Category: USA

Inland Revenue audits Microsoft NZ over transfer pricing practices

Microsoft New Zealand is bracing for possible action from the taxman. The company said in its annual accounts that Inland Revenue was auditing payments charged to it by Microsoft companies overseas over the two years to June 2015. Microsoft NZ listed the Inland Revenue audit as a “contingent liability” for… – Continue reading

Israel and U.S. Begin Sharing Data in Crackdown on Tax Evasion

The Israel Tax Authority says Americans have provided information on 35,000 accounts held by Israelis in the U.S. and on an unspecified number of American accounts in Israel. The Israel Tax Authority said Monday it had begun passing on data on Israeli bank accounts held by American citizens and Green… – Continue reading

Moving towards a simplified tax regime

As per the Economic Survey 2016, the ratio of Indian taxpayers to voters is 4%; ideally it should be roughly 23% at existing levels of economic and political development. The tax to GDP ratio at 16.6% is well below the emerging market economy norm of 21% and OECD average of 34%…. – Continue reading

Hammond threatens EU with aggressive tax changes after Brexit

Chancellor tells German newspaper if Britain were closed off from markets it may abandon European-style social model The chancellor, Philip Hammond, has suggested Britain could transform its economic model into that of a corporate tax haven if the EU fails to provide it with an agreement on market access after… – Continue reading

The G77 will push for ‘tax justice’ through a UN tax body, says Ecuador’s foreign affairs minister

The creation of a new United Nations tax body to clamp down on tax dodging, which experts say could cost developing countries more than $200 billion a year in missed revenues, will be a key priority of the Group of 77 and China under Ecuadorian leadership, according to the country’s… – Continue reading

Cayman Islands: Cayman Islands AEOI Update – Second Tranche of CRS Regulations Released

The Cayman Islands Government issued the second tranche of the Common Reporting Standard (“CRS”) regulations at the end of December 2016. Updated Guidance Notes will be issued in Q1 2017 by the Cayman Islands Tax Information Authority (“TIA”) to assist with the implementation of the regulations. Furthermore, TIA stated in… – Continue reading

Malta denounced as tax haven as it assumes EU presidency

Malta was today (11 January) accused of being a tax haven as it took over the rotating presidency of the EU. Some companies in the EU’s smallest country pay as little as 5% tax on their profits. The small Mediterranean island would have been included in the list of tax… – Continue reading

Snapchat opts for London over Dublin for international HQ

Move could be a worrying indicator of investment trends post-Brexit, post-Beps Snap, the company behind Snapchat, has opted to open its new new international headquarters in London, rather than Dublin, Amsterdam or Luxembourg, bucking a trend which for decades has seen US multinationals book their international sales in one of… – Continue reading

Argentina: Argentina And The United States Of America Signed An Exchange Of Information Agreement

On December 23, 2016, the US ambassadors and Alberto Abad signed an agreement for the exchange of tax information on request. 1. Introduction For the past few years, Argentina has been an active participant in the progress of exchange of international tax information. More than seventeen agreements have been signed… – Continue reading

A Classic Case Of Double Taxation?

The Central Board of Direct Taxes in India issued Circular Number 41 on December 21, 2016 providing clarifications on applicability of ‘indirect transfer’ provisions under the Indian Income Tax Act, 1961 to investors of Foreign Portfolio Investors (FPIs) – earlier known as Foreign Institutional Investors (FIIs) in India. The circular… – Continue reading

UK opposes planned US dividend tax for offshore investors

The US government is facing calls to delay the introduction of a new tax on foreign investors in US equity-linked derivative transactions, after the G5 group of countries signalled their opposition and the US Securities Industry and Financial Markets Association (SIFMA) indicated its members would not be ready for the… – Continue reading

Mauritius: Joint Statement By The FSC & The FSPA

The Mauritius IFC: Driving Growth in Africa As a jurisdiction of substance, the Mauritius International Financial Centre (Mauritius IFC) has been instrumental in driving quality investments in Africa, leading to sustained growth and prosperity across the continent. It is therefore with deep regret that we take note of the misperceptions… – Continue reading

Multinational CFOs increasingly view tax as reputational risk

Tax directors and CFOs at multinational companies are facing increasing numbers of tax audits, and are becoming concerned about the impact of public perception of their tax planning on their company’s reputation, according to research by Taxand. Its fifth annual global survey of CFOs, tax and finance directors across Europe,… – Continue reading

Rate Competition Is New International Tax Planning Reality

Lower corporate tax rates around the world are expected to play an important part in multinational companies’ tax planning in 2017, with a rate as low as 15 percent on the table in the U.S. and countries such as the U.K. planning to maintain or lower their current rates. A… – Continue reading

Bermuda is world’s worst corporate tax haven, says Oxfam

Four UK territories in list ‘undermine Britain’s efforts to be responsible member of the international community’ Bermuda is the world’s worst corporate tax haven, according to a list by Oxfam, which includes three other UK territories among those it names and shames. The charity’s list of the “world’s worst” 15… – Continue reading

Saint-Amans: greater co-operation the only way to maintain tax sovereignty

Tax sovereignty is incompatible with the globalised world, according to OECD tax policy director Pascal Saint-Amans Speaking at the Public Accounts Committee’s Global Tax Transparency Summit, Saint-Amans told told ministers, tax professionals and international representatives ‘a gap’ still exists ‘between the world globalising and tax sovereignty’. ‘As members of parliament,… – Continue reading

India, US strike 1st bilateral advance pricing agreement: Government

NEW DELHI: India and the US have reached a deal for the first bilateral advance pricing agreement, a move that will enable American firms to ascertain tax liabilities beforehand, Finance Minister Arun Jaitley said today. The two nations have resolved over 100 cases of tax disputes involving a tax of… – Continue reading

McDonald’s to scrap Luxembourg tax structure

Fast-food chain’s reorganisation means £800m from restaurants in Europe will flow through the UK instead McDonald’s is to scrap its controversial Luxembourg tax structure in a corporate shakeup that means $1bn (£800m) of income from fast-food restaurants across Europe will flow through the UK instead. The move comes 12 months… – Continue reading

Can current offshore wealth management centres survive?

After recent scandals, many financial and wealth management centres are losing their allure and ‘mid-shore’ options are taking their place, argues Philip Marcovici. Will all existing financial and wealth management centres survive? Are tax-free secrecy havens (the “offshore world”) a feature of the past? Is there room for entry of… – Continue reading

Planning for the Use of the United States as a Financial Haven: Part One

The United States has not agreed to participate in the Common Reporting Standard (CRS), relying instead on the Foreign Account Tax Compliance Act (FATCA) regime enacted in 2010 and initiated in 2014. United States participation in CRS is highly unlikely. Even with a change in control of Congress, CRS may… – Continue reading

US AND GRENADA FATCA AGREEMENT GOES INTO EFFECT

The Governments of the United States and Grenada have signed the Foreign Account Tax Compliance Act (FATCA) that will enforce a requirement for US citizens to file yearly reports on their non-US financial accounts. “This allows us to work together to ensure that financial institutions here in Grenada can help… – Continue reading

Trump warns that companies that offshore jobs will face 35 percent tariff

President-elect Donald Trump fired another warning shot Sunday at U.S. companies considering moving their operations out of the country, threatening “retributions or consequences” such as a hefty border tax if they do. The pronouncements came in a string of early morning tweets. Trump declared that he intends to incentivize businesses… – Continue reading

OFFSHORE TAX HAVENS COST SMALL BUSINESSES ON AVERAGE $5,128 A YEAR

Small businesses in the U.S. have to shoulder, on average, an extra $5,128 in taxes to make up for the revenue lost due to the abuse of offshore tax havens by multinational corporations, according to a new report by U.S. Public Interest Research Group Education Fund. As a new administration… – Continue reading

OECD Says Trump Tax and Spending Plans Will Boost Global Economy

A resurgent U.S. economy would help offset softness elsewhere in the world. Global growth will pick up faster than previously expected in the coming months as the Trump administration’s planned tax cuts and public spending fire up the U.S. economy, the OECD said on Monday, revising up its forecasts. In… – Continue reading

The IRS Must Adapt to Cryptocurrency, Not Accuse Bitcoin Users of Tax Avoidance

In light of the Coinbase case, expert Perry Woodin explains how the American tax system needs to deal with Bitcoin. It was recently reported that the IRS filed a petition in US federal court seeking full disclosure of Coinbase’s American customers records over just two alleged cases of tax avoidance… – Continue reading

Microsoft agrees to more transparency on taxes in Australia

The Australian government is one of the most aggressive in highlighting the issue of multinational corporations avoiding taxes through extensive use of tax havens. Microsoft’s Australian subsidiary will start disclosing the amount of tax it pays in Australia, opting in to a government-transparency program aimed at shedding light on the… – Continue reading

The competition of tax rates

A European nation appears “hungry” for business after lowering its corporate tax rate. But what does that say about the United States? Viktor Orbán, Hungary’s prime minister, has announced the government will introduce a flat corporate tax rate of nine percent, the lowest in the European Union. The average corporate… – Continue reading

French Panel Adopts ‘Google Tax’ on Diverted Profits

Big U.S. internet companies in France could get hit by a new BEPS-inspired penalty on “diverted profits” under a so-called Google tax measure that France’s National Assembly is set to consider next week. The amendment, proposed by Socialist Deputy Yann Galut and adopted by the Assembly’s finance committee, targets foreign… – Continue reading

(LEAD) Trump could spur global corporate tax cut competition: think tank

SEOUL, Nov. 17 (Yonhap) — U.S. President-elect Donald Trump’s pledge for a huge corporate tax cut could spur moves to reduce taxes on businesses and the rich across the world, a Seoul-based think tank said Thursday. During the campaign, the real estate mogul-turned-politician vowed to lower the business tax rate… – Continue reading

Germany Prepares Crackdown on Letterboxes

Nov. 15 — The German Cabinet is preparing to address a bill Dec. 21 to combat tax evasion by cracking down on letterbox companies and banking secrecy as a response to the Panama Papers and other scandals involving sophisticated forms of tax planning. The bill, prepared by the Federal Ministry… – Continue reading

Zero tolerance needed against tax secrecy, says former Panamanian advisor Joseph Stiglitz

There needs to be a “comprehensive global approach” against secret tax structures, says the Nobel Prize-winning economist, Joseph Stiglitz, who called for “zero tolerance”. Speaking to Parliament’s Panama Committee on Wednesday, the former advisor to the Panamanian government suggested that secrecy in tax affairs should be treated like a disease… – Continue reading

Dumping Obama’s faux foreign tax legislation should be high on Trump’s to-do list

President-elect Donald J. Trump has stated that among his top priorities will be revocation of President Barack Obama’s misguided executive orders. Among the first such items to get the ax should be a series of legally infirm international agreements to implement a monstrosity unfamiliar to most Americans, called the Foreign… – Continue reading

Americans Are Renouncing Citizenship Over FATCA Tax Law, Not Donald Trump

The number of individuals who renounced their US citizenship for Q-3 of Y 2016 was the 2nd-highest in history at 1,380, US Treasury Department reported. The Foreign Account Tax Compliance Act (FATCA), which enacted in Y 2010, and took years to implement, is “having an impact, perhaps bigger than these… – Continue reading

Vancouver Announces Empty-Home Tax to Take Pressure Off Rental Market

New tax takes effect on Jan. 1; highest penalties could reach C$10,000 a day Vancouver is implementing a new tax policy to rein in an overheated real estate market by forcing absentee landlords to make their vacant homes available for lease. Starting Jan. 1, the Empty Home Tax will be… – Continue reading

Significant Change In CRA Policy Harms Canadian Investors In US LLPs And LLLPs

Earlier this year the Canada Revenue Agency (“CRA”) announced its new administrative position that limited liability partnerships (“LLPs”) and limited liability limited partnerships (“LLLPs”) formed under the laws of Delaware and Florida are properly viewed as corporations for Canadian income tax purposes. It is widely expected that LLPs and LLLPs… – Continue reading

The coming abolition of cash

The Indian Government’s dramatic cancellation of large banknotes on the same day as the US election last week looks like the drastic solution to a very Indian problem with tax avoidance and the black economy, but it might turn out to be a harbinger of things to come everywhere. In… – Continue reading

How Donald Trump’s tax plan might save Apple billions of dollars

Over the past few years, Apple’s cash hoard has swelled to near unthinkable levels. Per the company’s most recent earnings report, Apple now has more than $237 billion in cash and other securities, anchored of course by the company’s insanely lucrative iPhone. Though the iPhone only has a thin slice… – Continue reading

Taxman sets police on Finns coming clean on undeclared overseas income

Finns alarmed by cracks in the previously iron-clad Swiss banking secrecy have come forward to volunteer information about undeclared overseas income to Finnish tax authorities. They were hoping for immunity from fines or criminal sanctions but dozens now face police investigations. The Finnish Tax Administration has requested police investigations into… – Continue reading

Trump’s Corporate Tax Reforms: What CFOs Need to Know

While Trump wants to close loopholes, many of them stem from public policy concerns — not “special interests.” After a dramatic upset victory in one of the most bitterly contested presidential races in recent history, Donald Trump now has some serious work to do. His corporate tax policies—which are vital… – Continue reading

Ukraine’s Cabinet of Ministers endorses draft agreement on FATCA with US

Ukraine’s Cabinet of Ministers has approved a draft agreement with the U.S. government to improve the implementation of tax rules and apply the provisions of the U.S. foreign account tax compliance act (FATCA). The decision is outlined in government resolution No. 821-r dated November 9, 2016 posted on the government’s… – Continue reading

IRS Nets $10 Billion FATCA Tax Haul

The US Internal Revenue Service (IRS) has netted more than $10 billion in secret offshore cash and investments. The controversial Foreign Account Tax Compliance Act (FATCA) has encouraged more than 100,000 taxpayers to reveal their overseas holdings. But the IRS suggests this is just the start as FATCA cranks up… – Continue reading

Nearly 100 Countries Poised to Adopt Multilateral Treaty

Ninety-eight countries are poised to formally adopt the OECD’s innovative multilateral tax treaty, which will place recommendations from the BEPS project into more than 3,000 bilateral accords, when the ad-hoc group meets later this month. The “Multilateral Convention to Implement Tax Treaty-Related Measures to Prevent Base Erosion and Profit Shifting”… – Continue reading

Moody’s Predicts Increase In US Firms’ Offshore Cash Piles

The level of cash holdings kept in foreign jurisdictions by US multinationals will continue to increase unless changes to domestic corporate tax rules are introduced, Moody’s Investors Services has said. According to a new report from the ratings agency, US non-financial companies rated by Moody’s will increase their cash holdings… – Continue reading

U.S. Multinational Companies Owe $700 Billion In Taxes On Offshore Profits, New Research Shows

American multinational corporations are apparently dodging nearly $700 billion in U.S. taxes they owe on profits stockpiled offshore, according to a new “corporate tax chartbook” from Americans for Tax Fairness (ATF) and the Economic Policy Institute (EPI). Last year, Fortune 500 companies had $2.4 trillion in untaxed offshore profits, on… – Continue reading