BEIRUT: Some bankers have said that European states are expected to follow the example of the United States and ask their citizens abroad to disclose their bank accounts to European financial authorities in a bid to combat tax evasion. “It’s not official yet but we expect some European countries to adopt similar… – Continue reading
I n July, the American pharmaceutical giant AbbVie, maker of the world’s top-selling drug – the arthritis treatment Humira – reached a blockbuster deal to acquire European rival Shire, best known for the attention-deficit medication Adderall. The merger was cheered by Wall Street, not for what the deal will do… – Continue reading
Ottawa (27 Aug. 2014)—Premiers and territorial leaders in Charlottetown for the Council of the Federation need to demand the federal government and the Canada Revenue Agency (CRA) stem the flow of Canadian money offshore because it is depleting revenues by at least $7.8 billion each year. Retrieving that money could… – Continue reading
An effort to control tax havens for those hiding their assets overseas has resulted in broad brush impacts on hard-working expatriate Americans living and working out of country. The previously delayed Foreign Account Tax Compliance Act (FATCA) is now in full swing effective July 1, 2014. In an attempt to close a… – Continue reading
Juan Martin del Potro denies he has committed tax evasion in his native Argentina. His spokesman Jorge Viale said Monday there was “no evasion” and all procedural steps were being followed to resolve the case. The newspaper Perfil reported on Sunday that Argentine tax authorities had opened a case again… – Continue reading
VP Bank said it had now concluded that it no longer needed to take part in the programme. “Thorough internal investigations and external expert opinions showed that the conditions for continued participation did not exist,” the Liechtenstein-based bank said in a statement accompanying its half-year results. “VP Bank therefore withdrew… – Continue reading
An innocuously named species of transaction has inspired a political furor this summer. After a number of U.S. companies announced plans to move overseas in so-called inversion deals, Sen. Carl Levin proposed banning them outright. President Barack Obama called the companies unpatriotic. Because of the controversy, Walgreen Co. backed away… – Continue reading
The Foreign Account Tax Compliance Act (FATCA) was enacted into law as part of the Hiring Incentives to Restore Employment (HIRE) Act of 2010. Its purpose was designed to prevent U.S. taxpayers from “hiding” under the cover of a foreign based entity or trust in evading U.S. income tax and… – Continue reading
Twitter is the latest major internet multinational to have opened up a Spanish subsidiary. But the popular micro-blogging site has followed in the footsteps of Google, Apple, Facebook and Linkedin, all of whom keep their Spanish corporate taxes down to the bare minimum by shifting their income to Ireland. Created… – Continue reading
The average temperature in Miami is 67 degrees in January. In Ontario, January temperatures range from an average low of 17 to a high of 33. But Burger King plans to pull up stakes in Miami and move its headquarters to Ontario. That reflects a frigid business climate in the… – Continue reading
According to Canada’s finance minister, the country’s corporate tax rate has dropped from 20% to 15% since the Conservative government took office in 2006. The U.S. tax rate is 35%, making the tax advantage for Burger King’s move to Canada a central part of the deal. Cutting corporate tax payments… – Continue reading
WASHINGTON — Two top Republican lawmakers profited from a corporate tax-avoidance maneuver that the Treasury Department is seeking to curb. While House Speaker John Boehner, Ohio, and Ways and Means Committee Chairman Dave Camp, Mich., have resisted calls for a crackdown on companies adopting overseas addresses to pay lower taxes,… – Continue reading
The Foreign Account Tax Compliance Act (FATCA) was enacted into law as part of the Hiring Incentives to Restore Employment (HIRE) Act of 2010. Its purpose was designed to prevent U.S. taxpayers from “hiding” under the cover of a foreign based entity or trust in evading U.S. income tax and… – Continue reading
With all the talk about inversions and America’s Burger King Going Canadian, it’s easy to ignore even more prevalent tax savings by numerous American companies. Take Microsoft, which admits in its 2014 SEC filing that it avoids $30 billion in U.S. taxes. The trick? Keep about triple that amount, $93… – Continue reading
Foreign Account Tax Compliance Act (FATCA) has been in force for a month and still more countries are joining the tax network. So far, 101 countries and financial jurisdictions have either signed or agreed to join FATCA. FATCA is aimed at identifying US taxpayers with offshore bank accounts and investments. Overseas… – Continue reading
This article, by Chris Horlacher, was originally published by The Dollar Vigilante. Many Canadians, referred to as snowbirds, spend three to six months each year in the United States. If they think to consult a tax adviser at all, they’re usually told that as long as they spend less than… – Continue reading
Microsoft’s stash of cash stored overseas, not subject to US taxes, is growing. In its latest regulatory filing, the software giant said it has now stockpiled $92.9 billion offshore and that this money could have cost the company $29.6 billion in taxes, but didn’t. That compares to $76.4 billion from… – Continue reading
Potential inversion deal highlights dropping corporate taxes in Canada, now the lowest among 10 countries, with the U.S. in 5th place. Fast-food giant Burger King faced anger from both Washington and average Americans Monday, a day after it announced that it was in talks to buy Tim Hortons and relocate… – Continue reading
NEW YORK — There’s more than one way for a U.S. company to avoid taxes by claiming a foreign address. Consider the business founded in 1916 as General Plate Co., a maker of sensors and controls for everything from Fords and Frigidaires to the spaceship that first carried Americans to… – Continue reading
Several recent high profile deals have directed media and public attention to the topic of “tax inversion,” whereby a company moves its headquarters overseas (usually in an M&A deal) in order to reduce its tax burden. According to the Wall Street Journal (citing Thomson Reuters) there have been 22 such… – Continue reading
Burger King is moving to Canada, by way of Omaha. Warren Buffett is finally getting into the burger business. Buffett’s Berkshire Hathaway brk.a -0.00% has agreed to help finance Burger King’s BKW -4.32% purchase of Canadian coffee-and-doughnut chain Tim Hortons THI 8.47% . The deal, first reported by The Wall… – Continue reading
CFOs of multinationals need to prepare by assessing how much their companies engage in profit shifting to cut their taxes. Do you have responsibility, whether direct or dotted line, for the tax function in your company? Does your company have, or plan to have, operations outside the United States? If… – Continue reading
Microsoft is the most recent member of the get-your-money-out-of-the-country club. The technology giant is facing scrutiny amid findings that it is housing nearly $92 billion offshore in an effort to avoid as much as $29 billion in US taxes. Annual filings with the Securities and Exchange Commission exposed that the… – Continue reading
THE National Tax Policy (NTP) has identified double taxation as one of the major hindrances to the growth of the Nigerian economy. Double taxation has become an issue paramount to investors and top executives of multinationals as income is generally taxable both in source and residence countries. In order to… – Continue reading
NEW DELHI: G-20, a group of developed and developing nations, is likely to press for adoption of “rapid timelines” by different countries for automatic sharing of information with a view to curb tax evasion. The issue of automatic sharing of tax information would figure prominently during the meeting of G-20… – Continue reading
On June 25, 2014, the IRS finally issued the instructions to the new version of Form W-8BEN-E, an 8-page withholding certificate to be completed by foreign entities. Previously, foreign individuals and most foreign entities would provide a one-page Form W-8BEN to withholding agents to certify the foreign entity’s entity classification… – Continue reading
The Foreign Account Tax Compliance Act (FATCA) is an important development in U.S. efforts to improve tax compliance involving foreign financial assets and offshore accounts.Depending on the amount of the aggregate value of their assets, US individuals are required to file Form 8938 – Statement of Specified Foreign Financial Assets… – Continue reading
Ireland can adopt ‘wait-and-see’ approach on tax breaks, says Department of Finance Ireland supports the EU review of all patent box regimes – under which certain member states offer tax breaks for intellectual property – and has decided to take a “wait-and-see approach” on the issue until guidance is provided… – Continue reading
Microsoft Corp. is currently sitting on almost $29.6 billion it would owe in U.S. taxes if it repatriated the $92.9 billion of earnings it is keeping offshore, according to disclosures in the company’s most recent annual filings with the Securities and Exchange Commission. The amount of money that Microsoft is… – Continue reading
LITTLE ROCK, AR –Former Little Rock attorney David Patrick Henry, Sr., 71, has been sentenced to five years in prison followed by two years of supervised released, according U.S. Attorney Christopher Thyer. Henry, Sr. is also ordered to pay over a million dollars. On March 21, a federal jury found… – Continue reading
MONTREAL • Eugene Melnyk, the billionaire owner of the Ottawa Senators and founder of drug maker Biovail Corp., is waging war against the company that now controls his one-time business. Mr. Melnyk alleges that Valeant Pharmaceuticals International Inc. is masquerading as a Canadian company to make use of this country’s… – Continue reading
The Delhi High Court upholds the non-taxability of gains from sale of shares of overseas entities by the Copal Group to the Moody’s Group. Interpretation of the indirect transfer tax provisions in a restrictive manner. 50% threshold for substantiality based on guidance by OECD/ UN material and Shome Committee Report… – Continue reading
Various reporters, editorialists and politicians are clamoring for Bruce Rauner, the Republican candidate for governor of Illinois, to release more of his tax returns — specifically, the detailed schedules that accompany the “top sheets” that he already has released. They probably will be disappointed, even if Mr. Rauner complies with… – Continue reading
Using the code name Hot Lips with Swiss banking representatives, an 83-year-old Delray Beach man conspired to hide more than $1 million from the Internal Revenue Service in foreign bank accounts. Bernard Kramer pleaded guilty Tuesday in New York federal court before U.S. District Judge Alvin K. Hellerstein, admitting he… – Continue reading
The Foreign Account Tax Compliance Act (FATCA) was enacted in 2010 by the US to target non-compliance by US taxpayers using foreign accounts. FATCA essentially requires foreign financial institutions to report information about financial accounts held by US taxpayers, or by foreign entities in which such taxpayers hold a substantial… – Continue reading
Manila (AFP) – Philippine world boxing champion Manny Pacquiao has won a Supreme Court reprieve in his battle to avoid paying tens of millions of dollars in extra taxes, authorities said Thursday. Pacquiao will not have to post a cash bond of 3.3 billion pesos ($75.2 million) and the government… – Continue reading
Aug 21 (Reuters) – Leumi, Israel’s second-largest bank, reported a smaller-than-expected decline in quarterly net profit, as the lender’s bottom line was hit by a provision to settle a U.S. tax probe. Leumi said on Thursday it earned 290 million shekels ($82 million) in the second quarter, compared with 474… – Continue reading
Medtronic Inc’s Chief Executive Omar Ishrak has insisted that the company’s USD42.9bn deal to acquire Dublin-based Covidien Plc, and, thereby, move its tax residence from the United States to Ireland in a “corporate inversion,” is based on business logic and not corporate tax reduction. Medtronic is among a number of… – Continue reading
The Cayman Islands, an important international business competitor for Bermuda, is expressing “consternation” that they have been included on a new list of high risk jurisdictions for financial crime. There are a total of 95 countries listed including Brazil, Afghanistan, Cuba, Russia, China, Iraq, the Republic of Congo and Jamaica…. – Continue reading
Serbia’s Information Commissioner has warned that banks must have the full consent of customers before information is passed to US tax authorities under the terms of FATCA, and that it would be illegal for customers to be declined services if they refuse to give consent. The comments were made by… – Continue reading
Never heard of FATCA? You will. FATCA—the Foreign Account Tax Compliance Act—is America’s global tax law. It was quietly enacted in 2010, and after a four-year ramp up, it’s finally in effect. What is most amazing is not its impact on Americans—although that is considerable—but its impact on the world…. – Continue reading
US has long tried to block tax inversions – with success – See more at: http://www.independent.ie/business/world/us-has-long-tried-to-block-tax-inversions-with-success-30520958.html#sthash.cT9EIpv4.dpuf US authorities have grappled for more than 30 years with corporate deals known as inversions by which American companies shift their tax domiciles abroad to avoid US taxes. Fifty-two substantial deals like this have occurred… – Continue reading
U.S.-China Agreement Requires Financial Institutions to Increase Transparency and Enhance Reporting Wolters Kluwer Financial Services recommends that financial institutions in China should take steps toward enhancing their data and reporting capabilities on financial accounts held by U.S. taxpayers in China as part of the Foreign Account Tax Compliance Act. This recommendation… – Continue reading
(Reuters) – The U.S. government has grappled for more than 30 years with corporate deals known as inversions in which U.S. companies shift their tax domiciles abroad to avoid U.S. taxes. Fifty-two substantial deals like this have occurred since 1983, about half of them since the 2008-2009 credit crisis, according… – Continue reading
Two women have challenged the constitutionality of a Canada-U.S. agreement to share the tax information of U.S. citizens resident in Canada, with the IRS. But an expert in U.S. tax law says that these individuals, most of whom consider themselves Canadians, could be worse off if the lawsuit succeeds. “If… – Continue reading
Law360, Washington (August 18, 2014, 5:20 PM ET) — Medical device manufacturer Zimmer Holdings Inc. is protesting a $79 million Internal Revenue Service assessment arising from transfer pricing adjustments that the agency made on transactions, including licensing agreements, between itself and a Dutch subsidiary, according to court records made public… – Continue reading
Minister of Finance Bob Richards confirmed this week that under the Bermuda-UK FATCA Intergovernmental Agreement [IGA] model 2, Bermuda and the UK have agreed the inclusion of a Limited Capacity Exempt Beneficial Owner Category in Annex II of the IGA. The effect of this amendment will mean that there will… – Continue reading
For years, chief executives have complained bitterly about the United States corporate tax code, arguing that it is too complicated and that rates are too high. The issue has reached a near boiling point this summer as many large American companies have sought to buy smaller foreign rivals so they… – Continue reading
To some, US companies switching their tax residency to gain a tax advantage are economic “traitors.” To others, they are victims of a United States tax code that effectively punishes them for investing at home and encourages them to look for opportunities overseas. In this Tax-News Topical Focus, we try… – Continue reading
SRINGFIELD — Republican Bruce Rauner not only has personal investments in the Cayman Islands, but he presided over his former private equity firm as it set up other investment vehicles in the Caribbean tax haven known for its secrecy. The Chicago Sun-Times verified through the Cayman Islands’ government-run online business… – Continue reading
