Category: North America

United States: Senators Introduce Bill To Require Reporting Of Beneficial Ownership Information

A bipartisan group of senators introduced a bill which would impose federal beneficial ownership reporting requirements for legal entities established under state law, intended to assist law enforcement in fighting money laundering and terrorist financing ("AML/CFT"). ... - Continue reading

Accidental Americans’ sue France over FATCA disclosure rules

A group representing French-American taxpayers  has filed a complaint against France with the European Commission over its compliance with the US Foreign Account Tax Compliance Act (FATCA), in a bid to avoid being blacklisted by French banks starting in January. France is a signatory to an agreement to give the… – Continue reading

Mexico 2020 tax reform: big changes proposed for foreign companies doing business in Mexico

On September 8, the executive branch of the Mexican government introduced Mexico 2020 tax reform, proposing far-reaching changes to the Mexican income tax, value-added tax, and Federal Tax Code. ... - Continue reading

Foreign investors inject $143.6 million in t-bills since July

KARACHI: Foreign portfolio investors invested $143.633 million in treasury bills from July onwards as the present government started betting on overseas funds into debt securities to finance budget deficit and refinance maturities. The State Bank of Pakistan’s (SBP) latest data showed that outflow from portfolio investors amounted to $5.808 million… – Continue reading

FATCA blamed for one in five US expats planning to give up passport

One in five US citizens living abroad are on the verge of giving up their passports according to a survey published by US tax consultants Greenback. The Greenback survey – which was conducted by more than 3,000 US expats – studies the expat community’s opinions on taxation, citizenship renunciation, and… – Continue reading

IRS offers tax break to some American expats

The Internal Revenue Service (IRS) has outlined new procedures for some “accidental Americans,”, giving them the chance to comply with their US tax and filing obligations and in turn qualify for relief from back taxes, penalties and interest. The changes would allow people with less than $2m in net worth… – Continue reading

Tax avoidance drives nearly 40% of global FDI: IMF

Nearly 40% of worldwide foreign direct investment (FDI), amounting to $15trn, “passes through empty corporate shells” with “no real business activities”, a study by the IMF and the University of Copenhagen reveals. According to the report, ten economies including Luxembourg, the Netherlands, Hong Kong, BVI, Switzerland, Singapore, Ireland, the Cayman… – Continue reading

US-born British citizen launches crowdfunding campaign to stop FATCA

A US-born British citizen has started a crowdfunding campaign to stop HMRC sharing her personal information with the US Internal Revenue Service (IRS) under the US Foreign Account Tax Compliance Act (FATCA). Law firm Mishcon de Reya has taken on the UK case for a client who alleges HMRC is… – Continue reading

Ukrainian government approves bill ratifying FATCA

The Cabinet of Ministers has approved a bill to ratify the Agreement between the governments of Ukraine and the United States to improve tax compliance and application of provisions of the U.S. Foreign Account Tax Compliance Act (FATCA) and related bills, the Ukrainian Finance Ministry’s press service reported. “On September… – Continue reading

Canada: Transfer Pricing: What’s New In Canada (Part II)

Transfer pricing disputes in Canada have, predominately, been resolved through either a request for competent authority assistance under the Mutual Agreement Procedure ("MAP") of a treaty, or, to a much lesser extent, through the notice of objection process with CRA Appeals.  Regardless of the recent increase in transfer pricing cases being brought before the Courts, the MAP will likely continue to be the dispute resolution process most often utilized by a Canadian corporation in transfer pricing cases because, in the absence of a 100% reversal of a transfer pricing adjustment by either CRA Appeals or a Canadian court, economic double taxation may still exist as a consequence of the CRA upward transfer pricing adjustment. The correlative relief provided by the treaty partner under a MAP settlement resolves that double taxation. ... - Continue reading

ICAB happy with Barbados’ removal from the EU’s blacklist

Barbados’ removal from the European Union’s (EU) blacklist has been welcomed by the Institute of Chartered Accountants of Barbados (ICAB). During her welcome remarks at the 15th Annual ICAB International Business Workshop, at the Barbados Hilton Resort, ICAB’s Executive Director, Kathy-Ann Hewitt, stated: “We are indeed happy that this change… – Continue reading

Canada, Switzerland ratify instrument to tackle tax avoidance

Canada and Switzerland on August 8 deposited with the OECD their instruments of ratification for the Multilateral Convention to implement tax treaty-related measures to prevent base erosion and profit shifting (BEPS MLI). The BEPS MLI, negotiated by over 100 countries and jurisdictions, updates the existing network of tax treaties and… – Continue reading

British citizens born in America face having bank accounts frozen

Tens of thousands of British citizens born in the US but only lived there for a few months or years face having their bank accounts frozen as part of a crackdown by the US tax authorities.    The Internal Revenue Service (IRS) is ordering British banks to hand over the… – Continue reading

United States: D.C. Circuit Expands U.S. Prosecutors’ Reach Over Foreign Bank Documents

In a recent decision, the U.S. Court of Appeals for the D.C. Circuit unanimously affirmed a district court order compelling three Chinese banks (not currently identified) to produce financial records in response to subpoenas issued by U.S. federal prosecutors, including records that were unrelated to the banks' U.S. operations or U.S. correspondent accounts. ... - Continue reading

European Union: The Increasing Link Drawn By Regulators Between State Aid & Taxation Systems

In 2018, the European Commission (EC) concluded two more investigations into whether the tax ruling practices of Member States breached European Union (EU) State aid rules: the first, a finding of unlawful State aid resulting from tax rulings by Luxembourg in favor of Engie; the second, a rare finding of no aid in respect of the treatment by Luxembourg of McDonald's under the Luxembourg-U.S. double taxation treaty. These decisions are discussed below. ... - Continue reading

Canadians for Tax Fairness concerned about inaction on Panama Papers

It is estimated that the use of tax havens is costing federal and provincial governments at least $7.8 billion in lost tax revenue. Low and middle income Canadians are the ones paying for that missing $7.8 billion in tax revenue. Ottawa (11 Aug. 2016) — The leak of the Panama… – Continue reading

CBI Dominica: Leading with Transparency

19 August 2019, Since 1993, Dominica has been at the forefront of the citizenship by investment (CBI) industry, setting high standards in due diligence, processing times, and most recently, transparency. Indeed, this month the nation liaised with prominent international professional services firm PricewaterhouseCoopers (PwC) to release a report clarifying the… – Continue reading

US appeals court sides with Amazon in $1.5 billion transfer pricing dispute

A US federal appeals court on Friday affirmed the Tax Court’s decision in Amazon, ruling that cost sharing buy-in payments made by Amazon’s Luxembourg subsidiary in exchange for Amazon’s transfer of intangible property should not include compensation for transferred residual business assets such as workforce in place, goodwill, and going concern value. ... - Continue reading

United States: Anti-Money Laundering And Sanctions: Trends And Developments Emerging Under The Trump Administration

Bank Secrecy Act/anti-money laundering (BSA/AML) and sanctions matters continue to be a core focus of regulators, law enforcement agencies, policymakers and Congress, and the story of the Obama and Trump Administrations on AML and sanctions is one of general continuity. ... - Continue reading

Tax laws of 12 low-tax countries including BVI, Bermuda, Cayman don’t harm other countries, 131-country group concludes

An OECD-led 131-country coalition, known as the “Inclusive Framework on BEPS,” has approved an assessment which concludes that 12 low or zero-tax countries do not have “harmful” tax regimes, the OECD today announced. ... - Continue reading

Taiwan to join anti-tax evasion program CRS

Taiwan expected to share financial information with Japan and Australia in 2020 TAIPEI (Taiwan News) – Taiwan is expected to exchange financial information with a number of countries in September of next year as part of the Common Reporting Standard (CRS) program designed to combat tax evasion. Developed by the… – Continue reading