On 1 April 2015 the British Virgin Islands (BVI), Cayman Islands and 19 other jurisdictions were removed from Italy’s blacklist of jurisdictions. As a result it will now be easier for Italian individuals and companies to engage in business with those based in the Cayman Islands and the BVI. The… – Continue reading
A record 1,336 US taxpayers gave up their passports or their green cards in the first quarter of 2015, according to Treasury Department statistics published in the Federal Register. The Treasury is required by statute to publish a quarterly list including the name of each individual who has lost or… – Continue reading
The US Foreign Account Tax Compliance Act (FATCA) is celebrating five years on the statute books at the end of the month – and has changed the face of tax reporting worldwide. President Barak Obama backed FATCA as part of the HIRE Act 2010 with the aim of clamping down… – Continue reading
KPMG in Saudi Arabia is hosting a seminar on taxation of US individuals and the impact of Foreign Accounts Tax Compliance Act (FATCA) at the Marriott Hotel in Riyadh on May 26. Under US tax law, US citizens and US permanent residents (green card holders) are required to file US… – Continue reading
(Bloomberg) — Monsanto Co.’s potential acquisition of rival agricultural-chemical maker Syngenta AG could be structured as a tax inversion under current U.S. rules despite political resistance to such deals, according to an analysis by Bloomberg Intelligence. Switzerland’s Syngenta last week rejected St. Louis-based Monsanto’s $45 billion takeover offer. Monsanto, the… – Continue reading
On May 7th, 2015, the US Treasury Department published its first quarter 2015 list of individuals who have chosen to expatriate and it was yet again an eye opening number. The 1,335 published names is the highest quarterly figure ever reported in the Federal Register. The number of individuals voluntarily… – Continue reading
Changing Requirements and Changing Methods As the first year of the US Foreign Account Tax Compliance Act (Fatca) being in effect is almost complete, the rules for reporting still appear to be in flux, as are the ways firms are responding to Fatca compliance and setting out methods to address… – Continue reading
A mixed bag of topics for this week’s edition of Lifelines: ‘Gaijin card’ deadline looms First up are the new residence cards, which have replaced the old alien registration cards (aka gaijin cards) for foreign residents. If you are still using your old card, be aware that the deadline for… – Continue reading
It may be time for another letter from Tom Cotton. Cotton, the Republican senator from Arkansas, had been in office only a few weeks back in March when he got 46 senators to sign on to an open letter to the leadership of Iran. The letter pointed out that agreements… – Continue reading
HONG KONG (CNNMoney) -Hasta la vista, Uncle Sam! A record 1,337 Americans gave up their passports in the first three months of the year, according to new data released by the U.S. government. That’s nearly 40% of the 3,415 Americans that renounced citizenship last year, suggesting that U.S. renunciations will… – Continue reading
The U.S. Internal Revenue Service is planning to broaden the use of subpoenas of documents in cases where the name of a taxpayer under investigation is not known. The so-called John Doe summonses were a breakthrough for the IRS in tackling offshore tax evasion when they were first addressed to… – Continue reading
After five years of the US’s Foreign Account Tax Compliance Act (FATCA), financial institutions need to play the long game for future gain, according to GoldenSource’s Dev Bhudia. Bhudia, vice president of product management at GoldenSource, wrote in an article that the challenge now is not classifying clients or managing… – Continue reading
THE THAWING OF RELATIONS between the United States (US) and Cuba will open up the opportunity for Barbados to “serve as an intermediary for investment into Cuba”. But two prominent American lawyers, including one who advises Government, have warned that the “on paper” advantage Barbados has under its double taxation… – Continue reading
Corporations that have reclassified themselves as “foreign-owned” received approximately $1 billion in federal contracts over the last five years. These companies profit from American tax dollars despite avoiding U.S. taxes themselves. That could soon change. Two members of Congress have reintroduced legislation that would block these companies from winning lucrative… – Continue reading
There are fears the Government’s plans to prevent foreign controlled banks from slipping under the taxman’s radar, could end up hitting their New Zealand customers in the pocket. The Inland Revenue Department (IRD) is proposing to impose a higher tax burden on non-resident investors who get income from interest, dividends… – Continue reading
Two roadshow events in Canada to promote Bermuda as the jurisdiction of choice for captive insurance companies and e-commerce business have been hailed a success. The Bermuda Business Development Agency (BDA) hosted the sessions in Toronto and Calgary this week. It was standing-room only at the first event, in Toronto… – Continue reading
A record 1,335 Americans living overseas renounced their citizenship in the first three months of 2015, according to the Internal Revenue Service. That number is 18 percent higher than the previous record, according to Bloomberg. In all of 2014, 3,415 individuals gave up their U.S. citizenship, the second straight year… – Continue reading
After nearly a year of planning, the Multistate Tax Commission Executive Committee today approved the Arm’s-Length Adjustment Services Advisory Group (the Group) Final Program Design. The following six states have agreed to participate in the Program: Alabama, Iowa, Kentucky, New Jersey, North Carolina and Pennsylvania. Today’s discussion focused on some… – Continue reading
The Senate’s No. 2 Democrat is warning a major U.S. agriculture company to think twice about moving its legal address offshore. Minority Whip Dick Durbin (Ill.) told Monsanto that it’s in the company’s best interest to remain headquartered in the U.S., and noted that the company has had no problems… – Continue reading
Top-level executives turned out for information sessions in Toronto and Calgary this week to hear a BDA-hosted delegation spell out the benefits of establishing captive insurance companies and e-commerce entities in Bermuda. The BDA said, “A 20-strong delegation from the Island delivered a compelling Bermuda message to well-attended sessions in… – Continue reading
Indiana and Illinois are at war. Indiana began it with “Illinoyed by Higher Taxes?” signs. And Illinois Gov. Bruce Rauner has continued it with his assertion that he will “rip the economic guts out of Indiana.” Chicago-based Edsal Manufacturing announced plans to expand in Gary, creating about 100 minimum-wage jobs…. – Continue reading
OTTAWA —The Liberal plan for the middle class, two planks of which were unveiled this week, could risk another brain drain in Canada, stalling the national economy, says one public policy and economics expert. “It’s a real possibility,” said Charles Lammam, director of fiscal studies at the right-leaning think tank… – Continue reading
While Illinois Governor Bruce Rauner is busy pitching his idea to shake up the budget by shaking out money from the pockets of the state’s poorest, a children’s advocacy group says a focus on revenue is the key to shoring up the $6 billion deficit. Voices for Illinois Children released… – Continue reading
Nedbank Private Wealth is an international private bank headquartered in the Isle of Man, a self-governing British Crown dependency. The bank has been growing its presence in the Middle East since January 2011 through a representative office established in Dubai and licensed by the UAE Central Bank. “Our presence in… – Continue reading
Organizations representing millions of Americans who work abroad are storming Capitol Hill in a push for tweaks to tax and banking policy. American Chambers of Commerce (AmChams) operating in various countries all over the world collectively represent about 6.5 million U.S. citizens living outside the country. Some, such as the… – Continue reading
As part of its 2015 Federal Budget announcements, Canada committed to implementing the “Common Reporting Standard” (CRS) promulgated by the Organization for Economic Co-operation and Development (OECD). While the OECD’s efforts to facilitate information reporting via the CRS and Canada’s corresponding implementation of such a regime will certainly have lasting… – Continue reading
All the world’s major banks have connections between each other and work together in a secret network to help people evade taxes, whistleblower and former HSBC IT engineer Hervé Falciani said yesterday, warning that illegal offshore transactions can’t be carried out through one single bank but only with the help… – Continue reading
Officials from Mexico’s Tax Administration Service (SAT) met with Costa Rican tax administration officials from April 20 to 22, 2015, to share their experiences in the area of tax information exchange. The Costa Rican authorities learned from Mexico’s experience in implementing the US Foreign Account Tax Compliance Act (FATCA) and… – Continue reading
Now that Costa Rica has been formally invited to go through the process of becoming a candidate nation worthy of joining the Organization for Economic Cooperation and Development (OECD), financial advisors and legal professionals are starting to ponder how their clients will be impacted by this new chapter in our… – Continue reading
Back when the Affordable Care Act was still a new concept—that is, before we found out that it has exceeded even our most optimistic expectations—more than a few prominent Americans were threatening to expatriate from the US if Obamacare was successfully signed into law. Well, disappointing though it may be,… – Continue reading
The Foreign Account Tax Compliance Act is meeting with some success in prompting foreign banks to disclose the holdings of U.S. taxpayers to the Internal Revenue Service, according to a former IRS official. FATCA was included as part of the HIRE Act of 2010 and requires foreign financial institutions to… – Continue reading
The American Chamber of Commerce has warned that new Irish tax incentives may fail because they do not match the needs of multinationals, reports the Irish News. The chamber, which represents 700 US companies, has said the forthcoming Knowledge Development Box – which will replace the discredited Double Irish structure… – Continue reading
Bipartisan legislation has been introduced into the House of Representatives to amend the Foreign Investment in Real Property Tax Act (FIRPTA) of 1980 that requires foreign investors to pay taxes on capital gains when selling commercial properties or real estate securities in the United States. To encourage foreign investment in… – Continue reading
Choosing the right location for the centralization and management of your IP is a very important strategic business decision. The ideal location to establish an IP structure is one that can serve the organization’s business strategies/model, safeguard and protect its IP and more important to contribute to its tax optimization…. – Continue reading
U.S. Ambassador to Armenia Richard Mills on Tuesday confirmed reports that a U.S.-Armenia Trade and Investment Treaty will be signed during President Sargsyan’s working visit this week to Washington, DC, the final step in the negotiation of a bilateral economic accord long sought by the Armenian National Committee of America… – Continue reading
Passing between tax administrations Polish and US information on accounts and income tax residents predicts signed by the president Bronislaw Komorowski law on ratification of the agreement with the USA on the use of so-called FATCA Act. As reported by the presidential office, in terms of the Act of 20… – Continue reading
The CBDT has constituted a high- level committee to secure confidential tax data, obtained under mutual exchange with US authorities, as part of India’s compliance measures for signing the much awaited Foreign Account Tax Compliance Act (FATCA). The seven-member panel will be headed by the Member (Income Tax) of the… – Continue reading
The parties to licenses of technology should consider tax issues with such licenses. The following is a summary of some of the tax implications that may arise with regard to technology licenses. Withholding Taxes. Where a license crosses an international border, withholding taxes may apply to any royalties payable. Under… – Continue reading
A federal judge demanded to know more about HSBC Holdings Plc’s compliance with its trade sanctions and anti-money-laundering deal with the U.S. after a monitor said the bank was “too slow” to mend its ways. U.S. District Judge John Gleeson in Brooklyn, New York, ordered the government to file a… – Continue reading
The Tax Foundation released its inaugural “International Tax Competitiveness Index” (ITCI) on September 15th, 2014. The United States was ranked an abysmal 32nd out of the 34 OECD member countries for the year 2014. (See accompanying Table 1.) The European welfare states such as Norway, Sweden and Denmark, with their… – Continue reading
With a new candidate seemingly entering the race for president each week, national attention is understandably focused on American politics. But while Americans spare little mind for the goings-on of international organizations, their activities not only have significant impact around the world, but could also play a role in the… – Continue reading
Monsanto announced that it has resumed possible merger talks with Syngenta, a Swiss-based agricultural chemical giant. The pair explored a merger in early 2014 before deciding against it. When the 2014 talks were going on, one of the principle attractions for the deal was the possibility of Monsanto buying Syngenta… – Continue reading
On April 21, 2015, the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) issued a Geographic Targeting Order (“GTO”) lowering reporting thresholds and triggering additional recordkeeping requirements for certain financial transactions in a move that is likely to have effects far beyond the 700 Miami-based electronics exporters that are specifically… – Continue reading
Chapter 3 of the Internal Revenue Code requires payors (and recipients) of certain types of U.S. source income to withhold tax if the beneficial owner or recipient is a non-U.S. person for income tax purposes. Chapter 4 also imposes similar withholding under FATCA for payments to foreign financial institutions and… – Continue reading
Money makes the mare go, and it seems to have gone. From 2012 through 2014, overseas investment by Indians grew by an astonishing 700 per cent in the British Virgin Islands, a favourite tax haven for the biz pashas with the big bucks. Inexplicable, after Narendra Modi—whose war was to… – Continue reading
NEW DELHI:Investment made by individuals or other entities may not have broken the law or acted improperly to hide details, details of investments made in famous tax haven countries or countries with little to offer besides registration of mail box entities are indeed intriguing. For example, total investment to Switzerland… – Continue reading
Taipei, May 2 (CNA) Taiwan has reached an agreement with Canada on the avoidance of double taxation at an annual bilateral economic consultation, the Ministry of Economic Affairs (MOEA) said Saturday. The double taxation avoidance pact, which will be signed very soon, will be favorable to Taiwan businesses because it… – Continue reading
A year after the signing of the intergovernmental agreement regarding FATCA (Foreign Account Tax Compliance Act) between Luxembourg and the United States, the bill of law was finally introduced on 27 March 2015 to the Luxembourg Parliament. The bill of law relates to the exchange of tax information between the… – Continue reading
MUMBAI: Five Foreign Portfolio Investors (FPIs) on Thursday mainly from the US and the UK have dragged the Indian government and the Income Tax department to the court for levying Minimum Alternate Tax (MAT) on their capital gains for the year 2011-12. The five FPIs — National Westminster Bank Plc,… – Continue reading
Bradley Birkenfeld was released from federal prison in August 2012 after serving 2½ years for his role as a Swiss banker hiding millions of dollars for wealthy American clients. Five weeks later, he found himself in the kitchen of a small rental house in Raymond, New Hampshire. At that moment,… – Continue reading
