Category: North America

Canada: Treaty Shopping: MIL, MLI And ALTA Things In Between

On February 12, the Federal Court of Appeal (FCA) released its decision in The Queen v. Alta Energy Luxembourg S.a.r.l.1 (Alta Energy), a case that represents an attempt by the Canadian tax authority to relitigate the issue of whether Canada’s domestic general anti-avoidance rule (GAAR) can apply to curtail so-called “treaty shopping”.2   ... - Continue reading

GRI issues international corporate tax reporting standard

The Global Reporting Initiative has issued a new international tax reporting standard that aims to ensure multinational companies are much clearer about how much they pay in taxes, and where. While the standard has no legal force, it could influence the ongoing debate in the U.S. and abroad on how… – Continue reading

Ukraine, U.S. ratify agreement on FATCA de-offshorization

The bill foresees that the Ukrainian banks will open information about the accounts of U.S. citizens in this country; Ukraine, on the other hand, will not be able to get the respective information about Ukrainian accounts in the States The Verkhovna Rada of Ukraine has passed the document about ratification… – Continue reading

US IRS tells banks not to close accounts just because of missing tax ID number: FATCA

The US Internal Revenue Service has eased the rules of FATCA compliance by telling banks overseas that they are not required to close the accounts of their accidental Americans clients who have not provided their tax identification number by January 2020. FATCA was passed in 2010 and forces banks wanting… – Continue reading

‘Who is buying Seattle?’: New report issues warnings on Seattle’s luxury housing boom

Seattle’s luxury housing boom will worsen inequality and affordability in the city, according to a new report, which calls for officials to require more transparency on who is actually buying luxury real estate in the area. The report — “Who is Buying Seattle? The Perils of the Luxury Real Estate… – Continue reading