Category: A-E

Applied Materials and Tokyo Electron Call Off $10 Billion Merger

TOKYO — Two of the world’s largest manufacturers of the machinery used to produce semiconductors, Applied Materials of the United States and Tokyo Electron of Japan, on Monday dropped plans to merge after the Department of Justice said that combining their businesses would restrict competition. The proposed $10 billion deal… – Continue reading

How the Isle of Man aims to become the bitcoin capital of the world

Ireland might learn as the Isle of Man positions itself as the new bitcoin capital of the world While bitcoin is attractive because of its inherent decentralised nature, it has struggled to be perceived as a legitimate currency, given the lack of accountability and total absence of someone or something… – Continue reading

Pfizer Inc. (PFE) Rumored To Be Eyeing British Giant GlaxoSmithKline plc (ADR)

Pfizer Inc. (NYSE:PFE) went big exactly a year ago when it announced a takeover offer for UK-based AstraZeneca plc (ADR) (NYSE:AZN). The company’s decision to lap up AstraZeneca was seen as opportunistic; it being laced with controversy on many accounts, with some allegations behind the company’s proposition to acquire AstraZeneca… – Continue reading

New Tim Hortons owners slash corporate taxes post-Burger King deal

When Burger King’s owners first announced last summer’s mega-deal to gobble up Tim Hortons, the fast-food firm’s executives downplayed a key reason why they were acquiring the Canadian coffee chain and relocating corporate HQ to Canada: to cut its taxes. “Tax wasn’t really the driver of this,” Daniel Schwartz, the… – Continue reading

India: Transfer Pricing Regulations Engulfs Market Intangibles

Trade in today’s global era visualizes significant number of international transactions in form of transfer of goods, services, capital and intangibles. International transfers arise within the Multinational Enterprise group entities and are called intra-group transfer. What is actually paid by one entity to another entity in the intra-group transfer is… – Continue reading

US, UK funds approach India on MAT citing OECD

However, OECD being persuasive may not help funds based out of nations whose treaties do not give specific exemption The Indian government’s clarification that it would honour tax treaties while making a demand of Minimum Alternate Tax (MAT) at the effective rate of 20 per cent came as a relief… – Continue reading

BSI Provides Road Map For Future Swiss Bank Agreements

On March 30, 2015, the U.S. Department of Justice announced that it had entered into a nonprosecution agreement with BSI SA, the first Swiss bank to reach resolution with the U.S. government as to its potential criminal exposure for assisting its U.S. clients in engaging in tax evasion.[1] As part… – Continue reading

CONFERENCE PREVIEW: Succession, Cross-Border Tax And Trusts Under Spotlight In Geneva

Moves to create a supposed level playing field for succession issues in Europe, along with more established themes around automatic exchange of information and US extra-territorial tax powers make their appearance in a major Geneva-based conference later in April. Figures from the world of wealth management will gather at the… – Continue reading

‘Institutionalised theft’: Barclays’ PFI contracts based on rigged interest rates ‘bleeding NHS & schools dry,’ say activists

Political activists gatecrashed Barclay’s AGM in Central London on Thursday to highlight the role of private finance initiatives (PFI) in “killing off” Britain’s public services, racking up unsustainable debt, dodging tax and funneling profits offshore. Thursday’s demonstration marks the first of three planned days of protest to raise awareness about… – Continue reading

Edouard Perrin, French reporter, charged for role in Luxembourg tax-scheme leaks

Documents exposed secret deals to slash global tax bills of multinational companies A French journalist has been criminally charged in Luxembourg for his role in exposing how hundreds of multinational companies used secret deals with the European duchy’s government to slash their global tax bills — a scheme that CBC… – Continue reading

We’re Just Learning the True Cost of China’s Debt

The true cost of the debt that China’s real estate developers peddled to eager international investors during a five-year property boom is now becoming clear. Having found themselves shut out of local bond and loan markets seven years ago, a band of developers began looking elsewhere for funds. First an… – Continue reading

Relief for FIIs, India allays fears on tax claims topping US$6.4 bn

The government on Wednesday assured over 1,000 foreign institutional investors (FIIs) across the United States, Hong Kong and Singapore they can avail of treaty benefits to ward off tax demands on capital gains booked over the years till March 31, reports the Financial Express. The development is significant given the… – Continue reading

Big Medical Device Makers Decry Device Tax While Dodging Billions by Offshoring Profits

Stymied in their efforts to fully repeal the Affordable Care Act (ACA), Republican leaders in Congress continue their efforts to undermine the law by starving it of funding. Today, the Senate Finance Committee will consider legislation that would repeal some of the tax changes enacted to pay for the ACA…. – Continue reading

Parliament takes aim at corporate ‘looting’

MPs say transfer pricing, though legal, presents challenges when determining if firms have evaded taxation and they want the practice criminalised. The portfolio committee on trade and industry has heard calls for the criminalisation of transfer pricing – a practice that, when abused, results in large corporations shifting profits offshore… – Continue reading

Corporate Investigations & White Collar Defense – April 2015

In This Issue: • It’s Stifling in Here! SEC Rules That Companies Can’t Put Restrictive Language in Confidentiality Agreements That Could Potentially Stifle Whistleblowers • An Opinion on Opinions: U.S. Supreme Court Decision in Omnicare • Is OFAC the New Black? Schlumberger and PayPal—The Rise in the Enforcement of Sanctions… – Continue reading

The “Netflix tax” – coming to a country near you

The arrival of Netflix in Australia has brought into sharp relief the GST base erosion problem caused by global digital commerce. Along with the non-taxation of low-value imported goods, the absence of GST on services and digital products imported by consumers represents an omission from the tax base that is… – Continue reading

Higher taxes probably avoidable if transfer pricing abuses curbed, says Davis

IF THE South African Revenue Service (SARS) focused on recovering money from transfer pricing abuses‚ Finance Minister Nhlanhla Nene probably wouldn’t have had to raise taxes by 1% in his budget speech‚ Judge Dennis Davis‚ head of the Davis Tax committee, told Parliament on Tuesday. He was briefing the portfolio… – Continue reading

Tax boss rebukes Google, Apple and Microsoft over Senate inquiry eviden

Commissioner Chris Jordan delivers rebuke to multinational tech giants contesting evidence they gave to a Senate inquiry into corporate tax avoidance The tax commissioner, Chris Jordan, has delivered a public rebuke to multinational tech giants Apple, Google and Microsoft, vigorously contesting evidence they gave to a recent Senate inquiry hearing… – Continue reading

Bitcoin is now VAT-Exempt in Spain

Bitcoin transactions are exempt from value-added-tax (VAT) in Spain, says Spanish tax lawyer Alejandro Gómez, The General Directorate of Taxes, a subsidiary of the Spanish taxing authorities, made the statement in a response to a request from Gómez. According to Gómez, the consultation found that Bitcoin payments were a form… – Continue reading

India Unties $6.4 Billion Tax Knot That Rattled Investors

India said foreign portfolio investors can use tax treaties to reject demands on past capital gains, seeking to defuse a row that cast a cloud over the $48 billion poured into stocks and bonds from overseas. Foreign institutional investors domiciled in countries that have signed double taxation avoidance treaties with… – Continue reading

Mylan $23 Million Chairman Shows Looming Teva Culture Clash

Mylan NV Executive Chairman Robert Coury made $22.7 million, including $1 million for his personal use of the drugmaker’s two corporate jets, in 2012 and 2013. At Israeli rival Teva, shareholders in 2012 balked at raising the chairman’s salary to $900,000 a year. The contrast highlights the sharp differences that… – Continue reading

Luxembourg thrives after tax regime shake-up

An inflow of bank deposits to Luxembourg from Asia and the Gulf have replaced reductions from European countries such as France and Germany following an overhaul of the Grand Duchy’s tax secrecy regime, reports the Financial Times. Pierre Gramegna told the Financial Times in an interview that “bank secrecy had… – Continue reading

EIB must tighten rules on low tax jurisdictions, NGOs warn

The European Investment Bank (EIB) must tighten up its lending rules to prevent its money being funnelled through tax havens, NGOs have warned in a new report, reports EU Observer. The report ‘Towards a Responsible Taxation Policy for the EIB’, published on Tuesday (21 April) by transparency NGOs Re-Common and… – Continue reading

Government of India versus FPI: Is there a solution?

MUMBAI/NEW DELHI: Markets fell 500 points on Monday. Punters’ worries about current tax disputes between Modi Sarkar and foreign portfolio investors (FPIs) being one reason why the Sensex dived. There has been a battle of phrases between FPIs and North Block. And it looks as if this will be a… – Continue reading

Why Finance Minister Arun Jaitley is Pranab Mukherjee 2.0 for the markets

The Finance Minister has failed to assuage markets’ fears on the issue of retrospective tax Markets are getting jittery each time the finance minister or his ministry utters the T word. Finance Minister Arun Jaitley reminds the market of UPA’s finance minister Pranab Mukherjee, who introduced the now-dreaded retrospective tax…. – Continue reading

EIB: From bad banking to good banking

Like many other public banks, the European Investment Bank (EIB) leverages its own means by acting as a catalyst for private investment through various financial mechanisms. Too often, though, attempts to attract private capital result in unpredictable risks and higher-than projected costs for the public coffer, write Xavier Sol and… – Continue reading

Taxpayer Advocate Urges IRS to Ease FATCA Rules for Americans Abroad

Doing so would get rid of ‘overlapping and duplicative disclosure requirements,’ says advocacy group for Americans abroad The IRS’ taxpayer advocate is urging the tax service to simplify rules for Americans living overseas. Currently, foreign bank accounts must be reported both to the Treasury, in a Report of Foreign Bank… – Continue reading

Firms may raise record $20 bn via offshore bonds in ’15: Vijayan Subramani

Indian companies had raised a record $18.6 billion in 2014 through offshore bonds. This year, it may cross $20.50 billion, says MD, Treasury and Markets, India, at DBS Bank Vijayan Subramani. In an interview with Bhavik Nair, Subramani indicates Singapore dollar-denominated bond issues from India are likely to make a… – Continue reading

Taxpayer Advocate Recommends Merging FATCA and FBAR Reporting Rules

The National Taxpayer Advocate has recommended that the reporting rules under the Foreign Account Tax Compliance Act and for foreign bank account reports in effect be merged to simplify the duplicative disclosure requirements that make it difficult for American expatriates to have bank accounts in the foreign countries where they… – Continue reading

Tories forced to return £50k donation from US tax evader’s wife

Britain’s Conservative Party returned a donation of £50,000 from a wealthy businesswoman on Monday after it emerged she was once wanted on charges of tax fraud in the United States. Beatrice Tollman, founder of luxury hotel chain Red Carnation, made an election campaign donation to the Tories earlier this month…. – Continue reading

Australia reaches tax loophole crackdown deal with UK

Summary:Australia and the UK have reached a deal aimed at helping tackle profit-shifting practices by multinational companies, such as Apple, Google, and Microsoft. Australia and the United Kingdom have agreed to form a joint working group to tackle profit shifting by multinational companies such as Google, Apple, and Microsoft. The… – Continue reading

Corporate giants often get huge tax breaks, while poor, undocumented immigrants have paid billions in state taxes

Ben Franklin’s famous dictum, “Nothing is certain except death and taxes” is crying out for an urgent revision. Why? Because even if still holds true for people like you and me, it has little to do with some of the country’s richest corporations. The truth is that for corporate giants… – Continue reading

China: Asia Tax Bulletin – Spring 2015

CHINA Tax Free Reorganisations • With circulars 109 and 116 jointly issued in December 2014 by the Ministry of Finance and the State Administration of Taxation, the Chinese authorities have relaxed the conditions for internal reorganisations. • Circular 109 deals with internal reorganisations. Provided the pertinent requirements are met, the… – Continue reading

European Union: European M+A News, Spring 2015

EUROPEAN M&A DOS AND DON’TS FOR NON-EUROPEAN BUYERS Inbound M&A in Europe by non-European buyers increased in 2014 by 68.6% compared to 2013, representing over a third of USD 901.4 billion total European M&A.1 For non-European buyers the basic framework of transactions may be similar, but there are a number… – Continue reading

New transfer pricing monitoring unit to detect illicit outflows, says Atiur

Bangladesh authorities are working with counterparts abroad to recover proceeds of corruption (‘stolen assets’), in terms of the UN Convention Against Corruption (UNCAC), Bangladesh Bank (BB) Governor Dr. Atiur Rahman has said. The central bank chief disclosed this while speaking at an event title Addressing the Linkage Illicit Flows and… – Continue reading

Foreign Investors and India’s Tax Men Are Clashing Anew: Q&A

Nothing is certain in India except death and tax disputes. Ask foreign portfolio investors: they now face demands for past dues of as much as $6.4 billion. The wrangle stems from the Minimum Alternative Tax, or MAT, which officials say leads to a 20 percent levy on capital gains by… – Continue reading

Google, Rio, BHP, Apple: Tax the ‘selfish corporate rabble’

The head of the Business Council of Australia (BCA), Catherine Livingstone, has called for a national “conversation” about what the federal government and the business community euphemistically call “economic reform”. Ever in thrall to trickle-down economics, they manage to talk in “doublespeak”, a close relative of the doublethink that George… – Continue reading

Uranium demand is putting miner Cameco back on investors’ radar

The outlook for uranium, moribund for some time, is looking up. And that means shares of Cameco Corp., the Saskatoon-based miner one analyst calls “the only real blue-chip stock in the sector,” are up, too – about 20 per cent from their 52-week lows. The stock has received a host… – Continue reading

Studies show, Congress Favors the Rich

When Hillary Clinton recently borrowed Elizabeth Warren’s talking points and claimed “the deck is still stacked in favor of those at the top” (in our economic and political system) against regular working people, did she mention reforming the tax code — and then offer any solutions? The simple answer is… – Continue reading

America’s Most-Wanted Swiss Bankers Aren’t Hard to Find

At least 21 financial advisers in Switzerland charged with aiding American tax dodgers are at large With its tan marble floors and leather-clad reception desk, the staid Zurich offices of the Julius Baer Group, one of Switzerland’s largest private banks, are an unlikely place to find an alleged fugitive from… – Continue reading

DOJ Announces First Non-Prosecution Agreement Under the Swiss Bank Program

On March 30, 2015, the U.S. Department of Justice (DOJ) announced that it reached the first non-prosecution agreement under the Swiss bank program with BSI, S.A. (BSI). BSI, one of Switzerland’s ten largest banks, has agreed to pay $211 million in fines and cooperate in any related civil or criminal… – Continue reading