Category: USA

Big U.S. firms hold $2.1 trillion overseas to avoid taxes: study

The 500 largest American companies hold more than $2.1 trillion in accumulated profits offshore to avoid U.S. taxes and would collectively owe an estimated $620 billion in U.S. taxes if they repatriated the funds, according to a study released on Tuesday. The study, by two left-leaning non-profit groups, found that… – Continue reading

Isle of Man: US FATCA Information Exchange Put Back A Year

In a move which is likely to be of interest to those organisations who put systems and procedures in place to comply, the US has recently announced (September 2015) that information on US persons does not now need to be exchanged for certain jurisdictions until September 2016. In Notice 2015-66… – Continue reading

Gaming the System: Underlying Problems of the U.S. Tax Code Must be Addressed

Last year at this time, news about “tax inversions” was grabbing headlines – cases where large U.S. multinationals would buy a foreign company in a tax-friendly jurisdiction, and then relocate its headquarters to reap the tax arbitrage benefits. The Obama administration responded to the rash of high-profile inversions with new… – Continue reading

Internal Revenue Service Begins Reciprocal Automatic Exchange of Tax Information Under FATCA IGAs

On October 2, 2015, the Internal Revenue Service announced that it had achieved a key milestone in implementation of the Foreign Account Tax Compliance Act (FATCA), a critical anti-tax evasion law passed by Congress in 2010 but not fully implemented until July 2014. The milestone announced by the IRS was… – Continue reading

Horizon Pharma relocates U.S. headquarters to Lake Forest

Daily Herald Reports Specialty drug manufacturer Horizon Pharma, which moved its corporate headquarters from Deerfield to Ireland in 2014, announced it is relocating its U.S. headquarters from Deerfield to Lake Forest as part of a company expansion. The Dublin-based company reported it signed a long-term sublease on a 160,000-square-foot building… – Continue reading

Foreign governments ready cash grab on U.S. earnings

Opposition to foreign taxes on American investment and hard work has been coded into our national DNA for almost 240 years. Yet almost two and a half centuries after resolving that we would not stand idle while others decide how to tax us, Americans once again must take decisive action… – Continue reading

US Has World’s Third-Highest Corporate Tax Rate

Not only does the United States retain the dubious distinction of having the highest corporate tax rate in the Organisation for Economic Cooperation and Development country grouping, it now has the third-highest rate of corporate tax in the world, according to the Tax Foundation. The non-partisan tax policy think tank… – Continue reading

Plans to overhaul global tax system to be published

A plan for overhauling the global system for the taxation of multinationals, to be published on Monday in Paris, will contain major challenges and opportunities for Ireland’s vital foreign direct investment (FDI) sector, according to tax experts, reports the Irish Times. The culmination of two years’ work, the report by… – Continue reading

FM warns of action against those hiding assets abroad

Finance Minister Arun Jaitley on Sunday said that people who had not declared their undisclosed assets in the 90-day compliance window offered by the government will now face the law including penalty and sentence upto 10 years while 638 people who had made the declaration can “now sleep well.” In… – Continue reading

KPMG Statement On OECD’s Final Recommendations On Base Erosion And Profit Shifting (BEPS) Initiative

NEW YORK, Oct. 5, 2015 /PRNewswire/ — The following statement is being issued today by KPMG LLP on the final recommendations released on Oct. 5 by the Organisation for Economic Co-operation and Development (OECD) on its coordinated Action Plan on Base Erosion and Profit Shifting (BEPS): “The OECD’s final recommendations… – Continue reading

OECD to unveil global tax plans

The OECD’s measures to reform international corporate tax systems will cause Ireland fewer problems than forecast, but for eurozone countries it will be just the beginning of greater and more detailed change. Following two years of constant meetings between tax experts from its 34 country members, the Paris-based body releases… – Continue reading

Two banks owned by Lord Ashcroft at centre of major US tax evasion probe

Two banks owned by former Tory Party vice-chairman Lord Ashcroft are at the centre of a major US tax evasion investigation. Authorities are probing whether wealthy Americans have been using the banks, based in the Central American tax haven Belize, to shelter funds offshore. Billionaire Lord Ashcroft is the majority… – Continue reading

India signs 16 advance pricing agreements with MNCs

The income tax department has signed 16 advance pricing agreements (APAs) with multinational companies (MNCs) so far, exempting their transactions with local units from rigorous tax audits. The income tax department has signed 16 advance pricing agreements (APAs) with multinational companies (MNCs) so far, exempting their transactions with local units… – Continue reading

Caribbean countries under attack

Once again, Commonwealth Caribbean countries are under attack as “tax havens”, even though they are nothing of the sort. This time it is not only the usual countries which have been listed. Trinidad and Tobago has been included, and we can bet that Jamaica and Guyana will be added unless… – Continue reading

US Treasury Department adds India to its FATCA list

MUMBAI: The US Treasury Department has issued a list of 34 countries which includes India with whom it would share information under FATCA (foreign account tax compliance act) regulations. The pact aims to cover automatic sharing of information on bank accounts and other instruments like mutual funds, insurance and equities… – Continue reading

US probes peer’s banking operation

AS the more lurid and unproven claims in Lord Ashcroft’s self-published hatchet job on the prime minister attract widespread ridicule, more embarrassment looms for the Tory peer concerning his banking operations in shady Belize. The US Department of Justice recently issued a summons for details of so-called correspondent bank accounts… – Continue reading

Tax Court Decision in Altera Overturns Important Transfer Pricing Regulations

On July 27, 2015, the U.S. Tax Court issued a stunning rebuke to the IRS by invalidating the part of the Internal Revenue Services’ (IRS) cost-sharing regulations under section 482 of the Internal Revenue Code that says taxpayers have to take into account, among other costs, the costs of stock-based… – Continue reading

A Pig Story, Belize Banks and Questions About U.S. Tax Evaders

It’s not just about the pig’s head. Britain’s headline writers went into high porcine pun mode last month over a suggestion that Prime Minister David Cameron, while still in university, had taken part in a club-initiation ritual that bizarrely incorporated part of a pig carcass. The second-hand allegation appears in… – Continue reading

IRS Begins Exchanging Tax Info with Other Countries under FATCA

The Internal Revenue Service said Friday it has met a key milestone relating to the Foreign Account Tax Compliance Act, or FATCA, having begun exchanging tax information with certain foreign governments in time to meet a Sept. 30, 2015 deadline. The automatic exchange of account information with tax authorities abroad… – Continue reading

Tax and information reporting requirements for US taxpayers living abroad

Introduction The Foreign Account Tax Compliance Act (FATCA) requires non-US financial institutions, including investment entities, to report US account holders to the Internal Revenue Service (IRS). This reporting is causing US taxpayers living abroad to consider whether they have been adequately filing annually their income and information returns in the… – Continue reading

Luxembourg completes FATCA implementation by enacting Luxembourg–U.S. intergovernmental agreement

The Luxembourg “FATCA Law”1 became effective on 1 August 2015. Among other provisions, the FATCA Law implemented the Model 1 Luxembourg–U.S. intergovernmental agreement of 28 March 2014 (IGA). On the day prior to the law taking effect, the Administration des Contributions Directes (Office of Income Tax) issued two circulars on… – Continue reading

Jersey: The Offshore Dragon: The Increasing Popularity Of IFCs In The PRC

Using companies incorporated in international financial centres (IFCs) in structuring financial transactions, capital raisings and corporate structures has long been popular in Asia, particularly Hong Kong (itself an IFC). Following the energetic expansion of the PRC economy and assisted in part by the relaxation of PRC regulations in relation to… – Continue reading

SA ranks above developed countries in ‘hidden’ money

SOUTH Africa has ranked higher than several developed countries in an assessment of money “hidden” in HSBC Swiss bank accounts, a report showed on Wednesday. “The money connected to SA was higher than money connected to France, eight times higher than that of the US, and 3.5 times more than… – Continue reading

Cambodia – United States: FATCA Agreement Signed

On 14 September 2015, Cambodia and the United States signed a Foreign Account Tax Compliance Act (FATCA) Agreement. FATCA seeks to obtain information on accounts held by U.S. taxpayers in other countries. It requires U.S. financial institutions to withhold a portion of certain payments made to Foreign Financial Institutions (FFIs)… – Continue reading

Only Rs 3k-cr disclosures in govt’s compliance window

A stream of people, including those from Rajasthan and Karnataka, walked into the only designated office before the closure of the one-time compliance window The Centre’s efforts to unearth unaccounted money stashed abroad seems to have got a tepid response, with the declarations made under the three-month compliance window that… – Continue reading

More disappointing news for U.S. citizens residing in Canada

In addition to Justice Martineau’s denial of injunctive relief and dismissal of the request for summary judgment in Hillis and Deegan v. The Attorney General of Canada, as discussed in our previous post, U.S. citizens residing in Canada received more disappointing news on September 29, 2015, when Judge Thomas M…. – Continue reading

Obamacare’s Cadillac Tax is very unpopular, except…

Not many people actually like Obamacare’s dreaded “Cadillac Tax,” including, reportedly, Hillary Clinton. But that doesn’t mean it will necessarily get repealed before it starts in 2018. A new survey shows that while that tax, which targets high-cost, employer-based health plans, is at first glance broadly unpopular with the public,… – Continue reading

New Thomson Reuters Report Equips Tax Professionals to Help Clients Comply with FATCA

NEW YORK, September 30, 2015 – A new report from Thomson Reuters sheds light on the dividend and income reporting requirements for banks, brokerages, and other financial institutions under the Foreign Account Tax Compliance Act (FATCA). Published by Thomson Reuters Checkpoint, New FATCA Compliance Obligations Facing Business Entities can be… – Continue reading

Ambassador Newry protests Bahamas’ tax haven status in DC

WASHINGTON, D.C., Sept. 30, 2015 –His Excellency Dr. Eugene Newry, Bahamas Ambassador to the United States, has written a letter to Municipal Officials of the District of Columbia and Federal Congressional Officials protesting “in the strongest terms” The Bahamas’ designation as a “tax haven” by D.C. authorities in the District… – Continue reading

Are corporate tax inversions ‘unpatriotic’?

Moving overseas to cut tax burden remains a viable option for some firms, though the presidential candidates may have other plans. With the long haul of a presidential election campaign just beginning, companies that leave the U.S. to lower their tax bills are once again political targets. Donald Trump this… – Continue reading

Montserrat – United States: FATCA Agreement Signed

On 8 September 2015, Montserrat and the United States signed a Foreign Account Tax Compliance Act (FATCA) Agreement. FATCA seeks to obtain information on accounts held by U.S. taxpayers in other countries. It requires U.S. financial institutions to withhold a portion of certain payments made to Foreign Financial Institutions (FFIs)… – Continue reading

U.S. IRS and Mexican SAT begin sharing info on bank accounts

WASHINGTON, D.C. — United States authorities have begun the exchange of information with Mexico on all Mexicans with bank accounts or investments in the U.S. who have obtained more than $10 USD in annual interest. With the implementation of the Foreign Account Tax Compliance Act (FATCA), Mexico plans to deliver… – Continue reading

Sunlight is the best way to disinfect corporate tax havens

Tax havens are by design secretive and opaque. The entire point of their existence is to conceal the wealth hidden within them. And a new book by Gabriel Zucman, The Hidden Wealth of Nations: The Scourge of Tax Havens, reveals, as never before, the extent of their role in the… – Continue reading

US$7.6tn hidden in tax havens – almost half annual US GDP

Gabriel Zucman, one of 3 French economists who in recent times have published extensive research on wealth and equality, in a book, ‘The Hidden Wealth of Nations: The Scourge of Tax Havens,’ published this month, estimates that 8% of the world’s financial wealth — some US$7.6tn — is hidden in… – Continue reading

OECD says Ireland to benefit post-BEPS

The OECD has said that its base erosion and profit shifting (BEPS) project will create policy challenges for Ireland, but the nation should emerge well placed to attract foreign direct investment, reports Tax News. The report states: “Given the strong presence of intellectual property-intensive information technology and pharmaceutical companies in… – Continue reading

“Delaware LLCs and UK Entity Classification: The Fallout From the Curious Case of George Anson”

Fundamental to any developed tax policy is knowing who the taxpayer is (or should be) with respect to any particular transaction. Although that can be relatively straightforward in purely domestic situations, a cross-border dimension can present different answers to this question in the jurisdictions involved and lead to issues over… – Continue reading

United States: Smooth Move: US Tax Tips Every Top Executive Should Know Before Moving To The United States

If you are a foreign executive moving to the United States for work, not only do you have to consider practical concerns like moving your family and finding a new residence, but you also need guidance as to any US tax implications stemming from the move. One of the first… – Continue reading

Crunchtime for OECD global tax-avoidance push

Efforts to amend details of new rules on corporate profits raise questions, reports the Wall Street Journal. Nearly 50 governments are set to agree this fall to a new set of rules to clamp down on tax avoidance among multinational corporations. Their chance of success, however, is unclear. If the… – Continue reading