Category: North America

CbCR obligations for Italian entity members of US groups

Concerns have arisen over a temporary misalignment between the US country-by-country reporting regime and Italian legislation. Antonella Della Rovere and Federico Vincenti of Valente Associati GEB Partners explain. An agreement for the automatic exchange of country-by-country reports (CbCR) between Italy and the US (Agreement) came into effect on September 27...

Greek Revenue Services, US IRS Sign Agreement for Tax Data Exchange

The US IRS announced this week on its website that the US has entered into a bilateral competent authority agreement with Greece to exchange country-by-country reports on multinationals. The agreement between the IRS and the Greek Independent Authority for Public Revenue, signed September 27, puts into effect a 2015 deal...

Court orders developer to reveal condo-flipper info

A Federal Court judge has approved at least one court order that will require a British Columbia developer to turn over information to tax officials about people who bought and flipped condo units before or during construction. And several similar applications are under way, reflecting the federal government’s efforts to...

100 Organizations Urge Congress to Reject Giant Tax Loophole for Offshoring and Tax Avoidance

GOP Leadership’s Proposal for a “Territorial Tax System” Would Encourage Corporations to Send Jobs Offshore and Avoid Paying Taxes. WASHINGTON – Today, 100 organizations sent a letter urging members of Congress to reject a proposal that would allow U.S. multinational corporations to pay little to nothing on their offshore profits....

Greenland joins Global Forum on Transparency and Exchange of Information for Tax Purposes

On 29 August 2017, Greenland officially joined the Global Forum on Transparency and Exchange of Information for Tax Purposes. Greenland thereby declared its commitment to implement both the international standard of exchange of information on request and the standard on automatic exchange of financial account information. On 8 February 2017...

United States: California Expands Voluntary Disclosure Program for Out‑of‑State Trusts

At a Glance… On September 25, Governor Brown signed into law Senate Bill No. 813, which updated the California Voluntary Disclosure Program (VDP) to include out-of-state trusts with California beneficiaries and non-resident partners of out-of-state partnerships, and to allow the Franchise Tax Board (FTB) to waive the S Corporation or...

BEPS Actions 8-10 Most Important For Latin American, Caribbean States

The Inter-American Center of Tax Administration (CIAT) has released a new statement summarizing the feedback from Latin American and Caribbean countries from ongoing discussions on countering base erosion and profit shifting. CIAT said it and a number of regional and international organizations have brought together policymakers from countries in the...

US set to lose $12bn in tax take by 2027 if multinationals relocate overseas

Tax inversions by US multinationals attempting to shift profits into lower tax jurisdictions could cost the US up to $12bn (£7.4bn) in lost corporate tax revenues by 2027, according to figures released by the US Congressional Budget Office There were 11 major corporate inversions from 2014-2015, although two significant inversions...

US Hearing On Improving IRS Appeals Process

On September 13, the US Ways and Means Oversight Subcommittee launched a hearing on improving the resolution process for taxpayer disputes and appeals with the Internal Revenue Service. The hearing is said to be the fourth in a series of attempts to reform and improve the IRS appeals process. “In...

Kazakhstan Signs FATCA Agreement with US

Kazakhstan and the United States have signed a Model 1 FATCA Intergovernmental Agreement (IGA), which will enable the automatic exchange of financial information on each country’s resident taxpayers to support tax enforcement efforts. The agreement was signed in Astana on September 11, 2017. Kazakh Minister of Finance Bakhyt Sultanov emphasized...

Multinationals would face mandatory tax on offshore profits, Steven Mnuchin says

Multinational corporations with profits held overseas would face a mandatory one-time tax as part of the planned Republican tax legislation, Treasury Secretary Steven Mnuchin said Wednesday. “There will be a ‘deemed tax’ as a one-time charge,” Mnuchin said in an interview with Fox News at the Treasury. U.S. companies have...

Slow UK aid for hurricane-hit islands linked to tax haven ties

Anguilla’s ex-attorney general says UK government may fear exposing its role in Caribbean territories’ tax arrangements Aid offered by the British government to its hurricane-battered territories in the Caribbean has been dismissed as “derisory” by a former attorney general of one of the worst-hit islands. Rupert Jones, who completed a...

OECD releases guidance to ensure BEPS country-by-country reports are used appropriately.

Canada has implemented the country-by-country reporting requirement for large multinational enterprises (MNEs) contained in the 2015 Final Report on Action 13 of the OECD’s Base Erosion and Profit Shifting (BEPS) Action Plan.  Canada’s legislation is found in s. 233.8 of the Income Tax Act (Canada), and is supported by the...

Panama probe: First prosecutions are taken to court for off-shore tax evasion

While at the beginning of the year (The Indian Express, March 16, 2017) the number of requests sent by India stood at 283 cases, it has now crossed 300. And while the number of replies received from among these 13 jurisdictions stood at 165, that figure has now crossed 240....

Canadian Businesses Urge Gov’t To Scrap Tax Plans

Thirty-five Canadian business organizations have written to Finance Minister Bill Morneau to ask that he scrap proposals to crack down on the use of tax planning strategies by private corporations. The business groups have together formed the Coalition for Small Business Tax Fairness to oppose the Government’s proposals. Signatories of...

Court Rules In Favor Of Taxpayer In Canadian TP Audit Case

The Federal Court of Canada has ruled that the Canadian Revenue Agency may not conduct further in-person interviews with representatives from a multinational corporation concerning its transfer pricing affairs, having already discussed earlier tax years. Cameco Corporation declined to produce approximately 25 personnel for oral interviews in relation to an...

CBDT head says tax information from countries pouring in, firms can’t escape anymore

Central Board of Direct Taxes (CBDT) Chairman Sushil Chandra on Wednesday said that the tax exchange agreements with other countries was resulting in information pouring in at a fast pace, thus there was no escaping for the multi-national companies (MNCs) from fair taxation. “We have got wide (tax) information from...

Banker’s Toolbox addresses beneficial ownership rules

Banker’s Toolbox, Inc., the leader in Bank Secrecy Act anti-money laundering compliance solutions for financial institutions, announced today the launch of its Due Diligence Manager solution for Beneficial Ownership. This extension of the existing BAM+ platform delivers exciting and holistic features including a completely flexible question builder and automated periodic...

US agrees to give Australia additional intelligence to chase tax avoiders

America has formally agreed to share detailed information of companies with the Australian government’s Tax Avoidance Taskforce. This means authorities get access to additional intelligence to track down US-based multinationals. This month, US authorities signed a country-by-country report exchange deal with Australia. It seeks to give authorities a broader picture...