Fertilizer maker CF Industries and Dutch rival OCI NV, which agreed to merge in August, said they would move the tax residency of the combined company to the Netherlands from the U.K., in a move to satisfy inversion rules put in place by the U.S. Treasury. When the deal was… – Continue reading
When someone dies owning an unreported financial account, the heirs and executors of the estate are faced with a serious problem. First, assuming there is undeclared income earned with respect to the account, such income will generate a tax liability for the decedent with respect to any tax years that… – Continue reading
All insurers to undertake a value search for new accounts opened after Sept 1 and up to Oct 31 by Dec 31 Insurance regulator Irdai has directed all insurers to register and submit information to CBDT for compliance with the obligations under Foreign Account Tax Compliance Act (FATCA) – Common… – Continue reading
The start date for the Common Reporting Standard (CRS) in early adopting countries is approaching fast, with financial institutions required to begin new account on-boarding procedures from 1 January 2016. CRS requires financial institutions in participating jurisdictions to identify account holders who are tax resident in other participating jurisdictions and… – Continue reading
President Obama signed the Protecting Americans from Tax Hikes Act of 2015 (the “Act”) into law on December 18, 2015. The Act extends retroactively certain provisions of the Internal Revenue Code (the “Code”) that had expired at the end of 2014 and makes a number of other changes to the… – Continue reading
A United States UBS bank client has failed in his bid to sue the Swiss authorities for handing his data to the US during a tax evasion row between the two countries. The European Court of Human Rights (ECHR) said the economic interests of Switzerland outweighed his individual privacy. The… – Continue reading
The Cayman Islands Tax Information Authority (TIA), on December 8, 2015 provided the following implementation updates for the Common Reporting Standard (CRS): 1. Updated Self-Certification Forms ( Individual and Entity) for compliance with CRS, U.S. and U.K. FATCA, which should be used by Cayman Islands funds. From January 1 onwards,… – Continue reading
Dec. 21 — The IRS proposed rules requiring large companies to report information including the amount of revenue, profit or loss, capital and accumulated earnings for each country of operation, consistent with OECD recommendations designed to combat base erosion and profit shifting. The proposed rules (REG-109822-15, RIN 1545-BM70) would apply… – Continue reading
American expats could have their passports revoked next month if they fail to comply with their tax and financial obligations. American expats could have their passports revoked next month if they fail to comply with their tax and financial obligations under the Foreign Account Tax Compliance Act, or Fatca, a… – Continue reading
The Treasury Department released a proposal on Monday that would require certain companies to annually report information relating to income and taxes on a country-by-country basis. The proposal would apply to businesses that are the parents of multinational enterprise groups with annual revenue of at least $850 million. The categories… – Continue reading
IRS Criminal Investigation » Agency initiated 3,853 investigations nationally and is nabbing criminals from tax cheats to terrorists despite budget cuts, chief says. Utahn Gerrit Timmerman III claimed his corporation — “The Office of the First Presiding Patriarch (Overseer) and his/her successors, a corporation sole over/for an unincorporated scriptural society,… – Continue reading
IT is ironic that what was almost at the centre of the BEPS project has ended up in not having a concrete agreement and with a vague promise of some review by the year 2020. One may recall that it was the big digital companies and their tax affairs that… – Continue reading
It is possible that the United States expats could have their passports revoked next month if they fail to comply with their tax and financial obligations under the Foreign Account Tax Compliance Act (FATCA). This was revealed by Mr. Jim O’Niell, Vice President of US Financial Advisory & Audit Firm… – Continue reading
American citizens risk losing passports if they do not report foreign income, bank accounts Dubai Americans must comply with tax law changes coming into effect in the new year and report income earned abroad and foreign-held bank accounts over $10,000 (Dh36,700) or else they risk losing their passports, a US… – Continue reading
The Protocol amending the Multilateral Convention on Mutual Administrative Assistance in Tax Matters will lead to substantially more transnational identity theft, crime, industrial espionage, financial fraud, and the suppression of political opponents and religious or ethnic minorities by authoritarian and corrupt governments. It puts Americans’ private financial information at risk…. – Continue reading
The Markets Supervision Directorate of the Central Bank published its programme of themed-inspections for 2016. These inspections reflect a number of supervisory priorities for 2016 and anticipate areas of emerging risk. This programme builds on the successful supervisory work undertaken in 2015 in the areas of Cyber Security, Operational Risk… – Continue reading
While Cayman National maintains its financial stability it says it is unable to declare a dividend as it prepares to pay some CI$5 million as a potential settlement with the US authorities over criminal law breaches related to tax evasion. The financial institution, in its Fourth Quarter report (ending 30… – Continue reading
Swiss private banking group Julius Baer Group Ltd. (JBAXY.PK,JBARF.PK) may have to pay more than it anticipated to settle a case with the U.S. Justice Department over American offshore accounts, according to media report quoting people familiar with the matter. The report indicated that the U.S. prosecutors could ask Julius… – Continue reading
The provisions commonly known as the Foreign Account Tax Compliance Act (FATCA) became law in March 2010. •FATCA targets tax non-compliance by U.S. taxpayers with foreign accounts •FATCA focuses on reporting: •By U.S. taxpayers about certain foreign financial accounts and offshore assets •By foreign financial institutions about financial accounts held… – Continue reading
An Easy Checkoff for Global Competitiveness: The Case for a U.S. Innovation Box – Robert D. Atkinson – November 30, 2015. “Taxing corporate revenues from innovation-based activities less will not only boost U.S. global competitiveness it will help bring back IP-based corporate profits now overseas. “Within the last decade a… – Continue reading
NEW YORK – The General Manager of Pakistan’s Habib Bank Ltd., New York branch, said Friday that steps have been taken to address the concerns of U.S. authorities after being hit by an enforcement order that barred the bank from conductingany dollar-clearing transactions or accepting any new accountsfor U.S. dollar… – Continue reading
Apple CEO says the company pays ‘every tax dollar we owe’ amid debate in the US over corporations avoiding tax by using offshore units Apple’s chief executive Tim Cook has dismissed as “total political crap” the notion that the technology giant was avoiding taxes. Cook’s remarks, made on CBS’ 60… – Continue reading
Edmond de Rothschild (Suisse) SA agreed to pay $45.4 million to avoid prosecution for helping U.S. clients evade taxes, admitting it aided them in moving cash and using sham offshore entities to hide money from the Internal Revenue Service. Rothschild is the 68th Swiss bank to reach an accord with… – Continue reading
The Bundesrat (upper house of the German parliament) approved the Law on the Automatic Exchange of Financial Account Information (Finanzkonten-Informationsaustauschgesetz) on 18 December 2015. Financial institutions face new reporting obligations and duties of care under this law. The new legislation requires financial institutions to provide the German Federal Central Tax… – Continue reading
When purchasing a real property overseas, there are situations when it may prove advantageous or even necessary to do so through an offshore corporation, rather than owning the property individually. It is crucial to understand that this can also have significant US tax consequences for US persons. Fortunately, “checking the… – Continue reading
The Department of Justice announced today that Edmond de Rothschild (Suisse) SA and Edmond de Rothschild (Lugano) SA (collectively EdR Switzerland) reached a joint resolution under the department’s Swiss Bank Program. EdR Switzerland will pay a penalty of more than $45 million. The Swiss Bank Program, which was announced on… – Continue reading
MUMBAI|NEW DELHI: Many US-based non-resident Indians are considering selling their property in India – even at a discount – amid confusion and fear that a new information-sharing protocol may bring their assets, bank accounts, mutual funds and capital market investments in India under the scanner of US tax authorities. India… – Continue reading
Employees relocating from Canada to the US may face a number of complex tax-related issues. Matt C Altro, president and CEO of Canadian firm MCA Cross Border Advisors, shares his advice for companies and their relocatees on planning for, and coping with, these challenges. Talent mobility is a key issue… – Continue reading
2016 Compliance Update For the past few years, FATCA has dominated the international tax compliance landscape. As that regime continues to be phased-in, a new regime – the Common Reporting Standard (“CRS”) – will begin to be implemented around the world. CRS, sometimes referred to as “Global FATCA,” will expand… – Continue reading
SYDNEY, Dec 17 (Reuters) – Australia on Thursday identified 600 companies which it said paid no tax last financial year, including Halliburton Co and Hilton Worldwide Holdings Inc, as part of a campaign to challenge “overly aggressive” tax arrangements. The Australian Taxation Office published the income and tax rates of… – Continue reading
According to a research report titled “Illegal Financial Flows from Developing Countries: 2004-2013”, recently published by the Washington based research institute Global Financial Integrity (GFI), Bangladesh stands 26th in the list of 149 developing nations, in terms of flight of capital including money laundering (The Daily Star, December 10, 2015)…. – Continue reading
Dreyfus Sons & Co. has operated for two centuries as a private Swiss bank, catering to Jewish clients who wanted to hide assets from the Nazis during the 1930s and World War II. More recently, it helped U.S. clients hide assets from the Internal Revenue Service by concealing their true… – Continue reading
It has been a tough year for Russian businesses. The latest monthly forecast of the Economist Intelligence Unit (EIU) predicts a contraction in Russian real GDP of 3.8% in 2015 and another 0.5% in 2016. “Structural weaknesses will keep trend GDP growth below 2% a year in the medium term,”… – Continue reading
Australian tax authorities on Thursday took the unprecedented step of publishing the records of hundreds of companies, including Google Inc (GOOGL.O) and Apple Inc APPL.O, which show they paid little or no tax on their in-country earnings. Of more than 1,500 largely foreign-owned companies which reported total earnings over A$100… – Continue reading
Fifty-three jurisdictions have agreed to automatic exchange of tax information beginning in 2017, under the OECD’s Common Reporting Standard. Over 40 others have committed to exchange information by 2018. Another wave of global tax information is about to take place, and financial institutions everywhere are in a race to prepare… – Continue reading
Given that the latest treaty was signed on 15 November 1967, the two countries felt it was appropriate to revise it in full. The new treaty, signed on Tuesday by the Spanish Ambassador to Finland, María Jesús Figa, and the Finnish Minister for Finance, Alexander Stubb, seeks to enable tax… – Continue reading
Over 90 jurisdictions have committed to the OECD’s Common Reporting Standard (CRS), creating comprehensive global automatic information exchange for financial assets and the entities through which such assets may be held. Over 70 jurisdictions have signed the OECD’s Multilateral Competent Authority Agreement, which implements the CRS. The CRS is scheduled… – Continue reading
Draft 2015 Instructions for Form 8966. IRS has published a draft version of the instructions to the 2015 Form 8966 (FATCA Report), which certain foreign financial institutions (FFIs) and others use to report information with respect to U.S. accounts under the Foreign Account Tax Compliance Act (FATCA). The instructions reflect… – Continue reading
RIGA – The Latvian Financial and Capital Markets Commission (FCMC) on Dec. 11 imposed a record 2-million-euro fine on Ukrainian-owned A/S Privatbank and ordered the dismissal of its CEO and managing board for violations of money laundering and other banking regulatory laws in connection with the alleged plundering and collapse… – Continue reading
The European Commission has extended its investigation into a tax ruling provided by the Irish Government to Apple. The Commission has asked the Irish authorities for additional information on the case. Irish media reports that the Government does not anticipate a decision until 2016. In late November, Finance Minister Michael… – Continue reading
On 22 December 2014, the Italian Parliament approved the Budget for 2015.40 Among other measures, the Law introduces the possibility of an exemption from corporate income tax (IRES, generally levied at 27,5%) and local tax (IRAP, generally levied at 3,9%) on income derived from qualifying intangible assets (such as patents,… – Continue reading
The $160bn (€146.5bn) merger of US pharmaceutical giant Pfizer with Dublin-based Allergan is an “opportunity” for Ireland, according to IDA chief executive Martin Shanahan. Last month Pfizer, the world’s largest pharmaceutical company, announced plans to merge with Botox manufacturer Allergan in a deal that will create the world’s biggest drug… – Continue reading
There are a number of ways to structure your offshore fund and the best option for you will depend largely on the location of the manager, your investor base and the type of investments that the fund will make. I have set out a summary of the three most common… – Continue reading
The U.S. Internal Revenue Service (IRS) has released Instructions for Form 1042 for 2015 that provide guidance for withholding agents regarding the filling in of their form. It includes updates for FATCA requirements in accordance with the newly issued regulations under Chapter 3 and 4 of the Internal Revenue Code…. – Continue reading
(CN) – A Russian nuclear energy official living in Maryland has been sentenced to four years in federal prison on money laundering charges, the Justice Department announced Tuesday. Vadim Mikerin, 56, of Chevy Chase. Md. was also ordered to forfeit more than $2.1 million, after he pleaded guilty to charges… – Continue reading
FATCA (the Foreign Account Tax Compliance Act) came into force in July 2014. It is far-reaching and may impose a compliance burden on the trustees of New Zealand family trusts, even if no US persons are involved. IRD has recently issued further draft guidance on the application of FATCA to… – Continue reading
Lately, the IRS is warning offshore account holders to disclose before it’s too late. Under FATCA, banks everywhere want to know if you are compliant with the IRS. And the cost of compliance for many people is growing. The IRS updated its list of foreign banks where accounts trigger a… – Continue reading
The US has refused to join the Common Reporting Standard (CRS) which binds banks to share information about assets with tax services of other countries. Switzerland has accused the US of double standards and abuse of confidence. On May 6, 2014, 47 countries agreed on a common reporting standard, an… – Continue reading
[BEIJING] China’s central bank is on guard against a sudden attack on the yuan in offshore markets, and is ready to intervene if the gap between offshore and onshore exchange rates becomes destabilising, sources involved in policy discussions say. Though the People’s Bank of China (PBOC) wants to avoid a… – Continue reading
Coffee chain Starbucks said it paid £8 million in corporation tax last year after posting record UK profits. The UK arm of the US-based chain said pre-tax profits jumped to £34.2 million in the year to September 27, compared with less than £2 million a year ago – as it… – Continue reading
