Category: North America

Canada, UK Tax Authorities To Deepen Cooperation

The tax authorities of the United Kingdom and Canada are to deepen cooperation to establish a stronger mutually beneficial relationship, senior officials from both Government have said. Canada’s Revenue Minister, Kerry-Lynne D. Findlay, met with David Gauke, the UK’s Financial Secretary to the Treasury, in London on September 8. Findlay… – Continue reading

Schumer to release offshore tax bill

Sen. Charles Schumer (D-N.Y.) released legislation Wednesday seeking to roll back the tax benefits for companies that reincorporate abroad. Schumer’s bill takes aim at a maneuver known as earnings stripping, a process by which U.S. subsidiaries can take tax deductions on interest stemming from loans from a foreign parent. The… – Continue reading

Jack M. Mintz: Ending corporate tax inversions is ill-advised. The answer is tax reform

Retroactive legislation curtails tax-avoidance schemes but undermines faith in a government that changes the rules of game after an investment is made The temperature is rising in the United States over corporate inversions. U.S. Treasurer Jacob Lew is looking to pass retroactive law to undo recent corporate restructurings and, with… – Continue reading

Federal Court hands down software tax decision

The Federal Court has handed down its decision in the case of Task Technology v Commissioner of Taxation in relation to the tax treatment of specific software payments. The case related to payments made by Task to CaseWare International Inc (CWI) for the right to market and distribute CWI software to end users… – Continue reading

Can inheritance tax work?

Now that we have new cabinet ministers to drive the economy forward, the next expectation is for martial law to be lifted so that foreign investors and tourists can feel more comfortable about returning to Thailand. Meanwhile, the junta is determined to quickly show the people some signs of genuine… – Continue reading

Government of Canada Strengthens Collaboration With the United Kingdom

Minister of National Revenue concludes two days of meetings in London LONDON, ENGLAND–(Marketwired – Sept. 9, 2014) – Canada Revenue Agency The Honourable Kerry-Lynne D. Findlay, P.C., Q.C., M.P., Minister of National Revenue, today wrapped up a successful two-day trip to London, England. During her visit, Minister Findlay met with David… – Continue reading

Airbnb pays tax on Australian profit offshore

Airbnb has joined other multinational tech companies by booking its Australian profits offshore through an Irish subsidiary. The move raises questions about how much local tax it pays and whether its rent-sharing model will run into trouble with regulators here. The private company, estimated to be worth $10 billion, has sought immunity from corporate… – Continue reading

UBS Appeals $1.4 Billion Bail in French Tax Evasion Probe

UBS AG (UBSN) asked a Paris appeals court to overturn a $1.4 billion bail looming over the Swiss bank as France steps up a two-year-old tax evasion probe. The hearing dragged on for nearly three hours as the parties argued the case. The court said it would decide on the… – Continue reading

Six Corporate Executives and Six Corporate Entities Indicted for Orchestrating a $500 Million Offshore Asset Protection, Securities Fraud, and Money Laundering Scheme Defendants Created Three Brokerage Firms in Belize to Assist U.S. Citizens in Fraudulent Manipulation Schemes of Publicly Traded Companies, Including Cannabis-Rx Inc. (CANA)]

A multi-count indictment was unsealed this morning in federal court in Brooklyn, New York, against six individual defendants: Robert Bandfield, a U.S. citizen; Andrew Godfrey, a citizen of Belize; Kelvin Leach, a citizen of the Bahamas; Rohn Knowles, a citizen of the Bahamas; Brian De Wit, a citizen of Canada;… – Continue reading

Medtronic Has Biggest Stash Of Offshore Cash Among Inverters

Medical device giant Medtronic Inc. leads all corporate inverters in the amount of offshore cash waiting to be tapped if their tax inversion deals are consummated. Medtronic is buying Covidien and moving to Dublin, and it has $13 billion of cash outside the United States, according to a report from the Financial Times,… – Continue reading

SEC charges Belize ‘neighbors’ of summer market sensation Cynk

On Tuesday, the SEC and the Justice Department charged several companies claiming to be located on the same floor of an office building in Belize City with fraud and conspiracy. We may not have heard the last from Cynk Technology. On Tuesday, the Securities and Exchange Commission and the Department… – Continue reading

Organisation for Economic Co-operation and Development (OECD) Publishes its Standards for the Automatic Exchange of Information

On July 21, the Organisation for Economic Co-operation and Development (OECD) published its Standard for Automatic Exchange of Financial Account Information in Tax Matters. The report contains the OECD’s model competent authority agreement (CAA), the common standard on reporting and due diligence for financial account information (CRS) and commentaries on both the CAA and CRS.The… – Continue reading

The Abrahamsens’ Case Did Not ‘Finnish’ Well: Taxation of Government Employees

A recent Tax Court decision1 addressed the tax consequences to a Finnish citizen of wages she received while working as an employee in the United States on behalf of her country’s Permanent Mission to the United Nations. The case involves Sole Abrahamsen, a Finnish citizen, who began working at Finland’s Permanent… – Continue reading

CFTC Concerned Over Big Banks Transferring Trading Operations Offshore

The Commodity Futures Trading Commission (CFTC) is wary of banks invoking guarantees on foreign swap deals, and is taking steps to scrutinize such activity. The Commodity Futures Trading Commission (CFTC) is wary of US banks shifting their trading activities offshore and has urged other regulators to scrutinize banks involved in… – Continue reading

Doubts mount about Valeant Pharmaceuticals’ tax structures

MONTREAL – The disclosure by Valeant Pharmaceuticals International Inc. that it is under audit by the U.S. Internal Revenue Service is raising further doubts among tax specialists about the future of the Quebec-based drug company’s tax strategies. Valeant estimates it has achieved US$2.5-billion in tax and other “corporate structure” savings… – Continue reading

Millions of Americans in Canada downplay links to Uncle Sam

With the Canadian government’s decision to comply in July with a Washington tax crackdown on “U.S. persons” around the world, many Ameri-Canadians are feeling rising anger, fear and even hatred toward their powerful country of origin. That said, the self-identities of Americans in Canada have been more ambiguous than they… – Continue reading

Apple’s burden: a mountain of money it can’t really use

US companies can end up sitting on vast piles of untappable cash, held overseas for tax purposes. Success for the iPhone 6 would make things worse If, as expected, the launch of the new iPhone and Apple’s iWatch health monitor leads to record sales, more money than ever will pour… – Continue reading

Biggest tax inverters ‘have $21bn offshore’

High quality global journalism requires investment. Please share this article with others using the link below, do not cut & paste the article. See our Ts&Cs and Copyright Policy for more detail. C Three US companies seeking to use controversial takeovers to cut their US tax bills hold at least… – Continue reading

California contractor gets prison in tax case

SANTA ANA, Calif. (AP) — A Southern California military contractor who failed to report millions earned from providing services in Iraq has been sentenced to four years in federal prison. Prosecutors say Nadim Saifan Jr. of Huntington Beach was sentenced Friday. He pleaded guilty in May to attempted tax evasion…. – Continue reading

Reality Check: Franken’s Ad On McFadden’s ‘Tax Inversion’

MINNEAPOLIS (WCCO) — A tough new ad from Democratic Sen. Al Franken accuses his Republican opponent’s business of avoiding taxes by headquartering overseas. But Republican Mike McFadden calls the ad “ridiculous” and “full of lies.” The ad marks a new Franken campaign strategy: directly attack McFadden for his business dealings…. – Continue reading

Inversions: a Symptom of the Tax Code’s Disease

Stopgap efforts to prevent corporate tax inversions won’t fix the underlying problems With Congress about to return for a final push before the midterm elections in November, one topic on everyone’s lips is so-called corporate inversions. The practice, where a large U.S. company buys a smaller foreign company in order… – Continue reading

No place to hide from the taxman – Seychelles signs automatic tax information sharing agreement

(Seychelles News Agency) – The Seychelles has become an early adopter of an agreement launched by the G5 group of countries – the United Kingdom, France, Germany, Italy and Spain – to automatically disclose details of individuals who have taxable income kept in offshore accounts. According to a press statement by Her Majesty’s… – Continue reading

Fund houses start due diligence of foreign investors

Fund houses have started asking foreign investors and distributors to furnish necessary details to comply with Foreign Account Tax Compliance Act (FATCA). Fund houses have started collecting necessary information from foreign investors about their tax residency status in order to comply with the requirement of Foreign Account Tax Compliance Act… – Continue reading

Most Dutch banks are ‘vague’ about tax avoidance: fair banking report

Seven Dutch financial institutions may be involved in evading taxes and are ‘extremely vague’ about what they do to ensure this does not happen, the Dutch Fair Bank Guide said on Wednesday. ABN Amro, Aegon, Delta Lloyd, ING, NIBC, Rabobank and Van Lanschot emerge as potential tax avoiders in research… – Continue reading

India Eyes Tax On £350 Billion Cash Hidden Offshore

The Indian government’s bid to unearth black money stashed away in hidden offshore accounts is starting to pay off. The government believes around £350 billion is hidden in undeclared bank accounts and investments outside the country and wants to bring the tax owed on the money back to India. Nine… – Continue reading

Using British Virgin Islands Companies for International Listings

The British Virgin Islands’ (BVI) corporate statute is ideally suited for international listings. BVI companies have been used widely for listings on international stock exchanges in New York, London, Singapore and Oslo. They have been especially popular for listings on the world’s most successful growth market, the LSE’s Alternative Investment… – Continue reading

The Real Tax Benefits of Inverting to Canada

On August 26, Burger King announced that it entered into an agreement to acquire Tim Hortons, Inc., the Canadian coffee-and-doughnut chain, in a transaction that will be structured as an “inversion” (i.e., Burger King will become a subsidiary of a Canadian parent corporation).  The deal is expected to close in 2014… – Continue reading

US finished FATCA regime use consulting in Baku

Baku, Fineko/abc.az. The U.S. Internal Revenue Service has conducted consultations in Baku on the application of FATCA (Foreign Account Tax Compliance Act). The Azerbaijani Ministry of Taxes informs that Service’s representatives were received by Deputy Taxes Minister Natig Amirov. “Consultations concerned the issues of information security in the process of… – Continue reading

More Swiss Banks Give Eric Holder One-Finger Salute

More Swiss banks are dropping out of the U.S. banking program that the IRS supposedly uses to prevent American citizens from stashing cash overseas to avoid taxes. Known for 100 years as the original tax haven, free from the prying eyes of governments around the world, Swiss banks have provided… – Continue reading

The Big Banks Organise Massive Tax Evasion on an International Scale

Another example of the “Too Big to Jail” doctrine: International tax evasion and fraud organised by UBS, Switzerland’s biggest bank. UBS, which had to be saved from failure in October 2008 by massive injections of Swiss public money, was involved in the LIBOR manipulation scandal, the currency markets manipulation scandal… – Continue reading

The cost of cutting ties with Uncle Sam soar: Tim Harper

Americans living in Canada are in a rush to renounce their citizenship in the face of Washington’s invasive tax grab. OTTAWA – Thomas Jefferson is famously believed to have defined the price of freedom as eternal vigilance. The price of freedom from Uncle Sam is a lot steeper. Faced with… – Continue reading

Several Swiss banks pull out of U.S. tax program: paper

(Reuters) – At least 10 Swiss banks have withdrawn from a U.S. program aimed at settling a tax dispute between them and the United States, Swiss newspaper NZZ am Sonntag said on Sunday, quoting unnamed sources. Around 100 Swiss banks came forward at the end of last year to work with U.S. authorities in… – Continue reading

U.S. Fee to Drop Citizenship Is Raised Fivefold

The fee for individuals to renounce U.S. citizenship is jumping to $2,350 as of Sept. 12—more than five times the current charge of $450. The U.S. State Department, in its explanation for the increase, said that documenting a renunciation is “extremely costly” and requires a minimum of two intensive interviews with… – Continue reading

Senate Hopeful Defends Role in Irish Firm’s Merger

Years before Burger King sized up a Canadian headquarters in a hunt for lower taxes, Republican U.S. Senate candidate Mike McFadden’s investment firm was involved in a merger that moved an American pharmaceutical company to Ireland and significantly dropped its tax rate. McFadden’s Minnesota-based firm made more than $11 million,… – Continue reading

How U.S. Corporations Skip Out on Their Tax Bill

Microsoft is avoiding paying billions in taxes—and it’s not the only one. a subsidiary of a foreign company, so the firm has not technically engaged in the so-called “inversion” scheme that President Obama and Democrats have lately been criticizing. However, according to a 2012 U.S. Senate investigation, the company has… – Continue reading

ObamaCare contract muddles Dem message on tax dodgers

The Obama administration is employing an ObamaCare contractor that was once based in the tax haven of Bermuda, even as it assails corporations for lacking the “economic patriotism” to pay taxes. Accenture was awarded a contract in January that’s now grown to well over $100 million to make improvements to… – Continue reading

Ad Watch: Is Wolf dodging taxes?

They say Wolf is dodging taxes by shifting money to income-tax-free Delaware. Bringing business inside Delaware’s borders is big. Sixty percent of all public companies are incorporated there – just miles from Pennsylvania. It’s also home to Weidner University’s Institute of Delaware Corporate and Business Law. Professor Lawarence Hamermesh is… – Continue reading

Facing up to Fatca

This article was first published in the 2nd quarter 2014 edition of Personal Finance magazine. Most people accept that they have to pay taxes in their country of residence. But citizens of the United States and green card holders who live outside that country – even if they have never… – Continue reading

Europe calls out corporate tax schemes our politicians won’t

You’ll have to forgive Amazon for getting a little flustered when the British Parliament publicly blasted the company for “gaming the system” to dodge paying taxes. Amazon is an American company. They’re used to far more deferential treatment. Responding to how the company paid only $7 million in taxes despite… – Continue reading