Interpreting corporate tax data shouldn’t be like playing “Where’s Waldo.” Analysts seeking to understand whether big corporations are engaged in tax-avoidance hijinks should be aided, not thwarted, by the information that companies make available in their annual financial reports. A long-brewing effort to require country-by-country (CbC) reporting of corporate income… – Continue reading
Over vodka martinis at Scott’s of Mayfair, James Bond might raise a quizzical eyebrow. The lease on 14-25 Mount Street — home of Ian Fleming’s favourite London haunt — has been put on the market by its wealthy owners at a rumoured £110 million. But the puzzle is, who are… – Continue reading
The game of cat and mouse between tax authorities and citizens has been played for a very long time. People have been dodging taxes for centuries. But the more nuanced and sophisticated game of avoiding tax is a more recent phenomenon. Indeed, when it comes to tax avoidance the game… – Continue reading
The Supreme Court of Canada has dismissed Conrad Black’s bid to have his multi-million-dollar battle with the Canada Revenue Agency over back taxes heard by the country’s highest court. The Supreme Court of Canada has dismissed Conrad Black’s bid to have his multi-million-dollar battle with the Canada Revenue Agency over… – Continue reading
A corporate tax holiday, one of the proposals currently being floated to help fund new highway projects, would actually cost the government around $118 billion, according to a new official projection. The proposal from Sens. Rand Paul (R-Ky.) and Barbara Boxer (D-Calif.) would allow companies to bring back profits currently… – Continue reading
The IRS on Tuesday proposed to amend its regulations so that taxpayers that are subject to withholding under Secs. 1441 through 1443 (chapter 3 of the Code, imposing withholding tax on nonresident aliens, foreign corporations, and foreign exempt organizations) or Secs. 1471 and 1472 (chapter 4 of the Code or… – Continue reading
Top Bay Area CPA Firm, Safe Harbor LLP, bolsters its focus on FBAR compliance issues in light of the upcoming June, 2015, deadline. FBAR (Foreign Bank Account Reporting) requirements are often necessary for residents with foreign financial accounts and assets. Safe Harbor LLP, a CPA firm in San Francisco specializing… – Continue reading
Ontario’s 2015 Budget, delivered on April 23, overhauled a number of the province’s tax credits and set out plans for a further crackdown on tax avoidance. The Budget made numerous changes to creative tax breaks, effective from April 23, 2015. The Ontario Production Services Tax Credit was reduced from 25… – Continue reading
The regulations require reporting FIs to notify TIA if they have reporting obligations under US FATCA and/or UK CDOT. With respect to US FATCA, Reporting FIs have until tomorrow (April 30th) to file their notification with an initial reporting deadline May 31st. With respect to UK CDOT, Reporting FIs have… – Continue reading
As compared to past federal Budgets, Budget 2015 contained fewer (and arguably less controversial) international tax measures. Nevertheless, Budget 2015 did announce the Government’s intention to address taxpayer concerns relating to (i) the withholding obligations borne by non-resident employers that have non-resident employees that work in Canada, and (ii) the… – Continue reading
THE global economic recovery, which has been assessed as uneven with manifest divergences across countries and regions, has however, been supported by Emerging Markets and Developing Countries (EMDCs) as the major drivers of global growth, although it is currently moderating in some countries. But the Intergovernmental Group of Twenty-Four on… – Continue reading
The British Virgin Islands Government has received a report that it commissioned on finding a new direction for the financial services industry, the recommendations from which will now be implemented, reports Tax News. The BVI engaged consulting firm McKinsey and Company to develop a pragmatic new strategy and implementation plan… – Continue reading
“Why are we doing this to folks? Why are we tormenting them in this way?” IRS Taxpayer Advocate Nina Olson asked in an address to Securities Industry and Financial Markets Association FATCA Policy Symposium in Washington last year. These “folks” are Americans living abroad: NGO workers, English teachers, physicians, taxi… – Continue reading
According to the most recent estimates, the quantity of goods carried by containers has risen from around 100 million metric tons in 1980 to about 1.5 billion metric tons in 2012. Out of these numbers, one container in every 11 that is engaged in global trade is either bound for… – Continue reading
Last September, the US Treasury Department announced new tax rules designed to crack down on the rising trend of “tax-inversion” deals in the pharmaceutical industry, as an increasing number of US firms had begun to pursue overseas acquisitions in attempts to relocate their legal addresses to non-US based headquarters to… – Continue reading
The April 21, 2015 Federal budget released by the Conservative Government includes updates on Canada’s involvement in the BEPS project and how Canada intends to fulfill its obligations to implement an automatic exchange of tax information with the G-20. Notably (with the exception of the common reporting standard discussed below),… – Continue reading
Asks Jaitley why the govt not keen to avail of German offer to share info on offshore accounts Former Union Law minister and senior lawyer Ram Jethmalani on Tuesday put the Union finance minister Arun Jaitley on the witness box and slapped him with a dozen questions on the Narendra… – Continue reading
They are even engaging in strong-arm tactics with US account holders Swiss banks, for decades the bastions of secrecy, are preaching the virtue of transparency to their US clients as they try to head off billions of dollars in potential fines for helping Americans evade taxes. Faced with the threat… – Continue reading
Five years on from FATCA’s inception, Dev Bhudia of GoldenSource argues that in order to realise new revenue streams from customer data, financial institutions can no longer afford to view regulations in isolation. They say birthdays are the perfect time to reflect and for many banks, the fifth anniversary of… – Continue reading
Section 55 of the Income Tax Act (Canada) (the “Tax Act”) contains an anti-avoidance rule that prevents a corporation from converting what would otherwise be a taxable capital gain into a tax-free intercorporate dividend. Section 55 deems a dividend not to be a dividend, but rather a capital gain, where… – Continue reading
A 15-strong delegation of Bermuda industry, government and regulator representatives will take part in a Canada roadshow next week, targeting top-level executives and touting the corporate benefits of setting up a captive insurance company in Bermuda, reports the Bermuda Business Development Agency. Led by Bermuda’s Economic Development Minister Dr. Grant… – Continue reading
A bill that could allow the state to collect taxes on corporate profits in offshore tax havens to fund Colorado schools survived a narrow party-lane vote in the state House of Representatives on Tuesday. The Democrats’ bill, which passed the House 33-31, faces a tough road as it moves from… – Continue reading
One million American citizens in Canada face double tax troubles. Max Reed explores these challenges in a spring series. The United States has two tools with which to collect information on accounts held by its citizens, FATCA and FBAR. Lots of attention has been paid to FATCA, less so to… – Continue reading
Vermont Sen. Bernie Sanders introduced a corporate tax bill earlier this month. Unsurprisingly, it cuts in a different direction than most tax proposals floating around Washington these days. The bill (S.922) is titled the Corporate Tax Dodging Prevention Act of 2015. A companion bill was introduced in the House by… – Continue reading
An OECD initiative on tax evasion is causing ripples around the world While a host of topics — from the necessity and the proposed scope of corporate tax reform, to corporate rate reduction and corporate inversions — are of major concern to those engaged in international tax, the overriding issue… – Continue reading
The Mauritius Revenue Authority (MRA) has informed Mauritius-based financial institutions (MFIs) that the filing deadline for submitting their US Foreign Account Tax Compliance Act (FATCA) data for the 2014 reporting year is July 31, 2015. FATCA requires all FIs outside of the United States to submit regular information on financial… – Continue reading
Yesterday afternoon, the Canadian government tabled the 2015 Canadian Federal Budget. Two measures are particularly relevant to certain employers. Withholding Relief for Non-Resident Employers and Employees To take effect next year (if the measure is enacted), Budget 2015 proposes an exemption from certain withholding requirements on payments from “qualifying non-resident… – Continue reading
NEW YORK — Introduced in the 1920s to ease the tax burden of farmers who wanted to swap property, it soon became a tool for real estate investors flipping, say, office buildings for shopping malls. Now, this little-known provision in the tax code, known as a like-kind exchange, has become… – Continue reading
Mahmud Abu Bekir testifies in the suit brought by his former wife. KUALA LUMPUR: The Sarawak Governor’s son, businessman Mahmud Abu Bekir Taib, today denied a string of accusations by his former wife’s lawyers, including the allegation that there were many women in his life. Testifiying in the Syariah High… – Continue reading
April 24 — Pressure is increasing on the Treasury Department to address concerns over language in the anti-inversions Notice 2014-52 that experts say could hurt the ability of foreign insurers to take part in commonplace business combination deals. “This has had an impact not only on foreign insurance companies, but… – Continue reading
When should the beneficiaries of an IRS-targeted tax shelter be allowed to sue their enablers? That’s the question the federal appellate court in Atlanta posed to the Florida Supreme Court April 17 in an ongoing bankruptcy-related case. The answer, which turns on statutes of limitations, probably will boil down to… – Continue reading
A recent indictment by the United States Attorney’s office in California illustrates the inter-relationship between currency transfer restrictions, (such as those involving Iran), foreign financial account reporting (the FBAR requirement) and the failure to report taxable income (filing of a false tax return). In United States of America vs. Ali… – Continue reading
Island Delegation to Tout Jurisdiction as Risk Capital and Potential e-Commerce Hub HAMILTON, Bermuda, April 27, 2015 (GLOBE NEWSWIRE) — A 15-strong delegation of Bermuda industry, government and regulator representatives will take part in a Canada roadshow next week, targeting top-level executives and touting the corporate benefits of setting up… – Continue reading
British Virgin Islands through its International Tax Authority (BVI ITA), went live last week with the Vizor for FATCA & AEOI solution, the “BVI Financial Account Reporting System”. Today, Vizor Ltd. announced that BVI went live with the Vizor for FATCA & AEOI solution. The British Virgin Islands Government (BVIG)… – Continue reading
Ireland might learn as the Isle of Man positions itself as the new bitcoin capital of the world While bitcoin is attractive because of its inherent decentralised nature, it has struggled to be perceived as a legitimate currency, given the lack of accountability and total absence of someone or something… – Continue reading
Pfizer Inc. (NYSE:PFE) went big exactly a year ago when it announced a takeover offer for UK-based AstraZeneca plc (ADR) (NYSE:AZN). The company’s decision to lap up AstraZeneca was seen as opportunistic; it being laced with controversy on many accounts, with some allegations behind the company’s proposition to acquire AstraZeneca… – Continue reading
With the Transcontinental Trusts Bermuda Forum taking place next week, it is timely to reflect on some of the attractive features and structuring alternatives that Bermuda’s trusts and related law provides and to consider some recent exciting developments. Bermuda provides a flexible, cost effective regime for the formation and administration… – Continue reading
International finance centres (IFCs) are frequently used to structure Russian inward and outward investment and it has been observed that in 2012, 11 of the 40 main recipients of Russian FDI were IFCs1. The BVI is at the forefront of offshore investment into Russia, and the share of outward FDI… – Continue reading
When Burger King’s owners first announced last summer’s mega-deal to gobble up Tim Hortons, the fast-food firm’s executives downplayed a key reason why they were acquiring the Canadian coffee chain and relocating corporate HQ to Canada: to cut its taxes. “Tax wasn’t really the driver of this,” Daniel Schwartz, the… – Continue reading
On 3 April 2015, Uzbekistan and the United States signed a Foreign Account Tax Compliance Act (FATCA) Agreement. FATCA seeks to obtain information on accounts held by U.S. taxpayers in other countries. It requires U.S. financial institutions to withhold a portion of certain payments made to Foreign Financial Institutions (FFIs)… – Continue reading
Americans have overcome oligarchy before — and there’s no reason we can’t do it again. Rising inequality seems to pose an insurmountable political problem. If the underlying causes are technological change and globalization, the forces appear to be unstoppable. Alternatively, if the causes are primarily political and involve the power… – Continue reading
Tim Thornton, Chief Data Officer, Mitsubishi UFJ Fund Services comments on the upcoming deadline for registration on the Cayman FATCA portal… The upcoming 30 April deadline for registration on the Cayman FATCA portal is another milestone in the implementation of FATCA. The relatively short window from the portal being available,… – Continue reading
Republicans and other people who are opposed to immigration reforms claim that they are a burden on the national economy and its resources. But latest reports suggest that undocumented immigrants paid as much as $12 billion dollars as taxes at state and national level. This is a huge amount and… – Continue reading
The U.S. Securities and Exchange Commission and the IRS are opposing bankrupt billionaire Samuel Wyly’s motion to sell his Woody Creek ranch because they believe he would hide sales proceeds in offshore accounts, according to court filings made earlier this month. Wyly, who filed for Chapter 11 bankruptcy Oct. 19… – Continue reading
About 11.4 million undocumented immigrants in the U.S. paid nearly $12 billion in state and local taxes in 2012, and granting them lawful permanent residence would further increase total tax collected, a study revealed. The recent study made by the Washington-based Institute on Taxation and Economic Policy said the average… – Continue reading
NUMBER OF THE WEEK: 6.5 percent The tax rate at which companies could voluntarily repatriate their foreign earnings under the Invest in Transportation Act of 2015 ( S. 981). Senators Barbara Boxer (D-CA) and Rand Paul (R-KY) introduced the bipartisan proposal, offering ways to save the Highway Trust Fund. Funding… – Continue reading
FPIs are battling it out with the income-tax department, which has issued notices demanding that they pay MAT to the tune of Rs40,000 crore New Delhi/Mumbai: Despite the government affirming that foreign portfolio investors (FPIs) can use tax treaties to fight tax demands on past capital gains, a majority of… – Continue reading
However, OECD being persuasive may not help funds based out of nations whose treaties do not give specific exemption The Indian government’s clarification that it would honour tax treaties while making a demand of Minimum Alternate Tax (MAT) at the effective rate of 20 per cent came as a relief… – Continue reading
On 20 March 2015, the British Virgin Islands Government issued revised guidance notes regarding the Intergovernmental Agreements between the British Virgin Islands (“BVI”) and the United States of America (the “US”) and the United Kingdom (the “UK”) to improve international tax compliance (the “Guidance Notes”). The Guidance Notes confirm that… – Continue reading
On March 30, 2015, the U.S. Department of Justice announced that it had entered into a nonprosecution agreement with BSI SA, the first Swiss bank to reach resolution with the U.S. government as to its potential criminal exposure for assisting its U.S. clients in engaging in tax evasion.[1] As part… – Continue reading
