Many kinds of U.S. multinational companies, including S-corporations, REITS, and financial services companies apparently dodged a bullet last month when the U.S. Treasury Dept. issued its final, substantially revised rules aimed at curtailing “earnings stripping.” The revised regulation represents an attempt by Treasury to help “narrow the rule and avoid… – Continue reading
The Internal Revenue Service lacks a strong operation to audit a critical international tax compliance area, according to a watchdog report released Thursday. At issue is transfer pricing, a cost structure used by multinational companies to price goods and services they sell to subsidiaries in foreign locations. The IRS requires… – Continue reading
Global governments battling tax avoidance increasingly are pushing multinational corporations for a bigger picture of how and where they pay taxes, leading to increasingly narrow questions from company tax officers. “We have a number of entities that are disregarded for U.S. tax purposes. When I fill out the country-by-country form,… – Continue reading
The row between commercial banks in the Caribbean and the larger ones on the American mainland just would not go away. In the past week, finance officials from across the globe and from multilateral institutions such as the International Monetary Fund (IMF) flew to Antigua for a conference on the… – Continue reading
The OECD has started to review how effectively the U.S. and five other countries handle cases in which multinational companies assert double taxation under the mutual agreement procedure of bilateral tax treaties. As part of the review, the Organization for Economic Cooperation and Development is inviting multinationals to answer a… – Continue reading
The British arm of McDonald’s paid £123m for “franchise rights” last year, as part of a controversial structure that is under investigation for enabling unfair tax avoidance. The European Commission launched a probe last year into whether Luxembourg’s tax arrangements for McDonald’s amounted to illegal state aid, as part of… – Continue reading
A Justice Department official on Friday hailed a U.S. government program that’s helping tax authorities finally track criminal activity around the world. At issue is the Swiss Bank program, which has helped authorities follow funds moved from Swiss accounts to around the world. “A lot of the U.S. account holders… – Continue reading
Panama will take a big step towards ending its status as an offshore tax haven on Thursday by signing a multilateral convention to share foreign taxpayer details with other governments, the OECD‘s head of tax said. Panama’s role as a major offshore tax haven came into the public spotlight earlier… – Continue reading
The International Monetary Fund (IMF), the Organisation for Economic Co-operation and Development (OECD), the UN Department of Economic and Social Affairs (DESA), and the World Bank Group introduced a joint initiative, the Platform for Collaboration on Tax, to UN Member States. Marijn Verhoeven, World Bank Group, expressed excitement that the… – Continue reading
With the exception of British Antarctica, the U.K.’s overseas territories and offshore dependencies are all surrounded by sun-winking ocean water. But that’s not their only common feature—they are all under increasing political pressure to become more transparent with their financial information. In a parliamentary report on tackling overseas corruption, the… – Continue reading
A United Nations human rights expert has urged the next UN secretary-general to make the elimination of tax havens a priority to ensure that corporations, billionaires and ‘kleptocrats’ pay their fair share of taxes. Speaking on Friday, American law professor Alfred de Zayas also urged Antonio Guterres, who will succeed… – Continue reading
As international compliance efforts pass several new milestones, the Internal Revenue Service reminds U.S. taxpayers with undisclosed offshore accounts that they should use existing paths to come into full compliance with their federal tax obligations. Updated data shows 55,800 taxpayers have come into the Offshore Voluntary Disclosure Program (OVDP) to… – Continue reading
FATCA disclosure agreement takes effect, worrying some Israeli-Americans Dual American-Israeli citizens finally need to pay up. After years of the US Internal Revenue Service gradually baring down on American citizens living in Israel who evaded reporting income or paying taxes and numerous rounds of amnesty for those belatedly coming forward,… – Continue reading
China is requiring multinational groups to provide more information, including the location-specific advantages of their Chinese entities, when they apply for advance pricing agreements. The State Administration of Taxation’s Public Notice 64, dated Oct. 11 and released Oct. 18, requires companies to provide the additional information to Chinese tax authorities… – Continue reading
Guyana and the United States (US) on Monday inked an agreement, clearing the way for this country to share bank account information about American citizens and permanent residents with the US to help stamp out offshore tax evasion. “Today’s signing makes a significant step forward in our countries’ efforts to… – Continue reading
U.S. companies operating contract manufacturers in Mexico can avoid double taxation between the United States and Mexico under a deal struck between their respective tax authorities and unveiled Friday by the IRS. So-called maquiladoras can avoid double taxation through a unilateral advance pricing agreement signed with the Servicio de Administración… – Continue reading
The Saudi Council of Ministers has authorized minister of finance or his deputy to discuss two draft uniform agreements on value added tax (VAT) and selective tax for Gulf Cooperation Council (GCC) states. The agreements shall be discussed within the framework of the GCC financial and economic committee, and sign… – Continue reading
Accounts show each of the firm’s 682 workers took home average of £242,000 each in 2015 Facebook lavished £165million on its UK staff last year, while handing the taxpayer just £4million. Accounts show each of the firm’s 682 workers took home average of £242,000 each in 2015. The bumper payout… – Continue reading
Singapore is seeking more time to revise the two-decade old tax treaty with India, saying its investors need more time to shift to source-based taxation. India has, however, rejected any deferment in the revision of the treaty that will help prevent Singapore, which is the top source of FDI into… – Continue reading
In 2015, more than 73 percent of Fortune 500 companies maintained subsidiaries in offshore tax havens, according to “Offshore Shell Games,” released today by the U.S. PIRG Education Fund, Citizens for Tax Justice and the Institute on Taxation and Economic Policy. Collectively, multinationals reported booking $2.5 trillion offshore, with just… – Continue reading
The United States is recommending that Trinidad and Tobago pass the Foreign Account Tax Compliance ACT (FATCA) by February next year, providing a five-month breathing space for the country. US Ambassador John Estrada in a brief statement issued from Washington said he wanted to provide an update on FATCA after… – Continue reading
During his remarks at a September 26 meeting with Argentine Finance Minister Alfonso Prat-Gay in Buenos Aires, US Treasury Secretary Jack Lew disclosed that the two countries are to negotiate a comprehensive double taxation agreement, to include provisions for the exchange of tax information. “To accelerate the process of sharing… – Continue reading
CANADA, ISRAEL SIGN AGREEMENT ON DOUBLE TAXATION As Prime Minister Justin Trudeau joined other world leaders in addressing the United Nations General Assembly, behind the glare of the camera lights, Foreign Affairs Minister Stéphane Dion met with Israel’s Finance Minster Moshe Kahlon on the sidelines to sign an agreement to… – Continue reading
A multi-billion euro back tax bill handed to Apple by the European Commission should not be seen as a precedent for future tax cases as it was based on state aid rather than tax law, the OECD official spearheading global tax reform said on Monday. European Union antitrust regulators last… – Continue reading
The Director of the OECD’s tax policy and administration unit has said there is no pressure on Ireland to change its 12.5% tax rate. “There is no question about the 12.5% rate, even the French have understood that Ireland will not change the rate,” Pascal Saint-Amans said. He said the… – Continue reading
Five months after the Panama Papers exposed the offshore dealings of government leaders and influential people, a new leak of 1.3 million files has revealed the names of individuals associated with companies registered in the Bahamas, a notorious tax haven. The files – received by the German newspaper Süddeutsche Zeitung… – Continue reading
Ecuador’s foreign minister, leading economists and campaigners call for a new U.N. body to root out tax evaders and crack down on offshore havens. Ecuador ramped up its fight against tax dodging Wednesday as the South American country proposed a plan on the sidelines of the U.N. General Assembly in… – Continue reading
Seven private sector organisations Tuesday called on the Trinidad and Tobago government and opposition to put aside their differences and ensure the country meets the September 30 deadline for the Foreign Account Tax Compliance Act (FATCA). They also warned that failure to do so could result in ”serious negative consequences”… – Continue reading
European Union antitrust regulators opened a probe on Monday into tax deals granted by Luxembourg to French power utility Engie, stepping up the EU’s campaign against tax avoidance by multinationals. The European Commission said it had concerns the tax rulings granted by Luxembourg since 2008 appeared to treat the same… – Continue reading
Israeli owners of US accounts and US citizens in Israel have until September 30 to object to information about them being disclosed to the IRS. Within 10 days, all the financial information about Israelis with a green card or a financial association with the US and US citizens with bank… – Continue reading
The following is a bolded checklist of important situations that may “trigger” a tax review by a skilled United States tax professional. Many of these situations also require a simultaneous review by a foreign tax professional. It is generally best practice for these tax professionals to work together to minimize… – Continue reading
Tax havens have become increasingly formidable players in the global economy. With increased globalization and financialization of the global economy, tax havens have become important players in the world economy. According to a report by Tax Justice Network, $21 to $32 trillion is stashed offshore. According to the World Bank, the GDP… – Continue reading
According to a new report, secretive offshore tax avoidance practices are on the rise among multinational businesses. The report, released from the Financial Accountability and Corporate Transparency Coalition (FACT), finds that these practices put investors at risk because they are caught off guard when governments act to collect the lost… – Continue reading
Potential slice of the Apple pie stems from Commission’s invitation to EU tax authorities. BRATISLAVA — The €13 billion clawback of unpaid taxes from U.S. tech giant Apple has piqued the interests of EU finance ministers, who have today asked the European Commission for more details on the potential share… – Continue reading
PORT OF SPAIN, Trinidad, Sept 10, CMC – Government and opposition legislators are to meet here on Monday as the deadline for meeting the September 30 deadline for passing the Foreign Account Tax Compliance ACT (FATCA). Caribbean financial executives have in the past bemoaned what they deem as an uneven… – Continue reading
After state aid inquiries into Amazon and McDonald’s, EU looks again at Luxembourg The European Commission may open a fresh investigation into tax rulings offered by Luxembourg as early as this week, as EU competition commissioner Margrethe Vestager continues her clampdown against corporate tax avoidance. Luxembourg is already awaiting a… – Continue reading
Banks and financial institutions in India have got some breather as regards compliance under the US-enacted Foreign Account Tax Compliance Act (FATCA). The Finance Ministry on Wednesday said that banks and financial institutions need not enforce “closure” of accounts by August 31, 2016 in respect of those cases where “self-certification”… – Continue reading
A coalition of Silicon Valley tech companies has urged the Dutch Government against making changes to the most “attractive” features of its corporate tax regime, warning that it risks damaging its traditionally strong tax competitiveness by doing so. The Silicon Valley Tax Directors Group (SVTDG), which includes more than 80… – Continue reading
For the last three years, the international debate on tax policy was all about consensus. Led by the Organisation for Economic Co-operation and Development, countries across the globe agreed that aggressive tax planning by multinational corporations which pushed profits into low-tax countries – or indeed took profits outside the charge… – Continue reading
Under EU rules it is illegal for countries to give financial help to some companies and not others in a way that distorts fair competition, writes Liza Lovdahl Gormsen. State aid rules were originally designed to protect the internal EU market and avoid retaliation among member states. The US Treasury,… – Continue reading
Talks have begun between the US and Irish governments about updating certain elements of the Double Tax treaty between the two countries. The existing treaty was signed in 1997 and a Protocol to the treaty was signed in 1999. The Department of Finance and the Revenue Commissioners are calling for… – Continue reading
As Brussels is slated to deliver a verdict next month on Apple and other US companies for evading billions of pounds in taxes, the US Treasury Department has warned the European Commission (EU) about taking such action. In a white paper commissioned by US Treasury secretary Jack Lew, the Obama… – Continue reading
In the latest move to revamp the tax system in Indonesia, the government is considering setting up tax haven areas to entice home money that was stashed abroad. The idea was initiated by former finance minister Bambang Brodjonegoro who believed that the distinct region could facilitate the investment of funds… – Continue reading
You might think the Panama Papers leak would cause the ultrarich to seek more transparent tax havens. Not so, according to Jordan Greenaway, a consultant based in London who caters to the ultrawealthy. Instead, they are going further underground, seeking walled-up havens such as the Marshall Islands, Lebanon, and Antigua,… – Continue reading
Apple is a major part of why the United States is the world’s leading innovator on new technologies, particularly those involving telecommunications and computers. The company has over 66,000 domestic employees, and a large percentage of its customers are here — at least 40 percent, according to its latest annual… – Continue reading
The U.S. has used judicial might to successfully pursue offshore tax cheats all over the world. A little-noticed new rule introduced by Barack Obama’s administration gets tough on U.S. states such as Delaware and Nevada, which are notorious for murky shelters often used for illicit purposes. But there is a… – Continue reading
Four months since the so-called “Panama Papers” made global headlines, Panama continues a path of reform aimed at improving financial transparency and closing loopholes exploited by foreign tax cheats. Among our steps, we established an independent committee to examine Panama’s laws and regulations and make recommendations for strengthening them. While… – Continue reading
AN Intergovernmental Agreement (IGA) between Barbados and the United States will allow for greater co-operation under the Foreign Account Tax Compliance Act (FATCA). This is according to Julia Tonkovich, of the United States Treasury Department. Ms. Tonkovich stated that FATCA, which was in place since 2010, is part of the… – Continue reading
Despite Western opposition, the 134-member Group of 77 is continuing to pursue a longstanding proposal for an inter-governmental UN-affiliated tax body aimed at combating corporate tax dodging and curbing illicit financial flows, including money laundering and off-shore banking. The proposal has already been shot down twice by Western nations, first,… – Continue reading
The intergovernmental agreement (IGA) between Curacao, a low-tax Caribbean territory, and the United States implementing the US Foreign Account Tax Compliance Act (FATCA) is now in force. FATCA, enacted by the US Congress in 2010, is intended to ensure that the US obtains information on accounts held abroad at foreign… – Continue reading
