Category: USA

Understanding the taxation of international and expatriate assignments

(Second of two parts) In last week’s article, we discussed how or why taxpayers working on international assignments have to consider the impact of different tax jurisdictions on their individual tax obligations. We also explained how most companies implement a tax equalization (TEQ) arrangement for the employees so that they...

Campaigners demonstrate ‘In Praise of Whistleblowers’

Members of the Methodist Tax Justice Network (MTJN) and the Tax Justice Network (TJN) gathered outside the Embankment headquarters of PricewaterhouseCoopers on Wednesday 5 April 2017 to demonstrate in support of whistleblowers and against the actions of PwC, who have facilitated global tax avoidance, tried to prevent the release of...

EU states urged to continue fight against tax avoidance

VALLETTA: European Union states should continue reforming corporate rules to tackle tax avoidance, EU tax commissioner Pierre Moscovici told finance ministers on Saturday, as some smaller nations urged slower reform to avoid scaring away big corporations. In a paper to be discussed at a meeting of EU finance ministers in...

G20 Citizens Favor BEPS Crackdown Over Tax Competition

Citizens in G20 countries would prefer their government engage in international efforts to improve the functioning of international tax rules than compete for tax receipts, says a new survey. G20 public trust in tax, a report compiled by the ACCA (the Association of Chartered Certified Accountants), IFAC (the International Federation...

OECD recommends introduction of US-style deferred prosecution agreements in Scotland

ANALYSIS: US-style deferred prosecution agreements (DPAs) should be introduced in Scotland to deal with corporate offending, according to a recent report by the global Organisation for Economic Cooperation and Development (OECD). Foreign bribery should attract significant penalties, and Scotland’s civil settlement regime is potentially too lenient, according to the report,...

1099 Pro Offers Common Reporting Standard Software for CRS Reporting

1099 Pro now offers Common Reporting Standard software for CRS reporting as part of the OECD’s Automatic Exchange of Information for Tax Matters (AEoI) program. 1099 Pro, Inc., https://www.1099pro.com, known for over 25 years of Windows based product development for 1042-S, 1099, & FATCA reporting recently confirmed the upcoming release...

Art of the deal: Trump, Dems look for common ground to close tax loopholes

Venture capitalists, investors left unfazed Both President Trump and Capitol Hill Democrats head into negotiations over tax reform vowing to put the squeeze on hedge fund managers by closing the carried interest tax loophole — a point of agreement that held out promise for becoming a foundation for a once-in-a-generation...

House bills to fund infrastructure reward big multinationals

U.S. Rep. John Delaney has introduced two infrastructure funding bills — H.R. 1669 and H.R. 1670 — that good government groups say would further incentivize corporate tax dodging, reward the biggest multinational corporations for stashing their profits in offshore tax havens and replace one system riddled with tax loopholes with...

Law Society reaches understanding with IRD on FATCA

The New Zealand Law Society says that following discussions with Inland Revenue and the New Zealand Bankers’ Association it has now reached an understanding with Inland Revenue about application of FATCA to lawyers’ trusts accounts. FATCA is the United States’ Foreign Account Tax Compliance Act. Its objective is to reduce...

EU Lawmakers Visit IRS, Delaware as Tax Haven Concerns Mount

The European Parliament’s Panama Papers investigative committee is preparing for a “fact-finding” visit with counterparts in the U.S. Congress, as well as officials from the Treasury Department and Internal Revenue Service. The European Union lawmakers’ four-day U.S. trip, which begins March 21, will include a visit to Delaware for meetings...

CARICOM seeks FATCA delay, but law may prove irrelevant

The Caribbean Community is looking at spending nearly quarter of a million dollars on a Washington-based consultant to lobby the Trump administration about the Foreign Accounts Tax Compliance Act. Cayman appears unlikely, however, to be affected by any lobbying – or even FATCA repeal – in the wake of last...

FATCA repeal on agenda of US Republicans

Washington’s Foreign Accounts Tax Compliance Act, known as FATCA, will be assailed afresh as lawyers and lobbyists renew efforts to repeal the law as part of President Donald Trump’s tax reform. Washington-based Jim Jatras, a Republican and co-leader of the Campaign to Repeal FATCA, says “lots is happening,” and his...

Combatting Foreign Tax Evasion With New Filing Requirements for Foreign-Owned Disregarded Entities: Tax Update, Volume 2017, Issue 2

The new regulations expand the filing requirements for Form 5472 to include disregarded entities with foreign owners when there are certain reportable transactions. If a non-U.S. person (individual or corporation) owns 100 percent of the stock of a U.S. corporate subsidiary, the subsidiary needs to obtain an employer identification number...

Tax executives anticipate Trump reforms

Tax reform is widely expected under the Trump administration by the corporate tax executives polled by BDO USA in a new survey. BDO’s 2017 Tax Outlook Survey polled 100 tax executives at public companies across the U.S., and found that 100 percent of the surveyed tax executives believe tax reform...

Anti-money laundering rule looms for advisers

WASHINGTON — In the current deregulatory environment, investment advisers might expect a reprieve from new federal compliance rules. But one exception is the proposal for an anti-money-laundering regulation, which experts believe is likely to become the law of the land, bringing with it a significant new compliance responsibility. A year...

Indiana Combined Reporting and Transfer Pricing Studies

On October 1, 2016, the Indiana Office of Fiscal and Management Analysis of the Indiana Legislative Services Agency released a Combined-Reporting Study and a Transfer Pricing Study. These studies, which address corporate income tax issues, were required by legislation passed in 2016. The Combined-Reporting Study discusses the reduction of state...

3 Key Tax Rules Governing Typical Business Deductions

What is a business expense deduction? A business expense deduction is a deduction allowed for ordinary and necessary expenses paid or incurred in connection with an individual’s trade, business or profession. IRC Section 62(a)(1) operates to assure that all trade or business expenses, deductible as delineated under specific IRC Sections,...

U.S. Agents Raid Caterpillar Over Offshore Tax Practices

Federal agents raided three Caterpillar buildings near its Illinois headquarters on Thursday, company and law enforcement officials said, in an escalation of an inquiry into the heavy equipment manufacturer’s offshore tax practices. Caterpillar has been dogged by accusations that it slashed its domestic tax bill by shifting corporate profits from...

Foreign person NRA tax withholding

Nonresident Alien NRA tax withholding is applicable to U.S sourced income paid to foreign person and does not apply to payments made to U.S. persons. Foreign persons include nonresident alien individual, foreign partnerships, foreign corporations, foreign estates, and foreign trusts. The tax generally must be withheld from the payment made...

Companies Get Draft Instructions for U.S. Global Tax Reports

U.S. multinational companies with more than $850 million in annual consolidated gross income now have draft instructions for filing IRS reports on their global tax and profits. The Internal Revenue Service added instructions to the draft Form 8975 and accompanying draft Schedule A it released in December 2016, companies that...

HSBC discloses tax evasion probes in India, other countries

Global banking giant HSBC has disclosed being probed by tax authorities in India and several other countries, including against its Swiss and Dubai units, for allegedly abetting tax evasion of four Indians and their families. Besides, the bank has been approached by the regulatory and law enforcement agencies of various...

CRA’s new fingerprinting policy could create travel problems for accused tax evaders

Tax agency calls mandatory fingerprinting ‘a powerful deterrent’ The Canada Revenue Agency’s new policy to fingerprint every person it charges with tax evasion could create travel problems at the U.S. border for some Canadians who haven’t had their day in court The Canada Revenue Agency has begun to record the...

United States: The United States May Become An International Intellectual Property Tax Haven

We are all familiar with the use of offshore intellectual property holding companies to capitalize on international tax gradients. These companies are designed to take advantage of strategic local tax rules to reduce tax burdens on royalty streams generated from licensing. Because of these favorable tax treatments, countries like Luxembourg...

Ecuador Referendum Blazes Trail in Fight Against Tax Havens

If the referendum passes, all public servants and elected officials in Ecuador will be barred from holding wealth in offshore accounts. As Ecuador heads to the polls Sunday to elect a new president and National Assembly, deciding the fate of President Rafael Correa’s 10-year Citizens’ Revolution, the small South American...

ANCA and Senator Menendez Discuss Benefits of a U.S.-Armenia Double Tax Treaty

Bilateral Economic Accord Key to Growing Trade and Investment WASHINGTON—Armenian National Committee of America (ANCA) Chairman Raffi Hamparian recently held a working meeting on Capitol Hill with U.S. Senator Robert Menendez (D-N.J.) on a range of shared priorities, including the negotiation of a new U.S.-Armenia Double Tax Treaty. This bilateral...

EU preparing legal challenge against Donald Trump’s US border tax plan in what could be biggest trade dispute in a century

EU lawyers are preparing to mount a legal challenge against President Trump’s hugely controversial US border tax proposals in what could be the biggest case in World Trade Organisation history. Mr Trump’s proposed “border adjustment system” would see US imports subjected to tax, while export revenues exempted. The reforms have...

IRS warns of ‘Dirty Dozen’ tax scams

MARTINSBURG — The Internal Revenue Service has started releasing this year’s top 12 scams targeting consumers known as “The Dirty Dozen.” The annually compiled list features a variety of scams the agency says are common and that taxpayers could encounter anytime, but especially during peak filing season. Phishing schemes lead...