Category: Individuals

National Assembly’s Procrastination to Lead to Extra Taxes with Korea-US FTA

The National Assembly of South Korea is postponing the ratification of the Foreign Account Tax Compliance Act (FATCA) for the automatic exchange of South Korean and U.S. taxpayers’ financial information. Under the circumstances, South Korean financial companies are about to be forced to pay more than 600 billion won (US$521… – Continue reading

Banks bear the brunt of tax laws which force foreigners to open an account

Banks say tax rules cracking down on property speculation force them to screen for money-laundering at their own cost. Banks are refusing to open accounts for foreigners if they think the costs outweigh the benefits. New property and tax laws launched late last year made “offshore persons” buying or selling… – Continue reading

Bank account requirement makes it tougher to pay tax in NZ: expert

A change to our tax rules aimed at foreign property investors is likely to affect many people, a tax expert says. A bill poised to be passed by Parliament this week may increase the red tape for anyone based overseas doing taxable business with this country. The Taxation (Residential Land… – Continue reading

Hong Kong: Recent Development On CRS / AEOI & CbC Reporting

In August 2015, the Organisation for Economic Co-operation and Development (OECD) published the first edition of the Common Reporting Standard (CRS) Implementation Handbook to provide practical guidance to assist government officials in implementing the Standard for Automatic Exchange of Financial Account Information in Tax Matters (AEOI). The AEOI and CRS… – Continue reading

Irish Revenue Explains Estonia DTC Royalty Tax Changes

The Irish Revenue has issued a brief explaining how the implementation of a most favored nation clause in Ireland’s tax treaty with Estonia will affect the tax treatment of royalties. Ireland’s Double Tax Convention (DTC) with Estonia became effective in 1999. It contains a provision whereby the tax treatment of… – Continue reading

Australia Moves to Remove ‘Double Taxation’ on Digital Currency

For a month starting May 3, The Treasury of the Australian government will be accepting submissions from interested parties to comment on a newly-released discussion paper entitled ‘GST treatment of digital currency’ as part of the 2016-17 Budget. The Treasury says the government has realized that consumers are ‘double taxed’… – Continue reading

Singapore banks discuss cooperation to fight money laundering

SINGAPORE (BLOOMBERG) – Singapore’s biggest banks are in talks about setting up a system for sharing information on prospective clients, in an effort to combat money laundering in the city-state. DBS Group Holdings, OCBC and UOB are exploring the possibility of a countrywide model for anti-money laundering and enhanced client… – Continue reading

UK: Proposed Changes To The Non-Dom Regime From April 2017

The tax treatment of non-domiciled individuals is changing again from April 2017. The changes were first announced in the 2015 Summer Budget, and a Consultation document was issued in September 2015 setting out further details. The proposed changes target three key areas: The taxation of non-domiciled individuals who have been… – Continue reading

US plans reporting requirements for foreign-owned disregarded entities

US disregarded entities owned by foreign persons would be treated as domestic corporations under regulations proposed by the US Internal Revenue Service (IRS) on Friday (REG-127199-15). The new rules would apply for purposes of the reporting, record maintenance, and other compliance requirements that apply to 25% foreign-owned domestic corporations under… – Continue reading

Canada’s record on finding tax evaders is dismal

Only a week after the so-called Panama Papers burst into the media spotlight early last month, the Canadian government issued a news release vowing to “crack down on tax evasion and tax avoidance.” The leak of a staggering 11.5 million documents from a Panama City law firm promised to reveal… – Continue reading

Residence-Based Taxation Put Forward For Americans Abroad

With regard to the increasing talk in the US Congress on tax reform, American Citizens Abroad (ACA) has provided the House of Representatives Ways and Means Committee with a full reform proposal for the enactment of residence-based taxation (RBT) for American expatriates. ACA has said lawmakers should enact RBT instead… – Continue reading

Governor of U.S Tax Haven Delaware Launches Blockchain Initiative

Governor Jack Markell will extend Delaware’s hospitality (home to more corporations than people) to Blockchain firms. Speaking at the Bitcoin community’s event in New York, Consensus 2016, Democratic Governor Jack Markell announced an initiative by the U.S State of Delaware to embrace the blockchain industry. His plan is to provide… – Continue reading

Japanese money in offshore tax havens could solve a lot of problems at home

TOKYO — Do the rich and powerful really dodge taxes? They do. The “Panama Papers” – 11.5 million or so documents leaked from a Panama law firm specializing in tax shelters of various kinds and degrees of ingenuity – are shocking, however, not only to the naively innocent but to seasoned… – Continue reading

US Court Dismisses Case Against FATCA Disclosures

The US District Court for the Southern District of Ohio has dismissed a case brought by Senator Rand Paul (R – Kentucky) and a group of individuals, who attempted to make several challenges to the Foreign Account Tax Compliance Act (FATCA) and the Report of Foreign Bank and Financial Accounts… – Continue reading

Australia announces multinational tax avoidance in federal budget

Australia announced a further crackdown on multinational tax avoidance in its annual budget on Tuesday, including the planned introduction of a UK-style diverted profits tax (DPT), that it expects to raise A$3.9 billion over the next four years. The government is creating a new Tax Avoidance Taskforce of 1,000 specialist… – Continue reading

UN urges countries to stem tide of firms profit-shifting to tax havens

Unctad thinktank shows firms funnelled $221bn in 2015 through low-tax jurisdictions such as the Netherlands and tax havens in the Caribbean The UN has urged governments to stem the flow of funds to tax havens after companies funnelled $221bn (£152bn) into countries with low tax rates last year. The Netherlands… – Continue reading

UAE – Jersey trade relations: from a tax haven to taxonomy

As with any offshore financial centre, secrecy has been synonymous with the Channel Islands of Jersey. But the reason for the strong relations between the self-governing British dependency and the United Arab Emirates – still not known to many – is not confidentiality alone. It has not been so long… – Continue reading

Tax planning in the context of Panama Papers

Panama Papers’ disclosures now and earlier dealings of Vodafone through Cayman Islands are stories of famous tax havens, which evoke discussions of how tax evasion takes place. These are all direct taxes, mainly corporate tax, and not indirect tax. These are cases of tax planning that come to the fore… – Continue reading

Equalization levy resistance shows up BEPS’ challenges

The Internet and Mobile Association of India’s (IAMAI’s) pushback against the equalization levy on e-commerce transactions introduced in the union budget shows up the difficulty revenue authorities will have when they try to protect their tax base. The last word on this subject hasn’t been said and the original budget… – Continue reading

FATCA documentation for US-based trusts

Introduction Even though a trust may be established under the laws of a US state and have a US trust company serving as trustee (hereinafter a ‘US-based trust’), this does not mean that it is a US domestic trust for income tax purposes. If non-US persons make substantial decisions for… – Continue reading

Tax evasion prosecutions in Canada fall dramatically

Prosecutions for tax evasion almost halved across Canada in just three years, figures released to Global News show. Fewer Canadians were taken to court for tax evasion in every part of the country between 2012-13 and 2014-15. In Ontario, cases fell to 47 from 119 just three years earlier. Manitoba… – Continue reading

Thomson Reuters Releases Special Report on OECD”s Country-by-Country Reporting Requirements

Thomson Reuters Checkpoint has just released a special report addressing the European Commission’s Anti-Tax Avoidance Package (ATA) and other global Country-by-Country Reporting (CbCR) developments designed in conformity with the OECD BEPS Action 13 recommendations. The report, BEPS Filing Requirements for Multinationals Under Country-by-Country Reporting, will help multinational enterprises (MNEs) gauge… – Continue reading

Mexico: Multilateral Agreement For Automatic Exchange Of Transfer Pricing Documentation

On January 27, 2016, 31 Countries (among them Mexico) signed the Multilateral Competent Authority Agreement for automatic exchange of Country-by-Country reports (the “Agreement”) to be received from their taxpayers as part of the implementation of Action 13 of the Base Erosion and Profit Shifting Action Plan issued by the Organisation… – Continue reading

LuxLeaks whistleblower trial begins in Luxembourg

The former PwC employee turned whistleblower behind the LuxLeaks scandal that implicated Luxembourg in industrial tax avoidance went on trial in the tiny European duchy on Tuesday. Antoine Deltour, 30, a former auditor at global accounting firm PwC, is accused of stealing documents from his employer before he quit the… – Continue reading

DNB to reveal tax haven customers

Scandal-plagued Norwegian bank DNB has agreed to turn over information to state tax authorities about Norwegian customers who have held bank accounts set up in tax havens by DNB’s own operation in Luxembourg. The future of DNB’s board of directors, meanwhile, was in doubt following heavy criticism that neither DNB’s… – Continue reading

Troubling Implications of the BEPS Project: Interest Deductibility

On October 5, 2015, the Organization for Economic Cooperation and Development (OECD) issued final tax policy recommendations stemming from its Base Erosion and Profit Shifting (BEPS) project. The reports, endorsed by the G20 Finance Ministers on October 8 and by the G20 leaders at their November 15-16 summit, consist primarily… – Continue reading

Banks to help create a national register of offshore firm owners

Greek banks and the state are in the process of creating a national register for offshore company owners, in compliance with a European Union directive to that effect. The register will be created on the Teiresias databank, known from its list of insolvent borrowers. Access will be granted to the… – Continue reading

Tax haven firms cashing in on Scotland’s PFI scandal

COMPANIES profiting from schools and hospitals built under private finance initiatives in Scotland are based in tax havens such as Jersey and Guernsey. An analysis carried out by the Sunday Herald has revealed numerous examples of PFI projects in Scotland which have owners based offshore. The owners include an offshoot… – Continue reading

Australia to Have Public Register to Record Tax Avoidance

Australia is following the path of the United Kingdom and is planning to create a public register that will unmask the shell company owners who take advantage of tax avoidance by the international companies. The Guardian reported that the Canberra government has expressed on making a public commitment to put… – Continue reading

Tax Avoidance: The Real Scandal Is What Multinational Companies are Getting Away With

Embarrassing our politicians and other public figures into publishing their tax returns is muddle-headed and distracting, however briefly satisfying. What we should be focused on is not what individuals are paying to the Treasury, interesting though that is, but unreasonable tax avoidance by multinational companies. There is a danger of… – Continue reading

Panama Papers Row Fails To Deter Trust Buyers

The Panama Papers row has failed to deter Permira and TPG from bidding for offshore trust firms, Sky News learns. Some of the world’s biggest buyout firms are queuing up to buy a string of offshore trust administrators despite the escalating global furore about the leaked Panama Papers. Sky News… – Continue reading

U.S. launches ‘criminal investigation’ involving Panama Papers

A federal prosecutor in New York has opened a criminal investigation involving the Panama Papers — a trove of materials from a Panamanian law firm that show a massive, secretive world of offshore industry. In a letter to the International Consortium of Investigative Journalists (ICIJ), U.S. Attorney Preet Bharara wrote… – Continue reading

Why We Should Be Really Worried About the Panama Papers

History shows us that tax evasion can have terrible effects, from economic inequality to societal collapse. In a world seemingly inured to financial scandals, the Panama Papers leak has reminded us of their capacity to shock. This huge document dump, which has revealed thousands of offshore accounts held in the… – Continue reading

France Hits McDonald’s With $341 Million Tax Demand : Possibly Unfairly

The French taxman, Le Fisc, has apparently decided to send McDonald’s MCD -0.24% France a tax bill for €300 million ($341 million). It’s not entirely obvious that this is a correct demand: nor, in fact, necessarily a legal one. If there were no European Union and no rules about the… – Continue reading

Private Eyes They’re Watching You – Offshore Planning after the Panama Papers

Overview If you have been reading my articles on JD Supra for a while, you will know that I love Afro-Cuban and Brazilian music. Nevertheless, the Hall and Oates song Private Eyes, is a more fitting song to describe the state of offshore planning in Tax Havens than “Oye Como… – Continue reading

HMRC launches consultation on new tax evasion offence

The Revenue has published its consultation on proposing to make companies criminally liable for failing to prevent their staff facilitating tax evasion The offence was first proposed in the 2015 Budget and was expected to come into effect in 2020. The Panama papers leak and subsequent scandal has put significant… – Continue reading

Once A Tax Haven, Gibraltar Now Says It’s Low-Tax

Gibraltar, a tiny British territory at Europe’s southern tip, is famous for its geography — a huge limestone rock — that appears on the Prudential logo. It’s a global center for offshore banking, with the trappings of wealth to prove it: Luxury high-rises tower over super yachts in Gibraltar’s marina. The… – Continue reading

U.S. Treasury readies new tax rules as G20 vows to fight evasion

The U.S. Treasury Department is finalising new tax rules aimed at combating the use of shell companies to evade taxes, U.S. Treasury Secretary Jack Lew said on Saturday amid increased pledges by global finance leaders to cooperate on tax issues. In a statement to the International Monetary Fund’s steering committee,… – Continue reading

Birong: Tax Day — the real April fools

As April 18 looms near, it’s hard not to have taxes weigh heavy on our minds. For a lot of Vermont small businesses, this day can be bittersweet. Paying taxes typically means that, as a business, you’ve made money; and for most small businesses that alone is an achievement. Small… – Continue reading

David Cameron’s finances touched a nerve – tax openness is the answer

Nearly half of people say the Prime Minister’s handling of his finances was ‘morally repugnant’, according to our opinion poll, and they support public tax returns for all As the fallout from the fallout from the Panama Papers leak begins to settle, the Prime Minister is left contemplating the damage… – Continue reading

India, US to Collaborate on Tackling Offshore Tax Evasion

India and the US have agreed to enhance collaboration on tackling offshore tax evasion and increase cooperation in sharing of cross-border tax information. “We are committed to continued collaboration and sharing of experience in tackling offshore tax evasion and avoidance, including joint tax audits and tax examination abroad,” Finance Minister… – Continue reading

Apple, Microsoft among top 50 U.S. corporations using offshore tax havens

Less than two weeks after publication of the Panama Papers, a year-long investigation by hundreds of news organizations around the world, including the Star, cast a bright light on the world of offshore tax havens, a new report from Oxfam reveals how much money the 50 largest U.S. corporations have… – Continue reading

Hong Kong, Latvia Sign DTA

On April 13 in Riga, Hong Kong’s Secretary for Financial Services and the Treasury K C Chan signed a comprehensive double taxation agreement between Hong Kong and Latvia. “This is the 35th CDTA that Hong Kong has signed with its trading partners and it signifies the Government’s ongoing efforts to… – Continue reading

Dodging tax is not just about offshore havens

The release of the so-called Panama Papers has shone a light on the secretive world of offshore tax havens and shown the exhaustive lengths that companies and wealthy individuals will go to in an effort to avoid paying tax. The trove of documents leaked from the Panama-based law firm Mossack… – Continue reading

UK To Fast-Track New Tax Evasion Offense

The UK Government will bring forward plans to introduce a new criminal offense for companies that fail to prevent their staff from facilitating tax evasion. Prime Minister David Cameron said that the offense will be introduced in legislation this year. Cameron explained: “This Government has done more than any other… – Continue reading