Category: North America

Year-End Tax Planning for U.S. Expatriates in Brazil: Sponsored

Amit Ramnani, director of Ipanema Wealth, an independent financial consultancy firm, discusses year-end tax planning techniques for U.S. expatriates. RIO DE JANEIRO, BRAZIL – Amit Ramnani, director of Ipanema Wealth, reminds U.S. expatriates that they still have time to apply some year-end tax-planning techniques. U.S. citizens who are resident in… – Continue reading

Sunshine Islands Feel Heat Over Tax Avoidance

The British government is about to get tough with so-called tax havens that are dragging their feet on revealing the secret ownership of thousands of offshore companies. One of the main thrusts of Britain’s drive to clean up the murky world of tax avoidance has been to put pressure on… – Continue reading

A battle over billions in business tax incentives

Deep in the $1.1 trillion dollar spending bill that Congress has to pass by Dec. 11 to avoid a government shutdown are 50 annual “tax extenders” that would provide tens of billions of dollars in tax relief for the private sector. Advocates say these measures, which have been around for… – Continue reading

Luxembourg: EC investigation of tax rulings, issued to US multinational

The European Commission today announced its decision to launch a “state aid” investigation into tax rulings granted by the tax authorities in Luxembourg to a company that is a member of a U.S.-based multinational taxpayer group. Background According to a February 2015 report, in 2008-2009, the group transferred its European… – Continue reading

Swiss bank to pay tax evasion penalty

Switzerland’s EFG Bank is to pay a penalty of $29m to the US Department of Justice to avoid prosecution for helping its American account holders evade taxes. The bank came forward as part of a voluntary programme launched in 2013, which allows Swiss banks to admit their potential role in… – Continue reading

Corporate tax revenues falling- OECD

Corporate tax revenues have been falling across OECD countries since the global economic crisis, putting greater pressure on individual taxpayers to ensure that governments meet financing requirements, according to new data from the OECD’s annual Revenue Statistics publication. Average revenues from corporate incomes and gains fell from 3.6% to 2.8%… – Continue reading

Free Webinar: BEPS could produce a “wild west” tax approach to captives

Tax authorities around the world could take a “cowboy” attitude towards captive tax rights when following guidance from the Base Erosion and Profit Shifting (BEPS) papers, according to Dr Pierre Olivier Gehriger, partner and certified tax expert at Pestalozzi Attorneys at Law. Speaking on a Captive Review webinar hosted by… – Continue reading

Alan Grayson said he closed Cayman Islands hedge funds, but records list as active

Democratic U.S. Senate candidate Alan Grayson said more than two months ago that he had closed down the Cayman Islands-based hedge funds that helped prompt ethics complaints against the populist congressman from Orlando. Grayson declined to provide documentation to the Tampa Bay Times when asked for it in early October,… – Continue reading

Is the Royal Dutch Shell and BG Group Deal Near Completion?

Bidness Etc takes a look at how Shell-BG merger is right on track, after receiving approval from Australia’s Foreign Investment Review Board Royal Dutch Shell plc (ADR) (NYSE:RDS.A) is just one step away from closing a merger deal with BG Group plc. On Thursday, December 3, the Anglo-Dutch company received… – Continue reading

Brazil: Tax | Legislative Decree No. 146/15

Legislative Decree approving the Agreement between Brazil and the United States of America for Tax Information Exchange and Instruction 1571/15 IRS On 26th June 2015, Legislative Decree No, 146/15 (“Decree“), which approved the agreement between Brazil and the United States to allow the exchange of information under the Foreign Account… – Continue reading

Non-disclosure of overseas assets to become ‘risky affair’ from 2017, warns Jayant Sinha

He said steps are being taken to put in place a robust information security mechanism in the Income Tax department Non-disclosure of overseas assets will become a “very risky affair” from 2017 as government will by then start getting information on them from foreign countries, Minister of State for Finance… – Continue reading

India-Mauritius tax treaty revision talks on, says Tax official

Right to levy capital gains tax by India is also part discussions, he said India is engaged in “positive talks” with Mauritius on revision of bilateral tax treaty as some issues still need to be sorted out, an official said today. “Negotiations have been going on. Talks with Mauritius have… – Continue reading

Mystery surrounding sources of corporate tax bounty which has hit €6.3bn

Corporate taxes continued to flood into the exchequer’s coffers last month, compounding a mystery about their source and raising doubts about whether a future government can rely on the company receipts after the election. The Revenue Commissioners and the Department of Finance have moved in recent weeks to dampen down… – Continue reading

“Tax Extenders” Bill Swells Massively Under Lobbyist Onslaught

A blockbuster tax cut deal, with a 10-year cost of $889 billion and counting, is deep into negotiations on Capitol Hill, proving that Congress doesn’t care about the deficit as long as the right groups get the giveaways. Virtually every year, Congress packages a series of over 50 tax breaks… – Continue reading

Guernsey: Guernsey Issues Regulations To Implement Common Reporting Standard

On 23 November 2015 Guernsey issued regulations to implement the Common Reporting Standard (“CRS”) under Guernsey’s domestic law. The regulations follow on from the commitment made on 29 October 2014 by Guernsey, along with the other Crown Dependencies and a number of other jurisdictions, to start exchanging information under the… – Continue reading

The IRS Is Losing Hundreds of Criminal Investigators

Tax cheats can breathe a little easier. The gun-toting Internal Revenue Service investigators who send felons to prison are retiring in droves and there’s no one to replace them. IRS Criminal Investigation agents are the elite special forces in the never-ending war on tax evasion. They are feared among criminals… – Continue reading

Banks, MFs ask US NRIs to submit FATCA certificates

MUMBAI: Indian banks and mutual funds have in the past fortnight started warning NRIs who hold an American passport or are working in the US that their accounts could be frozen unless they get a tax-compliant certificate from US authorities, thanks to a treaty signed by New Delhi and Washington…. – Continue reading

The Real Cost Of Global Tax Reform: An Unsustainable Increase In Accounting And Legal Fees

Leaders from the Group of 20 largest economies (G20) met in Turkey last month to put their final stamp of approval on a major overhaul of the international rules governing corporate taxes. The vote was the icing on a cake that the Organization for Economic Cooperation and Development (OECD) has… – Continue reading

Wilderness Safaris secretly stashing millions in tax havens?

A lengthy and yet complex investigation by The Botswana Gazette into financial affairs of the company in the shady tax haven of Bermuda blows the lid off the dealings amounting to P29 million with a mailbox sister company that has no office, employees or any legitimate business activities. Not only… – Continue reading

Canada: BEPS Final Reports: An Update On Treaty Shopping

The Organisation for Economic Co-operation and Development (OECD) sees treaty shopping as an important source of Base Erosion and Profit Shifting (BEPS). In this context, it identified the prevention of treaty abuse as one of fifteen issues or “actions” in respect of which recommendations were to be formulated as part… – Continue reading

Premier: critics show ‘a lack of respect’

Michael Dunkley has hit back at calls for Bermuda to make its beneficial ownership information public, claiming that critics are “attempting to solve a problem that does not exist”. After three days of meetings in London, the British Overseas Territories agreed to put information on the people who ultimately own… – Continue reading

Change in UK Treatment of Dual-Resident Companies May Affect U.S. Tax Planning

On November 30, 2015, the UK tax authorities at HM Revenue and Customs (HMRC) reached an agreement with Jersey about the interpretation of the company residence tie-breaker provision of the Jersey-UK income tax treaty. After reviewing other income tax treaties that contain similar provisions, HMRC will now take the view… – Continue reading

Chris Blackhurst: Britain’s island tax havens need action

Amid all the diplomatic comings and goings on Syria and how to tackle Islamic State, an important but little-noticed high-level gathering has been taking place in London. The Overseas Territories were holding the fourth meeting of their Joint Ministerial Council at Lancaster House. Leaders from Anguilla, Bermuda, British Virgin Islands,… – Continue reading

Offshore Industry Tipped for Growth, Driven by Demand from Emerging Markets, According to OIL Offshore 2020 Report

HONG KONG, Dec. 2, 2015 /PRNewswire — Demand for asset protection, wealth planning and funds by high net worth individuals in Asian countries will drive continued growth in the offshore industry, according to OIL’s sixth “Offshore 2020” annual market research study. OIL, the leader in international incorporations and corporate services… – Continue reading

McDonald’s Investigated for European Tax Evasion

The U.S. multinational will likely be investigated for evading taxes with Luxembourg’s help, following a report by trade unions earlier this year. McDonald’s is under investigation by European Union regulators for illegal tax deals with Luxembourg, according to sources close to the inquiry. The multinational—joining a list of EU tax… – Continue reading

FATCA List – December 1, 2015

The US Internal Revenue Service (IRS) reports no new registrations under Foreign Account Tax Compliance Act (FATCA) rules in November. The list stays at 177,147 institutions in 226 financial jurisdictions. The list details which overseas financial institutions have agreed to pass personal and financial information about accounts and investments controlled… – Continue reading

Global Forum to discuss tax info exchange,data safety tomm

The Global Forum established an AEOI group in consequence of the G20 Leaders’ Declaration in September, 2013 with a view to establish a mechanism to monitor and review the implementation of the new global standard on automatic exchange of information. As India and other countries enhance their cooperation to crack… – Continue reading

GOP Pushes For International Reform In Wake Of Big Pharma Tax Flight To The UK

Republicans in both chambers of Congress said international tax reform is necessary to retain companies in the United States following pharmaceutical giant Pfizer’s announcement it is moving its headquarters overseas after its merger with Ireland-based Allergan, citing the country’s high corporate tax rates. During hearings in the House Ways and… – Continue reading

UK government amends view on DTA residence articles

UK tax authority HM Revenue and Customs (HMRC) has announced a change of view on the interpretation of the company residence articles in 16 double taxation agreements (DTAs), reports Tax News. The change was prompted by an agreement with Jersey on the interpretation of the company residence tie-breaker article in… – Continue reading

The foreign investment tax advisers should pay attention to

Taxes levied on foreign stock dividends can be recouped, but it makes most sense for high-net-worth clients with multimillion-dollar positions Advisers could be missing out on a way to maximize returns on their clients’ foreign investments. Americans investing in non-U.S. stocks could be earning less of a return than they’d… – Continue reading

Panton seeks Cayman’s removal from non-cooperative tax list

As the Joint Ministerial Council meeting continues in London this week Financial Services Minister Hon Wayne Panton says he intends to meet with European States in a bid to have Cayman removed from their lists of third-country, Non-cooperative Tax Jurisdictions. The minister, speaking at the last sitting of the Legislative… – Continue reading

Federal Tax Advisory: Economic Substance Doctrine Cases

Things are heating up in the economic substance doctrine area, which could lead to a U.S. Supreme Court review of the IRS’s aggressive arguments for the doctrine. Certiorari Petitions Salem Financial Inc. and Bank of New York Mellon Corporation have both petitioned for Supreme Court review of the Federal Circuit… – Continue reading

Luxembourg finance minister attacks EU on business tax uncertainty

The European Commission’s use of state aid rules to challenge corporate tax agreements is causing uncertainly for businesses in Europe, Luxembourg finance minister Pierre Gramegna has said. Gramegna told the Financial Times this week that the situation “raises so many issues about predictability and certainty”. The Commission announced in October… – Continue reading

The foreign investment tax advisers should pay attention to

Taxes levied on foreign stock dividends can be recouped, but it makes most sense for high-net-worth clients with multimillion-dollar positions Advisers could be missing out on a way to maximize returns on their clients’ foreign investments. Americans investing in non-U.S. stocks could be earning less of a return than they’d… – Continue reading

British Virgin Islands: BVI Financial Account Reporting — Preparing For The CRS

The Common Reporting Standard (CRS) is the standard for automatic exchange of financial account information produced by the Organisation for Economic Cooperation and Development (OECD) which provides for systematic and periodic automatic exchange of information between signatory jurisdictions. At its heart is a requirement for financial institutions, including British Virgin… – Continue reading

The Changing Face of Luxembourg Finance

“Luxembourg is famous for two things: its steel industry and its rose cultivation industry”. This quote from an Italian guidebook of the 1930s was uttered by Luxembourg’s Finance Minister Pierre Gramegna at the annual conference of the Luxembourg Directors’ Association on 17 June 2015[1]. The economic outlook of the tiny… – Continue reading

Congress Should Embrace the International Consensus to Crack Down on Corporate Tax Avoidance

Some U.S. lawmakers on Tuesday used a pair of hearings in the Senate Finance Committee and the House Ways and Means Committee to showboat for corporate special interests and oppose a growing worldwide movement to crack down on international tax avoidance. Last month, leaders of the 20 largest economies in… – Continue reading