came today from Minister of Industry, International Business, Commerce and Small Business Development, Donville Inniss, prior to signing a Foreign Account Tax Compliance… – Continue reading

G20 tax reform plan should prevent another Lux leaks

The G20 Communique is good news on the international tax reform front. As part of the G20 commitment to boost economic resilience the Communique commits G20 nations to taking action to ensure fairness in the international tax system. This means they are looking at ways to ensure profits are taxed… – Continue reading

France, a Tax Haven? Yes, for Companies From Microsoft to Huawei

Move over, Ireland. Companies from Microsoft Corp. (MSFT) to China’s Huawei Technologies Co. scouring Europe for fiscally attractive shores are turning to an unlikely country: France. As a base for research and development teams, that is. Tax breaks for R&D, 5.6 billion euros ($7 billion) this year alone, combined with… – Continue reading

G20 tax avoidance pledge ‘still leaves poor countries vulnerable’

Oxfam director Winnie Byanyima says what is on the table is not enough to stop poor countries being ‘bled dry’ Moves by G20 nations to tackle corporate tax avoidance are welcome but will only begin to uncover the full problem while leaving poor countries still vulnerable to exploitation, tax justice… – Continue reading

New Zealand To Get Tough With International Tax Evaders: To Work With OECD To Enforce Transparency And Compliance

New Zealand is planning to crackdown on tax evaders and combat the menace of avoidance by international firms. As part of the exercise, New Zealand will work with an international action plan being spearheaded by the OECD.  This was stated by Finance Minister Mr. Bill English. He told media persons… – Continue reading

Taxman’s new take on transfer pricing will attract foreign investments

In today’s global economy, where multinational companies do business in different geographical and tax jurisdictions, the need for arm’s length pricing of related party transactions is a growing concern for revenue authorities. Tax bodies are increasingly requiring multinationals to document their related party transactions. Where these transactions are not well… – Continue reading

G20 endorses OECD tax avoidance timetable

The latest G20 leaders’ summit in Australia, which ended yesterday, has endorsed the various strands of international tax work being undertaken by the European Commission and by OECD, including work on the Base Erosion Profit Shifting (BEPS) project Prime Minister David Cameron said there had been ‘important breakthroughs’ in making… – Continue reading

MLPs Can Generate Tax Bills In Retirement Accounts

It’s a surprise to many people that MLPs generate taxable income in retirement plans requiring a tax filing and payment of taxes. Traders and investors are interested in using their IRA and other retirement plan accounts (collectively referred to as “retirement plans”) for making “alternative investments” in publicly traded master… – Continue reading

Metlife Completes Merger of Three Life Insurance Companies and One Former Offshore Reinsurance Subsidiary

MetLife, Inc. (NYSE:MET) today announced that it had completed the mergers of its subsidiaries MetLife Insurance Company of Connecticut, MetLife Investors USA Insurance Company, MetLife Investors Insurance Company and Exeter Reassurance Company Limited. The merged company has been renamed MetLife Insurance Company USA and is domiciled in Delaware. All necessary… – Continue reading

South Africa: President Zuma Wraps Up Brisbane Visit

Pretoria — President Jacob Zuma has concluded his visit to Brisbane, Australia, where he led the South African delegation to the G20 Leaders’ Summit, says the Presidency. The main outcome of the Leaders’ Summit was a commitment to lift the G20’s Gross Domestic Product (GDP) by at least an additional… – Continue reading

Beijing’s Interest in Offshore Tax Evasion Limited to Corrupt Officials

Fifty-one countries signed the Multilateral Competent Authority Agreement in Berlin on Oct. 29 to fight offshore tax fraud and evasion. The agreement aims to put an end to banking secrecy by sharing tax-related information with member states. Missing from the signatory list are the United States and China. China’s absence… – Continue reading

BEPS: G20 leaders mark ‘significant progress’

G20 leaders have made “real progress” towards ensuring that “big companies pay the tax they owe”, David Cameron said at the end of the G20 summit in Brisbane yesterday. “There are now over 92 different countries and tax authorities properly sharing information and, as the OECD set out at this… – Continue reading

Reliance Jio Ties Up With Lenders for $1.5 Billion Loan Facility

New Delhi: Telecom operator Reliance Jio Infocomm has arranged credit facilities worth $1.5 billion with lenders, including Bank of America and Barclays, to refinance existing loans. Mukesh Ambani-led RJio would utilise the latest credit arrangements to re-finance debt tied up by it in 2010. The new loan facilities are guaranteed… – Continue reading

Corporate Close-Up: The Burden of California’s Taxes and Fees on Limited Liability Companies

The limited liability company, or LLC, has become a popular form for organizing a business.  Using an LLC generally avoids the double layer of taxation encountered with a corporation while providing limited liability for its members, and offers more flexibility than S corporations in which corporations may not be shareholders. … – Continue reading

Businesswoman contests release of Cayman bank records

A high-profile businesswoman accused of using Cayman Islands bank accounts to dodge more than $7 million in taxes is seeking to challenge the use of information obtained by the U.S. Internal Revenue Service through a tax information exchange request. Cheryl Womack, a Kansas City businesswoman who has a home and… – Continue reading

Nigeria: Still On the Taxation of Foreign Companies Operating in Nigeria

IN July 2014, the Federal Inland Revenue Service (FIRS) sent letters to some tax consultants requesting their non-resident clients operating in Nigeria to file complete tax returns effective from 2014 tax year. In practice, non-resident companies file their tax returns on the deemed profit basis. Following an initial period of… – Continue reading

Benelux-China legal update

Recent months saw various important developments that are relevant to Sino-European trade and investment. These include (i) changes to the EU Parent-Subsidiary Directive, (ii) the entry into force of the double tax treaty between Luxembourg and Taiwan, and (iii) proposed changes to China’s Foreign Investment Catalogue and the Governmental Verifications… – Continue reading

India economy not yet mature for GAAR: ASSOCHAM

Apex industry body ASSOCHAM has urged the Centre to amend the Indian income-tax law so as not to introduce the general anti avoidance rules (GAAR) from assessment year 2016-17 as India’s economy is neither mature enough to stand up to its exacting standards nor is the tax administration ready to… – Continue reading

Bill Gates commit money to Unitus’ offshore fund; Rupee fund bags $4M more

The venture seed fund has already announced 14 investments in India. Impact investor Unitus Seed Fund (USF) has announced that its India-focused offshore fund vehicle has received commitments from Microsoft co-founder Bill Gates, besides Concur Technologies’ CEO Steve Singh and Diego Piacentini, SVP (international consumer business) at Amazon.com Inc. It… – Continue reading

Greek Ministry of Finance issues templates and guidelines for advance pricing agreement negotiations

ITR Correspondent In an effort to provide taxpayers with an integrated procedural framework for the negotiation of advance pricing agreements (APAs), the Greek Ministry of Finance recently released template application forms for both preliminary consultations and formal negotiations, as well as additional guidelines on the overall APA procedure. The forms… – Continue reading

Global tax avoidance crackdown has broad support – Bill English

There is broad global support for moves to curb international tax avoidance, says Finance Minister Bill English, on the sidelines of the G20 Leaders’ Summit in Brisbane. Cracking down on tax avoidance is one of the key agenda items at this weekend’s G20 Summit, where New Zealand is an invited… – Continue reading

G-20 leaders agree on $2 trillion boost to growth

BRISBANE, Australia — Under pressure to jolt the lethargic world economy back to life, leaders of G-20 nations on Sunday finalized a plan to boost global GDP by more than $2 trillion over five years. The fanfare, however, was overshadowed by tensions between Russian President Vladimir Putin and Western leaders…. – Continue reading

Chevron’s multi-billion tax dodging: We don’t agree

You know those annoying “We Agree” television ads by the fossil fuel corporate giant Chevron? The ones where an actor playing a student or a concerned member of a community “agrees” with supposedly noble objectives of this multinational? Those ads make me feel like puking. The objective of this campaign… – Continue reading

G-20 set for ‘very aggressive’ crackdown on tax avoidance

BRISBANE: Australia has vowed a “very aggressive” crackdown on tax avoidance at weekend G-20 talks, as a row rages over Luxembourg’s sweetheart arrangements with multinationals. Closing corporate tax loopholes and endorsing a common reporting standard to increase transparency are set to be a primary focus of the G-20 summit in… – Continue reading