Category: Q-Z

Top British companies using Luxembourg tax avoidance scheme ‘like a magical fairyland’ to save billions

Papers show firms used internal loans and interest payments to cut tax bills Leaked tax documents show arrangements were signed off by EU state They are legal, but are predicted to trigger calls to stop firms avoiding taxes British companies using scheme include Dyson and drugs group Shire Some of… – Continue reading

UPDATE 2-Israel arrested UBS adviser, 13 others, in tax evasion investigation

Nov 5 (Reuters) – Israel arrested 14 people, including a senior UBS investment adviser, as part of an investigation into Israelis allegedly holding undisclosed bank accounts with UBS worth hundreds of millions of euros, the Tax Authority said on Wednesday. All 14 had been released on bail soon after their… – Continue reading

Indian Government Loses Major Tax Case to Vodafone

Vodafone sign in India. Photo: Ishan Khosla. Used under Creative Commons license. Vodafone recently won a rare – but potentially very significant – victory over Indian tax authorities. The Bombay High Court dismissed the government demand for the company to pay 30 billion rupees (about $490 million) for a share… – Continue reading

Maine’s largest landowner, billionaire media magnate avoids millions in taxes with inversion deal

NEW YORK — Shifting the address of his Liberty Global Inc. from Colorado to London last year didn’t just put billionaire John C. Malone in a position to reduce his company’s tax bill. He also took precautions to avoid the capital-gains hit that the so-called inversion would trigger for him… – Continue reading

$50K wrapped in newspaper, computer with 2 hard drives, diamonds hidden in toothpaste tube: Trial of former UBS executive dredges up Swiss banks’ shady past

FORT LAUDERDALE, Fla./ZURICH — From bundles of cash inside scraps of newspaper to setting up shell companies, the trial in Florida of a former UBS  executive is a reminder of the extreme methods some Swiss bankers used to hide clients’ cash. Raoul Weil, 54, is the highest ranking Swiss banker… – Continue reading

Europe’s tax haven investments in Africa

In front of European Commissioners, leading politicians, chief executives of huge multinationals, senior bank bosses and billionaires, the Egyptian investment tycoon was asked to set the tone of the forum, a three-day lobbying event funded by the EU. Dr Heikal is founder and chairman of Qalaa, an African investment fund… – Continue reading

UBS Sets Aside $2 Billion For Currency Rigging And Tax Evasion Settlements

UBS, Switzerland’s largest bank, has had to set aside Sfr1.84bn (or £1.2 billon / $1.9 billion) in legal provisions to pay for possible fines and to settle regulatory investigations. It has also warned shareholders that these costs are likely to be “at elevated levels” for the “forseeable future”. The Swiss… – Continue reading

Tabcorp calls for overseas-based online bookmaker crackdown

Tabcorp is pushing the Federal Government to even the playing field when it comes to wagering. Tabcorp’s chairman Paula Dwyer wants a ban on rival offshore betting companies operating in Australia. An estimated 14 per cent of betting by Australians is with non-licensed offshore operators, Ms Dwyer told shareholders at… – Continue reading

Tim Hortons-Burger King merger approved by Competition Bureau

Canada’s Competition Bureau says that Burger King’s plan to buy Tim Hortons does not pose a competitive threat to the fast food industry. The antitrust watchdog issued a No Action Letter (NAL) Tuesday, confirming that it reviewed the proposed transaction and concluded that it will not, at this time, “challenge… – Continue reading

Wright Medical Will Merge With Tornier in All-Stock Deal

Wright Medical Group Inc. (WMGI), a U.S. maker of bone implants, will merge with Tornier NV, creating a new company valued at $3.3 billion in the latest proposed tax inversion since tighter rules were announced last month. The legal address for the new company, to be called Wright Medical Group… – Continue reading

How Far Up Switzerland’s Biggest Bank Did U.S. Tax Evasion Scam Reach?

The secret binder lay wedged in a hidden drawer inside a filing cabinet in his office on the Bahnhofstrasse in Zurich, the heart of the world of Swiss private banking. Martin Liechti, a former top private banker at Swiss bank giant UBS, privately called the binder his “CYA file,” a… – Continue reading

Offshore firms still get government contracts

The Treasury Department has spent millions of dollars on federal contracts for companies that have shifted their legal address abroad, even as the Obama administration pushes to rein in the practice. Just last month, Treasury Secretary Jack Lew moved to limit the appeal of those tax deals, known as inversions,… – Continue reading

European Tax Investigations

In June, the European Commission (“EC”) announced the opening of three investigations into tax rulings in Ireland, Luxembourg and the Netherlands and, in particular, into tax rulings applied by Ireland to Apple, by Luxembourg to Fiat Finance and, last, by the Netherlands to Starbucks. In October 2014, the EC announced… – Continue reading

Key witness, Liechti, testifies in UBS tax evasion trial in Florida

(Reuters) – A key witness in the federal tax evasion trial of a top Swiss bank executive took the stand on Thursday to testify against his former boss, Raoul Weil, who is accused of conspiring to conceal up to $20 billion in U.S. taxpayers’ assets in secret offshore accounts. The… – Continue reading

Penal consequences force taxpayers to report deals that are not taxable: Vijay Iyer

Business Standard  October 23, 2014 Last Updated at 23:20 IST The Bombay High Court recently in the case of Vodafone India Services Private Limited (Vodafone) held that the foreign direct investment (FDI) received by the Indian company in the form of share capital cannot be taxed in India under the… – Continue reading

US-driven quest against money laundering: Standard Chartered to close thousands of UAE accounts

Standard Chartered has notified thousands of UAE small and medium enterprise customers it is closing their accounts as it responds to pressure from US regulators to cut its risks following an anti-money laundering settlement. “We regret to notify you that Standard Chartered Bank will no longer be able to provide… – Continue reading

UK: Charities And VAT ‘Abuse’

There is a common misunderstanding in the charity world that tax avoidance, and its ugly sister – tax abuse, cannot be regarded as applying to charities except where charities are ‘hijacked’ to line the pockets of wealthy ostensible donors. But that is simply not the case. A charity which seeks… – Continue reading

Swiss bank secrets begin to emerge

Echegaray says account holders can take part in country’s fiscal amnesty If Argentines who hold 4,040 undeclared bank accounts in Switzerland don’t normalize their fiscal status and pay their debts, the AFIP tax bureau will file a complaint before the Office of Economic Crime and Money-Laundering (PROCELAC) requesting it investigates… – Continue reading

India: Vodafone Victorious In Multi Million Transfer Pricing Battle, Yet Again!

Bombay High Court holds that shares issued at a premium by a resident entity to a non-resident entity is a capital account transaction and does not give rise to any income; Income arising from an International Transaction between AEs must satisfy the test of ‘income; as provided under the ITA… – Continue reading

Apple and other tech giants now have to pay their fair share

Ireland puts an end to a tax loophole that saved Google, Apple, Microsoft, and Facebook billions in taxes “Double Irish” might sound like a drink that corporate tax lawyers reach for at the prospect of paying higher tax bills, but it’s actually the name of a controversial — albeit legal… – Continue reading

Bombay High Court ruling on taxability of share premium in the Vodafone India case

The much-awaited decision of the Bombay High Court was pronounced on October 10. Transfer pricing adjustment carried out in Shell/Vodafone case has been at the centrestage of every public discussion on Indian transfer pricing legislation. The incredulous stand taken by the tax authorities has evoked a strong response from investors… – Continue reading

Spain’s Tax Breaks, TD Bank, Ex-UBS Banker: Compliance

The European Union expanded its crackdown on illegal tax breaks, ordering Spain to recover money from companies that benefited from rules encouraging merger activity outside of the country. The European Commission said the Spanish measures unfairly rewarded companies for buying stakes in foreign competitors. Telefonica SA (TEF) last year lost… – Continue reading

Commission’s Tax Drive Unsettles Multinationals

Europe’s antitrust regulator is encroaching on what has been the preserve of national governments. There’s a new tax sheriff in town. Europe’s top antitrust regulator, the Brussels-based European Commission, has launched an unexpected assault on what it suspects are sweetheart tax deals for multinational companies, plowing into an area traditionally… – Continue reading

Steris, the latest to renounce U.S. Citizenship, Only Paid a 16.3% Tax Rate Over Three Years

After announcing Ohio-based Steris Co.’s plans to become British for tax purposes on Monday, CEO Walter Rosenbrough later said on a conference call, “We’re not typically users of aggressive tax policies and I don’t think we are here.” That’s his story, and he’s sticking to it. But even a cursory… – Continue reading

Time to Make Corporations Pay Taxes They’re Avoiding

Blue-ribbon corporations are deserting our country “to avoid paying taxes but expect to keep receiving the full array of benefits that being American confers, and that everyone else is paying for,” Fortune magazine reports. That’s right, Fortune wrote it; not Pravda. In a scathing article titled “Positively Un-American” by Allan… – Continue reading

Tokyo District Court Allows Tax Saving from Share Repurchase

On May 9, 2014, the Tokyo District Court reversed a large tax that had been imposed on a large U.S. multinational’s Japanese holding company (“Japan HoldCo”). Under the Japanese Corporate Tax Law, if a shareholder returns shares to an issuing company (i.e., the issuing company acquires treasury shares), a portion… – Continue reading

Tax-Lowering Deals Keep Coming as Steris Unfazed

The U.S. government’s attempt to prevent companies from seeking a tax address outside the country hasn’t stopped Steris Corp. (STE) The Mentor, Ohio-based provider of hospital sterilization products and services announced today that it will buy the smaller Synergy Health Plc (SYR) and establish the combined company’s tax address to… – Continue reading

Can the EU tame the multi-national tax dodgers? Why Europe wants to turn the screw on the big guns

The screw is being turned on American companies that use complex structures to whittle down their tax bills. But is the latest EU probe a paper tiger or a game changer? It was supposed to be good news. Amazon’s announcement yesterday that it would hire 1,000 staff was dressed up… – Continue reading

AbbVie Says It Reconsidering Deal With Shire

The drugmaker AbbVie said Tuesday it is having second thoughts about its deal to combine with British counterpart Shire after the U.S. government created new limitations on the tax benefits of incorporating overseas. North Chicago, Illinois-based AbbVie said it notified Shire that its board intends to reconsider the recommendation it… – Continue reading

Alleged mastermind of UBS tax evasion scheme faces trial

(Reuters) – Former UBS bank executive Raoul Weil was the mastermind of the Swiss bank’s illegal offshore operations that helped thousands of Americans evade taxes, prosecutors said at the start of his federal trial on Tuesday. Weil, 54, was the third-highest ranked executive at the Zurich-based wealth management firm and… – Continue reading

Shareholders in BES firms seek information on €1.6m transfer

Cash in companies run by businessman Declan Conway was moved to two offshore companies Shareholders in two Business Expansion Scheme (BES) companies run by businessman Declan Conway have written to him demanding to know why almost €1.6 million was transferred from both firms to a number of offshore entities. Between… – Continue reading

Vodafone Wins Another Indian Tax Case; This Time Over Transfer Pricing

Vodafone has emerged victorious against the Indian taxman in the latest bout of litigation between the two. The important point for the rest of us being what it tells us about those endless claims of tax avoidance and tax evasion by large companies. It’s not just that large amounts of… – Continue reading

What Yahoo and Nokia’s Offshore Cutbacks Tell Us About India

Yahoo! just made about $9 billion in cash from Alibaba Group’s initial public offering, and investors are licking their lips at the thought of how Marissa Mayer might spend it. Snapchat? AOL? Well, here’s one area you shouldn’t expect her to invest in: offshoring more jobs to India. The company… – Continue reading

Nokia’s Largest Plant to Shut Down in India

BANGALORE, India — One of the world’s biggest cellular phone manufacturing plants, located in the southern India city of Chennai, will stop production of mobile phones and down shutters after Nov. 1. Microsoft, its lone customer, has terminated a subcontract agreement. “Microsoft has informed Nokia that it will be terminating… – Continue reading

US Tax Inversion Planners Respond To Treasury Measures

The non-legislative measures put forward by the Treasury Department on September 22, to deter multinationals from using corporate inversions to move their tax residence abroad and move away from the high United States tax rate, have so far produced a mixed bag of results. The measures are aimed at preventing… – Continue reading

IRS Denies Treaty Benefits Despite Lack of Treaty Shopping

In Starr International Company, Inc., v. United States, the taxpayer (“Starr International Company, Inc.” or “SICO”) filed a complaint in the United States District Court for the District of Columbia seeking a tax refund from the IRS of approximately $38 million.  The refund is allegedly due to an overpayment of… – Continue reading

Canada: Tax Court Of Canada Allows Foreign Tax Credit Generator Arrangement

Major changes have occurred with respect to foreign tax credit (FTC). The Department of Finance announced in the federal budget of March 4, 2010, a proposed legislation regarding FTC generators (FTCG) and released modified draft legislation on August 27, 2010. These new FTCG rules target the FTC per subsections 126(4.11)-(4.13)… – Continue reading

State aid: Commission investigates transfer pricing arrangements on corporate taxation of Amazon in Luxembourg

The European Commission has opened an in-depth investigation to examine whether the decision by Luxembourg’s tax authorities with regard to the corporate income tax to be paid by Amazon in Luxembourg comply with the EU rules on state aid. The opening of an in-depth investigation gives interested third parties and… – Continue reading