Category: USA

Global tax enforcement puts Cayman in the crosshairs

The investigation and prosecution of tax evasion has, in the last decade, grown from a specialised subcategory of law enforcement into a first-tier policy concern for the global community.Starting with the US government’s crackdown on Swiss bank UBS in 2008, there has been a steady drumbeat of news about prosecutions… – Continue reading

Markit launches tax utility

LONDON & NEW YORK–(BUSINESS WIRE)–Markit (Nasdaq:MRKT), a leading global provider of financial information services, today announced the launch of a tax utility. The initial offering supports compliance with US Treasury FATCA obligations. Designed in partnership with Deutsche Bank, HSBC and Morgan Stanley, the service provides tax form validation and secure… – Continue reading

Southeast State & Local Tax: Important Developments – March 2016

The Williams Mullen Southeast State and Local Tax (SESALT) team is pleased to provide you with a comprehensive recap of important tax developments around the Southeast. VIRGINIA CORPORATE INCOME TAX Conformity with Internal Revenue Code. Virginia Governor Terry McAuliffe signed emergency legislation on February 5, 2016 that advances the state’s… – Continue reading

International Tax Advisory: America’s Next Tax Model

The Treasury recently released a revised U.S. Model Income Tax Convention (the “2016 Model”), the U.S. starting point for bilateral treaty negotiation, last updated a decade ago. In May 2015, the Treasury circulated several proposed changes in draft form. Those proposals generally survive in the 2016 Model, although the Treasury… – Continue reading

FBAR, FATCA Filings Top 1 Million As IRS Increases Scrutiny On Foreign Accounts

A record high 1,163,229 Report of Foreign Bank and Financial Accounts (more commonly, FBARs) were filed in 2015, up more than 8% from the prior year. That growth, however, is nothing new: FBAR filings have grown on average by 17% per year during the last five years , according to… – Continue reading

How Other Countries Are Joining the U.S.’s Fight Against Offshore Tax Evasion

For the last five years, the U.S. has waged a strong battle against offshore tax evasion. In 2010, America began its boldest crackdown with the enactment of the Foreign Account Tax Compliance Act (known widely as “FATCA”). FATCA requires foreign financial institutions (e.g., banks, investment houses, etc.) doing business in… – Continue reading

Chinese Official: Turn South China Sea Island into Cayman Islands-Style Bank

China’s chess game to seize control of the South China Sea may take an interesting turn if an influential businessman’s suggestion is followed and Beijing turns one of the disputed islands into its very own Cayman Islands-style offshore bank. The idea, as explained by The Washington Post, is to establish… – Continue reading

The rich people who pay no tax

Only the little people pay taxes. For a small, select cohort of rich Australians, the famous quote of New York property billionaire Leona Helmsley rings not as an outrage but as an inspiration. In the most recent documents released by the Australian Tax Office, there were 55 people who had… – Continue reading

Tax tensions between the US and Europe hit new high

In the final session of the two day Global Tax Conference at Dublin Castle yesterday, a senior Canadian tax advisor used the analogy of children playing football to describe the relationship between multinationals and government when it comes to tax. In a kids football match, he said, when the ball… – Continue reading

Cayman National units admit helping U.S. clients evade taxes

Two units of Cayman National Corporation Ltd pleaded guilty to U.S. charges on Wednesday as part of a $6 million settlement of an investigation into how the financial services firm helped Americans evade paying taxes. Cayman National Securities Ltd and Cayman National Trust Co Ltd each pleaded guilty in federal… – Continue reading

Brown to introduce new tax payment regulation for corporations

With American corporations keeping a record amount of profits offshore to avoid paying U.S. taxes, U.S. Sen. Sherrod Brown (D-OH) will introduce legislation requiring corporations to “Pay What You Owe Before You Go.” During a news conference call today, Brown will outline his bill that would require corporations to settle… – Continue reading

Showdown looming over Singapore bank secrecy laws in UBS tax evasion case

NEWARK, NEW JERSEY (BLOOMBERG) – The US Internal Revenue Service (IRS) sought to make UBS Group turn over records on an account in Singapore held by a US citizen, setting up a showdown with the city-state over its bank-secrecy laws and potentially opening a new front against offshore tax evasion… – Continue reading

No double taxation agreement with Panama; Maltese domicile subject to tax on worldwide income

Maltese individuals resident and domiciled for tax purposes, that is people whose permanent residence is in Malta, are required to pay tax in Malta on their worldwide income, according to the Income Tax Act. This essentially means that Minister Konrad Mizzi is required to pay tax on foreign earnings. However… – Continue reading

Using tax money to raise taxes

If a member of Congress told you that he was going to use some of your hard-earned tax dollars to support an international organization that demands that you pay higher taxes, what would you say? Unfortunately, the question is not hypothetical, because that is exactly what is now happening. Congress… – Continue reading

Are all FDIs real foreign investment?

While the various reforms initiated by the Centre has led to a significant increase in FDI inflows into India, the Economic Survey feels the need for a closer examination of such FDI flows to determine whether there has been any instances of tax evasion. The survey noted that out of… – Continue reading

Would the real tax havens please stand

“It is tantamount to an economic blockade”. That’s how Antigua and Barbuda’s Prime Minister, Gaston Browne, described the current withdrawal from Caribbean indigenous and offshore banks of correspondent relationships by US banks. His sentiments were echoed by Dean Barrow and Freundel Stuart, the prime ministers of Belize and Barbados respectively…. – Continue reading

Trump, Sanders Agree on Ending Deferral of Overseas Earnings

During a political season in which populist fury and anger at big business is running high, two presidential candidates want to eliminate the ability of multinational firms to keep earnings overseas and avoid U.S. taxes. They also just happen to be the two most surprising and disruptive candidates in the… – Continue reading

US Democrat Bill Takes Further Aim At Inversions

On February 23, US House of Representatives Ways and Means Committee Ranking Member Sander Levin (D – Michigan) and Budget Committee Ranking Member Chris Van Hollen (D – Maryland) introduced legislation aimed at reducing the number of corporate tax inversions by limiting the use of “earnings stripping.” Tax inversion techniques… – Continue reading

IRS Releases Dirty Dozen Scam List: Don’t be a Victim

Each year, people fall prey to tax scams. That’s why the IRS sends a list of its annual “Dirty Dozen.” Stay safe and be informed – don’t become a victim. If you get involved in illegal tax scams, you can lose money or face stiff penalties, interest and even criminal… – Continue reading

Wind of Change: IMF Chief Calls For New International Taxation System

Governments globally should take steps to adjust taxation systems to close loopholes allowing multinational corporations to avoid paying taxes in countries of their origin, International Monetary Fund (IMF) Managing Director Christine Lagarde said on Monday. WASHINGTON (Sputnik) – The IMF chief said taxation allows governments to mobilize their revenues. She… – Continue reading

A tax haven professes to stand on principle, risking pariah status

PANAMA’S most notorious moment as a haven for tainted cash came with the nationalisation of money-laundering in the 1980s under Manuel Noriega, a military strongman. It has since clamped down on egregious financial criminality, but remains home to thousands of secretive firms and famous for the discretion of its bankers… – Continue reading

CBDT issues clarification for implementation of FATCA and CRS

New Delhi :The Central Board of Direct Taxes (CBDT) has issued a clarification with regard to an inter-governmental agreement between India and USA signed for implementation of Foreign Account Tax Compliance Act (FATCA). The CBDT further said in its statement that the Government of India has also joined the Multilateral… – Continue reading

Revealed: how Project Goldcrest helped Amazon avoid huge sums in tax

Documents released during the internet giant’s court battle with the US Internal Revenue Service over a possible $1.5bn in unpaid taxes detail a complex restructuring and a deal with Luxembourg that delivered Amazon multimillion-dollar savings Amazon is facing a landmark court ruling in the US that could prise open its… – Continue reading

A global revolution in corporate tax is taking place but it will not be televised

A quiet revolution is taking place across Europe. It isn’t playing out on the streets of capital cities or in the debating chambers of national parliaments. It has been slowly happening with every newspaper headline about how little corporation tax some companies pay relative to their size. It is also… – Continue reading

Cayman Islands: Getting Up To Date On FATCA – A Recap And Update

What is FATCA? FATCA refers to US legislation more fully known as the Foreign Account Tax Compliance Act and includes the US Treasury regulations implementing it. It was enacted as part of the Hiring Incentives to Restore Employment Act of 2010 (otherwise known as the, “HIRE Act”) on 18 March… – Continue reading

The biggest loophole of all

Having launched and led the battle against offshore tax evasion, America is now part of the problem DEVIN NUNES raised eyebrows in 2013 when, as chairman of a congressional working group on tax, he urged reforms that would make America “the largest tax haven in human history”. Though he was… – Continue reading

States Targeting Snowbirds Fleeing to Tax-Friendlier Climates

Wealthy taxpayers who split time between states should be prepared to prove where their true home lies. You’re lounging by the pool of your second home in Florida, chuckling as you think of your friends back home braving the blizzard in Massachusetts. And you’re musing: Perhaps it’s time to escape… – Continue reading

Apple’s latest tax avoidance ruse: Tech giant issues $12bn in bonds so that it doesn’t have to move money out of low-tax offshore havens to pay dividends

Apple has sold $12billion in bonds as part of another scheme to lower its tax bill. The tech giant got itself further into debt even though it has $215billion in the bank, more than the US Treasury. California-based Apple sold the bonds under a complicated scheme which is reportedly designed… – Continue reading

Poor Tax Policy Sends U.S. Businesses in Search of Friendlier Tax Climates

Pfizer, one of the largest multinational pharmaceutical companies in the world, recently announced plans to merge with Allegran, Plc, a pharmaceutical company based in Ireland. The new merged corporation, worth a total of $160 billion, will move its headquarters to Dublin, Ireland to avoid the U.S. government’s “double taxation” of… – Continue reading

Comment: Privacy v transparency – Withers’ Noseda on incoming OECD tax rules opening a new battle front

In almost every field of legal work, privacy is regarded as a primary and legitimate concern to protect the interests of individuals and organisations. This was confirmed recently when the European Court of Justice (ECJ) struck down the US-EU data exchange agreement amid fears that data transferred to the US… – Continue reading

Why a Hong Kong tax compliance act may be closer than you think

Where the United States leads on legislation, foreign jurisdictions slavishly follow Hongkongers will need to declare all their assets abroad by 2025. No, the government has not announced the policy yet. But academics have noticed a trend which strongly suggests Hong Kong will follow the US example in foreign tax… – Continue reading

Big corporations will always cheat (yep, I said cheat) on their taxes. Here’s how to deal with it

Let me give you a heads up: First, I’m going to tell you some things that will make you ill. Then I’m going to present a cure. It will make you feel better—until, of course, you realize that knowing the cure brings us as close to implementing it as buying an… – Continue reading

Varner: Taxes and international trade

A while back in Germany, I was driving on the straight as an arrow B-1. That is Bundesstrasse, the equivalent of a U.S. highway, a notch below the Autobahn. Roads tend to curve around farmers’ fields, having been there first. The B-1 from Cologne on the Rhine toward Berlin was… – Continue reading

Tax competition – that would be something to thank the Scots for

A 30% tax bracket. A rise in the standard rate, with a rebate for lower earners. Higher taxes all round to finance more spending. In Scotland, ahead of May’s elections for the devolved parliament, a fascinating debate on tax and spending is under way, with the main parties setting out… – Continue reading

California Legislature poised to pass replacement tax on health care plans

SACRAMENTO — After months of uncertainty, the Legislature appears poised to approve a tax on health care plans that would generate $1.27 billion annually and could substantially boost funding for developmentally disabled Californians for the first time in more than a decade. If lawmakers approve the tax in a series… – Continue reading

Banksters making the U.S. a tax shelter?

Just when you thought the banksters had done all they could to rig the game against people that bail them out, you hear another tale of industrial-strength greed. This time, the scam is so ironic it’s almost absurd. For almost a decade the U.S. government has been going around the… – Continue reading

FATCA has brought in just $13.5 billion in revenue on a cost of $1 trillion

Earlier this week the State Department released its latest statistics for people who have renounced their US citizenship. 2015 was another record year, with 4,279 people divorcing themselves from the US government and heading to greener pastures elsewhere. This was the third year in a row that broke the previous… – Continue reading

ECCB Governor seeks to speed up foreign banking agreements

The Eastern Caribbean Central Bank (ECCB) is seeking to expedite the signing of Intergovernmental Agreements (IGA) that will prevent the loss of correspondent banking relationships (CBR) for commercial banks in the Eastern Caribbean Currency Union (ECCU). Towards this end, Governor of the ECCB, Timothy NJ Antoine sought the assistance of… – Continue reading

Election is the calm in the storm of maintaining a competitive corporate tax regime

When Tim Cook and his two senior Apple colleagues were questioned by a US Senate sub-committee back in May 2013, the headlines generated in the world’s business press were unsettling. Some lawmakers repeatedly characterised Ireland as a tax haven, saying behemoth Apple channelled billions of dollars of global revenues generated… – Continue reading

Special investigation: Why it’s not just planes that vanish in Bermuda

Journalist Steve Topple investigates Bermuda-based big business tax avoidance and its links with UK political parties – and even some charities LAST WEEK saw the news emerge that everyone’s favourite search engine, Google, only had to pay £97m in back-tax (not the “major success” of £130m as was first reported)… – Continue reading