Category: North America

Italy: Transactions with tax havens governed by proportionality (and reason) | International Tax Review

ITR Correspondent Italy has updated its rules governing transactions with parties located in tax havens. Following a legislative process which began in 2013, the Italian Government on September 14 2015 enacted a decree addressing a wide array of international tax matters, including one of the most controversial Italian tax rules… – Continue reading

Africa: Designing Flexible Fiscal Regimes to Protect Revenues

Protecting the tax base of extractive industries, moving toward more responsive and flexible fiscal regimes, and improving international cooperation have become priorities in the Andean region, as commodity prices and revenues from extractive industries continue to decline, participants at a recent IMF conference heard. The three-day conference, Determining the Tax… – Continue reading

Sen. Hatch to convene hearing on OECD BEPS reports, EU State Aid investigations

Steptoe & Johnson LLP Today, Senate Finance Committee Chairman Orrin Hatch (R-UT) announced that the Senate Finance Committee will hold a hearing on December 1, to examine the Organization for Economic Cooperation and Development’s (OECD) Base Erosion and Profit Shifting (BEPS) reports and the European Union’s (EU) State Aid investigations… – Continue reading

European Union: The End Of Financial Privacy?

Over 90 jurisdictions have committed to the OECD’s Common Reporting Standard (CRS), creating comprehensive global automatic information exchange for financial assets and the entities through which such assets may be held. Over 70 jurisdictions have signed the OECD’s Multilateral Competent Authority Agreement, which implements the CRS. The CRS is scheduled… – Continue reading

US Justice Department Announces Privatbank IHAG Zürich AG Reaches Resolution Under Swiss Bank

The Department of Justice announced today that Privatbank IHAG Zürich AG (IHAG) reached a resolution under the department’s Swiss Bank Program. IHAG will pay a penalty of more than $7 million. “Through the information provided by IHAG and other Swiss banks in the Program, the department has unraveled the various… – Continue reading

Americans In Costa Rica Advised To Ensure US Tax Compliance

QCOSTARICA via Tax-news.com – The inclusion of a passport revocation provision to fund part of the proposed US highway bill would “disproportionately” affect American citizens living overseas, like in Costa Rica, according to a recent release from the deVere Group, a financial consultancy. The provision, which would be effective from… – Continue reading

State may gain up to €620m in Pfizer’s Allergan deal

Pfizer $160bn purchase of Allergan will see firm move HQ to Dublin Ireland’s exchequer is in line for an annual boost of up to €620 million following the announcement that Pfizer is buying rival Allergan in a $160 billion (€151 billion) deal. The takeover will see Pfizer move its corporate… – Continue reading

Wanted: central bank boss to fix 1,700-year-old European tax haven

MILAN (Reuters) – San Marino is looking for a new central bank governor to clean up its banks – traditional havens for tax dodgers – and fix their badly damaged balance sheets. Big problems for the micro-state began in 2009 when Italy, hit hard by the global financial crisis, added… – Continue reading

Previewing US Tax Reform

The latest Tax Reform Business Barometer survey, issued by The Tax Council and Ernst & Young, found that tax professionals expect Congress to approve tax reform legislation no earlier than 2017, with most congressional leaders having all but given up hope that tax reform is achievable in the remainder of… – Continue reading

I-T Dept inks 11 agreements to solve transfer-pricing issues

Of these, one advance pricing agreement has a ‘rollback provision’ The government has concluded 11 agreements to tax multi-national companies via the transfer-pricing mode. Of these, one advance pricing agreement (APA) has a ‘rollback provision’, which means those relating to previous years. The government has signed 22 APAs so far… – Continue reading

The offshore financial industry shows resilience as demand stays robust

The offshore industry is poised for growth, as the industry insiders see the demand for offshore financial and corporate services likely to increase in the coming years, according to an industry survey conducted by OIL, a corporate service provider specializing in international incorporations. The industry has been battling negative perceptions… – Continue reading

The offshore financial industry shows resilience as demand stays robust

The offshore industry is poised for growth, as the industry insiders see the demand for offshore financial and corporate services likely to increase in the coming years, according to an industry survey conducted by OIL, a corporate service provider specializing in international incorporations. The industry has been battling negative perceptions… – Continue reading

What’s Your Audit Risk? It Depends!

Taxpayers who are considering one of the Streamline Procedures (Non-resident or Resident) have been advised by the IRS that their returns are subject to the regular audit selection process even though they must identify their returns with a red stamp on the top of the front page of the returns… – Continue reading

Wolters Kluwer Financial Services Warns Industry to be Braced for Further FATCA and GATCA Complexity

Complexity of regulations means first adopters will gain competitive advantage, newly released white paper notes The banking industry should be braced for further complexity when it comes to the US Foreign Account Tax Compliance Act (FATCA) and the looming Global FATCA (GATCA). And those institutions that move more quickly to… – Continue reading

Why incorporate a startup in the British Virgin Islands?

As the founder of a startup company, one of the first questions you need to consider is “where should I incorporate my company?” Investors are drawn to the British Virgin Islands (BVI) for its flexible and modern corporate regime, tax neutrality, respected legal system, political stability and effective regulatory framework…. – Continue reading

New PE Language for BEPS Scales Back Earlier Drafts

Through tweaks to the Model Tax Convention, the OECD believes its work on profit shifting will stem elaborate structures, such as commissionaire arrangements, used by large multinationals to avoid the creation of a permanent establishment. The Organization for Economic Cooperation and Development, however, responded to concerns from taxpayers by narrowing… – Continue reading

U.K., U.S. Differ on Approaches to Implement BEPS

The U.K. and the U.S. governments will adopt different approaches to implementing the OECD’s final package of measures to tackle base erosion and profit shifting, panelists at a London forum said. The U.K. government considers an inclusive, multilateral instrument to upgrade bilateral tax treatments as the “best way” for countries… – Continue reading

FATCA – correlation of the global economy with the US economy

Already from December 1, 2015 come into force provisions requiring all financial institutions calling their clients to make statements about their residence tax (FATCA – Foreign Account Tax Compliance Act). It is the first significant action since records to OPF. FATCA imposes on foreign institutions, including the Polish reporting obligations… – Continue reading

Americans in Hong Kong, Asia could lose their passports for unpaid taxes

The eight million Americans living overseas, including In Hong Kong and the rest of Asia, should “ensure their financial affairs are in order and compliant” before the New Year, or face having their passports revoked, warns the boss of one of the world’s largest independent financial advisory organizations. Nigel Green,… – Continue reading

Audits: Vanguard income taxes ‘deficient’ for 2010-14

Mutual-fund giant Vanguard Group underpaid taxes on its income in Texas for 2010-14, according to records of the Texas Comptroller of Public Accounts. State-sponsored audits found payment “deficiency” for all four years in Vanguard’s payments of the state’s corporate franchise tax, which charged companies 1 percent percent of a company’s… – Continue reading

Ambassador Hull: Region should not be strong-armed into becoming tax collectors for the US government

LK Hewlett St. Kitts-Nevis Permanent Representative to the OAS, Dr. Everson Hull has expressed strong views on the impact of FATCA on the region’s banking system. Delivering a presentation to over 200 banking executives and other stakeholders in the financial services sector from across the Caribbean at the recent Caribbean… – Continue reading

IRS Updates FATCA Registration Website

The IRS has upgraded the Foreign Account Tax Compliance Act (FATCA) Online Registration System, enabling sponsoring entities to register their sponsored entities to obtain a global intermediary identification number. The upgraded system also will allow users to update their information, download registration tables and change their financial institution type. The… – Continue reading

Curaçao Attended The STEP Latin America Conference 2015

WILLEMSTAD – A 20-member delegation from Curaçao participated in the STEP Latin America Conference (STEPLatAm) 2015, which was held on the 22nd and 23rdof October at the Renaissance Hotel in Sao Paulo, Brazil. The STEPLatAm conference is a leading conference for wealth structuring and trust and estate practitioners. During the… – Continue reading

Make note of new disclosure requirements

Towards compliance with tax information sharing laws put in place in recent times, all financial intermediaries are mandated to seek information from account holders. They are also obliged to share information of your account with relevant authorities. SEBI too has issued guidelines on identification of beneficial ownership and mandated all… – Continue reading

Uncovering the Mysteries of Tax Optimization

Gabriele Galimberti and Paolo Woods make a complex and impenetrable subject palatable To do justice to the work undertaken by Paolo Woods and Gabriele Galimberti, requires thinking of them not as photographers, but as investigators. Their search for truth begins with a mystery, one embodied in Ian Fleming’s Dr. No…. – Continue reading

KPMG REPORT: INITIAL IMPRESSIONS OF NOTICE 2015-79 ON INVERSIONS

Notice 2015-79—released November 19, 2015, by the Treasury Department and IRS—announces their intention to issue regulations relating to inversion transactions and post-inversion restructuring transactions. Notice 2015-79 provides for rules that: Limit the ability of domestic companies to effect an inversion Limit the advantages of certain post-inversion restructuring transactions Clarify certain… – Continue reading

Ethiopia: Unmet Demands of the G20

The creation of the Group of Twenty (G20) was believed to serve as a remedy to the harsh realities of the world today. The initial formation of the Group of Seven G7 could do little to avert pertinent challenges both the developing and the developed nations face frequently. So a… – Continue reading

Welbeck Solutions: Whistleblower exposes secretive city firm at the heart of vast tax avoidance operation

Company used actresses including former Alan Partridge star to bombard financial sector workers with cold calls The grey Basinghall Street office building, in the heart of London’s City financial district, gives few clues about the frenzy of activity that was going on inside. But for years, this was the home… – Continue reading

IRS To Release Additional Rules On Corporate Inversions

This week, the IRS released Notice 2015-79, which describes intended regulations to cover inversions and related transactions. Colloquially, an inversion refers generally to a transaction in which a domestic corporation is acquired by a foreign corporation. I.R.C. §§ 367 and 7874 operate as the anti-inversion rules; § 367 deals with… – Continue reading

More Banks Spill Tax Evasion Secrets To Avoid Criminal Charges, Account Holders Beware

Lately, the IRS is warning offshore account holders to disclose before it’s too late. Under FATCA, banks everywhere want to know if you are compliant with the IRS. And the cost of compliance for many people is growing. The IRS updated its list of foreign banks where accounts trigger a… – Continue reading

Swiss banks to pay $81 mln, avoid U.S. charges on aiding tax evasion

Three Swiss banks will pay a total of more than $81 million to the U.S. Justice Department to avoid possible prosecution for helping Americans to evade taxes, the department said on Thursday. The three banks, the Swiss unit of BNP Paribas SA (BNPP.PA); KBL (Switzerland) Ltd (LU0092281103.BR); and Bank CIC,… – Continue reading

Clock Ticking for U.S. Holdouts as BNP Joins Swiss Tax Pact

The clock is ticking for American tax dodgers around the world after BNP Paribas SA’s Swiss unit and two other banks joined a U.S. program to avoid prosecution, revealing the exact methods of Swiss bankers’ legendary discretion. BNP agreed to pay $59.8 million in a program that has brought in… – Continue reading

US Tries to Prevent Corporations From Abusing Foreign Tax Havens – Treasury

The US Department of the Treasury said that the United States introduced new restrictions to prevent US-based multinationals from restructuring after mergers to establish foreign parent companies in order to avoid paying taxes. WASHINGTON (Sputnik) — The United States introduced new restrictions to prevent US-based multinationals from restructuring after mergers… – Continue reading

Swaziland to collect tax from US citizens, firms

Swaziland will implement the United States Foreign Accounts Tax Compliance Act FATCA 2010 by collecting tax from US individuals and companies operating in the country.APA learnt on Friday that the act, whose objective is the facilitation of the exchange of financial information between US and other countries where its citizens… – Continue reading

Govt to implement United States FATC Act of 2010

THE United States of America (USA) wants all companies of US origin, individuals and body corporates that are resident in Swaziland to report their financial information in their home country, the USA. This development is a result of Swaziland government announcing that it will implement the United States Foreign Account… – Continue reading

Malta and Caraçao agree tax treaty

The governments of Malta and the Caribbean island of Caraçao have signed a treaty, which both sides say will prevent tax evasion and the double taxation of companies operating in both jurisdictions. In line with internationally agreed standards, Malta’s finance minister Edward Scicluna and his counterpart from Caraçuo Jose Jardim… – Continue reading

The Offshore Wrapper: a week in tax justice #71

Now that’s what I call a Big Tax Case A long running court case that has become known as the ‘Big Tax Case’ appears to be reaching a conclusion. It involves Scottish football club Rangers, who went bust in 2012. After it failed, a new company was created. It bought… – Continue reading

Finance Malta wants faster innovation

Malta recently ranked first for efficiency in transposing directives into national legislation – but the chairman of Finance Malta, Kenneth Farrugia, believes that the pace of innovation needs to accelerate. “We claim to be nimble, but we need to push it much more. Innovation needs to be much faster paced…. – Continue reading

Oil And Gas Contractors Face Tax Hikes And Job Losses

British oil and gas contractors are amid a huge financial upheaval as a combination of job cuts and tax changes threaten their well-paid lifestyle. Thousands of contractors in the oil and gas industry worldwide have lost their jobs as companies look to protect their cash by sacking staff. The oil… – Continue reading

Recent OFAC Designations Reflect Coordinated Money Laundering Focus

On November 12, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced the designations of Altaf Khanani Money Laundering Organization (Khanani MLO) and Al Zarooni Exchange pursuant to Executive Order 13581, the transnational criminal organization designation authority. OFAC designated Khanani MLO as a transnational criminal organization[1]… – Continue reading