Taipei, Jan. 15 (CNA) Taiwan and Canada have signed an agreement to prevent the taxation of the same income twice in the two countries, the Ministry of Foreign Affairs said Friday. The signing was completed earlier in the day and will likely take effect on Jan. 1, 2017 after the… – Continue reading
The offshore yuan posted the biggest weekly gain since October as China’s central bank limited the currency’s supply and forced a narrowing of its discount to the mainland rate. The monetary authority repeatedly bought the currency in Hong Kong this week, sending interbank borrowing costs to an all-time high. Yuan… – Continue reading
One of our favorite discussion topics is the VAT — more specifically, whether the United States will ever adopt a federal consumption tax. In that regard, much can be learned from looking at the experiences of other countries. What’s happening in India – the world’s largest democracy — is noteworthy… – Continue reading
BRASILIA, Jan 14 (Reuters) – Brazilian President Dilma Rousseff on Thursday signed a bill that gives amnesty to holders of undeclared offshore assets in exchange for a fine, part of efforts to cut a swelling budget gap and revive investment in the recession-hit economy. The law offers amnesty from prosecution… – Continue reading
While there is an urgent need to restructure the current income tax slabs, especially hiking the Rs 10 lakh limit for the highest rate of 30%, presumptive taxation for the unorganized businesses also needs to be looked at by FM Arun Jaitley. As Finance Minister Arun Jaitley gears up to… – Continue reading
CROWN POINT — Lake County officials are debating whether they have accidentally double taxed Cedar Lake and Schererville residents. Lake County Commissioner Gerry Scheub, D-Crown Point, argues this week a mistake by the County Council in funding the county’s E-911 public safety dispatching service has resulted in Cedar Lake residents… – Continue reading
Things just keep getting worse for Gene the Taxi King. A federal judge ruled Tuesday that New York taxi mogul Evgeny “Gene” Freidman illegally transferred more than $60 million in real estate assets into offshore trusts as a means of evading ex-lender Citibank. The ruling, which cited “numerous and glaring”… – Continue reading
The government of the British Virgin Islands (“BVI“) has amended the Mutual Legal Assistance (Tax Matters) Act, 2003 in order to enact domestic legislation implementing the OECD Common Reporting Standard (“CRS“) which was published on 31 December 2015 (the “BVI CRS Legislation“). It is not currently intended to issue guidance… – Continue reading
Following a number of questions and concerns raised with the Governor’s Office in recent days, I thought it would be helpful to clarify the situation with respect to seven pieces of legislation passed by the House of Assembly during December 2015. Four of these Acts, which give the Government of… – Continue reading
ARLINGTON, Va., Jan. 14, 2016 /PRNewswire-USNewswire/ — Bloomberg BNA today announced the publication of the Daily Tax Report’s 2016 Outlook on tax and accounting policy. Dozens of policy experts, along with current and former members of Congress, congressional staffers and federal agency officials provided insights on the year ahead regarding… – Continue reading
Billionaire John Paulson’s New York hedge fund firm has shut an operation in Bermuda that had been targeted by a Democratic lawmaker as a tax shelter. Paulson’s venture, a reinsurer named PacRe Ltd., has stopped writing new coverage, and its insurance policies have expired, according to two people familiar with… – Continue reading
Only one major amendment lodged by the government so far INFORMATION ON WHO OWNS SCOTLAND will be publicly available – but new Scottish Government proposals will still fall short of calls for action on land owned in tax havens. The Land Reform Bill, which has faced criticism from MSPs and… – Continue reading
Democratic presidential hopeful Hillary Clinton wants to end what she calls “the Bermuda reinsurance loophole” as part of her tax program outlined Tuesday. In a factsheet entitled “Investing in America by Restoring Basic Fairness to Our Tax Code” posted on her campaign website, Ms. Clinton says that “high-income money managers… – Continue reading
Dominican Republic, in January 2016. The Dominican Republic could soon be part of an initiative of the OECD would force financial institutions of the country to exchange information on the accounts of their customers in other countries that are part of this project. The Organization for Economic Cooperation and Development… – Continue reading
The Limited Liability Companies Bill, 2015 was published on 18th December 2015. It is likely to be enacted as the Limited Liability Companies Law in January 2016 and brought into force before the end of June 2016. Once that is completed, the Cayman Islands will then be able to offer… – Continue reading
FATCA letters are going out from banks around the world to millions of US expats in readiness for reporting their financial information to the Internal Revenue Service (IRS). If you are one of the 8 million US expats subject to the Foreign Account Tax Compliance Act (FATCA), what do you… – Continue reading
Americans living abroad feel that the Foreign Account Tax Compliance Act negatively impacts their professional lives and that compliance with the related tax reporting requirements is overly burdensome, a survey by Americans Abroad Global Foundation and the University of Nevada has found. But most survey respondents believe the U.S. government… – Continue reading
KUWAIT: Kuwaiti citizens who possess US passports need to straighten out their US tax status to avoid the penalty of having their US passports scrapped, said Abdulaziz Al-Anjeri, head of the American Tax Bureau in Kuwait. Technically Kuwaitis are barred from holding a second citizenship but many are suspected of… – Continue reading
In June of 2015, Connecticut passed legislation that implements combined reporting for tax years beginning on or after January 1, 2016. Part of the new regime, which is codified by Conn. Gen. Stat. P.A. 15-5, § 144 (2015), requires water’s-edge combined groups to include entities incorporated in tax havens in… – Continue reading
The IRS has announced important changes to its offshore account programs. They come as FATCA is taking hold worldwide. Many foreign banks are rooting out Americans with increasing vigilance. One key target of the changes? Americans living abroad and certain others who can now come within the IRS Streamlined Program…. – Continue reading
The BVI has passed legislation to implement the Organisation for Economic Co-Operating and Development (OECD) Common Reporting Standard for the exchange of tax information (CRS). The amendments to the Mutual Legal Assistance (Tax Matters) Act, 2003, which implement CRS in the BVI, will come into force on 1 January 2016…. – Continue reading
The BVI and Cayman are often referred to as “tax neutral” and you might have been told that, for this reason, it would be advantageous to establish your fund in either jurisdiction. What does this actually mean and what does it mean for your fund? Primarily, it means that BVI… – Continue reading
The Democratic presidential candidate’s plan, which would increase tax rate to 4% for only 0.02% of Americans, was criticized by Sanders’s campaign Hillary Clinton would add a 4% tax “surcharge” on Americans who earn more than $5m a year and close “egregious” tax loopholes if she became president, expanding on… – Continue reading
Irish drug giant’s long-standing plan to acquire US rival – and lower its tax bill – is finally sealed thanks to beefed-up cash offer The drugs maker Shire yesterday clinched a $32bn (£22bn) takeover of US rival Baxalta after sweetening the deal with a bumper cash component despite fears such… – Continue reading
Tax inversions and corporate tax rate cuts would be huge for these stocks Certain politicians are decrying a tax move known as an “inversions,” which allow a U.S. company to merge with a foreign one with a more favorable tax rate. Yet, it’s the politicians who created the necessity for… – Continue reading
Canada and the United Kingdom have signed an agreement that clearly outlines procedures for the application of the arbitration provisions of the Canada-United Kingdom income tax treaty. The agreement provides for a clearly outlined process for the arbitration of tax disputes between the two nations. The agreement establishes rules and… – Continue reading
Federal Supreme Court of Switzerland denies treaty benefits in case of dividend paid on shares acquired for hedging derivative contracts. Court stated that due to the fully hedged nature of ownership, there was economic nexus and interdependency between two independent transactions and therefore, the “intermediary” bank did not have beneficial… – Continue reading
Microsoft CEO Satya Nadella will be sitting in the House gallery as an honored guest at the State of the Union (SOTU) address tonight. By all rights, he be should sitting before a Congressional committee instead, answering for his company’s blatant tax avoidance. Microsoft is playing a game called “Global… – Continue reading
A web of offshore companies was used to shield controversial builder Tom McFeely’s ownership of an apartment building close to London’s Olympic stadium, an Insolvency Service official has claimed. The allegation was one of several levelled against the Priory Hall developer as part of proceedings issued by official assignee Christopher… – Continue reading
U.S.-based multinational corporations are allowed to play by a different set of rules than small and domestic businesses or individuals when it comes to the tax code. Rather than paying their fair share, many multinational corporations use accounting tricks to pretend for tax purposes that a substantial portion of their… – Continue reading
A lawyer for the Internal Revenue Service on Monday disclosed a series of emails and legal memos from 2004 apparently showing that Dallas entrepreneur Sam Wyly was interested in knowing the legal and financial ramifications if he renounced his U.S. citizenship. The IRS also introduced testimony from previous court proceedings… – Continue reading
According to a recent petition, the Israeli government has taken the wrong side in a world war that the US is waging over taxes of its overseas dual citizens. The financal future of 9 million Americans worldwide and hundreds of thousands living in Israel could be at stake. According to… – Continue reading
Royce Gracie isn’t scheduled to fight at Bellator 149 until February, but he’s in a serious fight with the IRS over his taxes, including whether he rightfully claimed a tax credit for the poor. Remember the scrawny guy in a gi who smoked the field at UFC 1 and had… – Continue reading
Most Americans who work overseas feel that FATCA negatively impacts their careers, and that compliance requirements are burdensome, says a new study released by the Americans Abroad Global Foundation and the University of Nevada. The study surveyed nearly 700 adults who live and work in more than 60 countries. Key… – Continue reading
Changes in I-T Act likely to curb tax evasion by multinational companies The government might change transfer pricing provisions in Budget 2016-17 to ensure companies with overseas presence and consolidated revenue of more than Rs 5,000 crore comply with extensive data reporting and documentation. Legislative changes in the Income Tax… – Continue reading
This is the first of our series of posts on Brazilian tax treaties. In each post we will provide an overview of a specific tax treaty between Brazil and a particular foreign country, as well as comments on any Brazilian administrative or judicial precedents applying the treaty, and highlights on… – Continue reading
NAIROBI, Jan. 11 (Xinhua) — Kenya and Canada are set to sign an agreement on the promotion of investments and trade between the two countries, officials said on Monday. Canadian High Commissioner to Kenya David Angell told Xinhua in Nairobi that the two governments are talking to each other and… – Continue reading
The year 2015 will be marked as the year of slow economic growth and haphazard fiscal and monetary policies due in part to the uncertainties brought about by the change in government. There were also leadership changes at the FIRS and a number of state tax authorities. This article outlines… – Continue reading
On December 21, 2015, the Internal Revenue Service (IRS) and the U.S. Treasury Department (Treasury) released proposed regulations (REG-109822-15) on country-by-country (CbC) reporting (the Proposed Regulations). In general, the Proposed Regulations are modeled after, and are consistent with, the Organization for Economic Co-operation and Development (OECD) recommendations for CbC reporting,… – Continue reading
few days before Christmas, in the full light of an Australian summer, the Australian tax commissioner published the tax details of 1,500 large corporate taxpayers which showed a staggering one-third of these companies paid no tax in 2014. This transparency measure was part of a wider package of ground-breaking legislation… – Continue reading
If taxed on the nearly $100 billion dollars they keep offshore, the largest U.S. financial institutions could cover the U.S.’s entire poverty-focused foreign assistance budget for 2014. Tax havens are a scourge. They allow individuals and institutions to cloak their financial activity in secrecy to escape and undermine other jurisdictions’… – Continue reading
January 2016 You will find below a summary of some of the most important tax developments that have happened since the release of our last newsletter, at OECD, EU or country level, in the area of tax transparency and the fight against tax avoidance. EU – Tax transparency and anti-BEPS… – Continue reading
New Delhi: Mutual Fund houses will have to mandatorily provide compliance details for the new global tax avoidance law FATCA with regard to each client on the stock exchange’s mutual fund trading platform. In a circular, BSE said for each and every transaction mutual fund houses have been asked “to… – Continue reading
Jan. 6 — Some dual-resident taxpayers don’t have to report specified foreign financial assets on Form 8938 for 2015, the IRS said. These taxpayers won’t have to do the reporting as long as they determine their income tax liability—for all or part of the taxable year—as if they were nonresident… – Continue reading
Mutual Fund houses will have to mandatorily provide compliance details for the new global tax avoidance law FATCA with regard to each client on the stock exchange’s mutual fund trading platform. In a circular, BSE said for each and every transaction mutual fund houses have been asked “to upload FATCA… – Continue reading
Viacom Inc. was accused by one of its former executives of plotting to hide revenue from “Teenage Mutant Ninja Turtles” in a Netherlands entity to avoid taxes. The ex-vice president for financial planning at Viacom claims she was fired after opposing what she believed was an illegal tax dodge. Nataki… – Continue reading
The Department of Justice announced today that Union Bancaire Privée, UBP SA (UBP), reached a resolution under the department’s Swiss Bank Program. UBP will pay a penalty of more than $187 million. “Today’s agreement marks the final resolution with UBP, which acknowledges its role in conspiring with U.S. taxpayers to… – Continue reading
Now that the final report on BEPS Action 7 has been released, “Preventing the Artificial Avoidance of Permanent Establishment Status” (Final Report), taxpayers are able to consider the final language to be incorporated into Article 5(5) of the OECD Model Tax Convention.1 This language also will be incorporated into the… – Continue reading
On December 18, 2015, the President signed the Omnibus Appropriations Act (the “Act”) into law.1 Notably, the Act contains a number of substantive changes to the tax laws applicable to “real estate investment trusts” (“REITs”). Although several changes will adversely affect certain REITs, on balance REITs and their investors fared… – Continue reading
Taipei, Jan. 6 (CNA) President Ma Ying-jeou (馬英九) lauded his administration’s efforts to improve the country’s development and expressed optimism Wednesday about the future for Taiwan’s next generation, citing a recent survey that found Taiwan the most optimistic about the future among other Asian nations. If peace and prosperity in… – Continue reading
