HMRC has today published new draft guidance notes to cover the automatic exchange of financial account information under the International Tax Compliance Regulations 2015 (SI 2015 No. 878) (the Regulations), which were made in the spring. The main document is a new draft HMRC guidance manual covering the Regulations. The… – Continue reading
U.S. authorities have targeted Belize-based banks in a new expansion of their hunt for Americans suspected of evading taxes by hiding income and assets in offshore accounts. A federal court in Miami on Wednesday approved special “John Doe” legal summonses seeking information about U.S. taxpayers who may hold undeclared accounts… – Continue reading
The Chief Minister has written to the District of Columbia Council to find out why the Isle of Man has been placed on their tax black-list, reports Energy FM. The Island featured on their list of ‘tax havens’ in their recent fiscal year report, along with 39 other countries. Allan… – Continue reading
“I want to commend the government for bringing this bill to parliament,” said Opposition Leader Hon. Dr. Denzil Douglas said today of the government tabled Foreign Account Tax Compliance Act (USA) (Implementation and Enforcement) Bill 2015. During his presentation on the bill’s debate in the National Assembly today (Sept 15),… – Continue reading
Jay Fishman, who built New York-based Travelers Cos. into one of the world’s biggest insurers, lamented that disparities in tax rates are pushing established rivals and industry newcomers outside the U.S. Over the past 15 years or so, “we’ve counted 10, 12, maybe even 15 Bermuda-based startups that ultimately became… – Continue reading
Chevron’s tax filings face repeated challenges from the United States and other global tax authorities, according to a new union-backed report that calls on world governments to crack down on the energy giant’s alleged profit-shifting tactics. The world’s largest trade union body, the International Trade Union Confederation (ITUC), has called… – Continue reading
Banks are threatening to close accounts of British expats living in the USA if they fail to complete piles of paperwork to comply with the Foreign Account Tax Compliance Act (FATCA). Millions of US expats worldwide are already caught by the law which requires foreign financial institutions to supply details… – Continue reading
Hong Kong’s Financial Services Development Council (FSDC) has released a report setting out recommendations on policies, including tax measures, to enhance the city’s role as a regional and global financial booking center. Financial institutions utilize such centers to enter into contracts for financial products, undertake primary obligations for delivery or… – Continue reading
Action 6 (Treaty Abuse) is a key element of the OECD’s BEPS Project. Action 6 targets, in summary, “treaty shopping”, i.e., where a person in country A, which is not, in principle, eligible to benefit from a given tax treaty with country B, invests through an entity in country C… – Continue reading
In a decision released August 14, the Tax Court of New Jersey ruled that an intangible holding company with no physical presence was required to file a New Jersey corporation business tax (CBT) return and pay the related tax due based on its income.1 No relief was available to the… – Continue reading
NEW YORK: Noting that progress on a bilateral investment treaty with India has been “slow”, a senior US trade official has said in the absence of progress on economic reforms by India to ensure ease of doing business, the likelihood of getting to such a treaty is “low”. “Frankly, it… – Continue reading
A federal court judge dismissed an attempt to put an early stop to a controversial program in which the Canadian government agreed to share financial information of an estimated one million “U.S. persons” living in Canada with the Internal Revenue Service. Particularly troubling to some opponents is that the agreement… – Continue reading
On Thursday, The House Ways and Means Committee will once again contemplate making permanent controversial tax breaks that overwhelmingly benefit big business at a cost of $380 billion over the next 10 years. Known as tax extenders, these giveaways are a package of tax breaks that Congress must vote to… – Continue reading
The Inland Revenue Board of Malaysia in September 2015 issued guidance concerning the requirements for compliance with an intergovernmental agreement (IGA) to implement the FATCA regime. The FATCA guidance notes provide guidelines and practical information for Malaysian-based financial institutions, businesses, their advisers, and officials dealing with application of the FATCA… – Continue reading
Consolidation in Europe’s private-banking industry is inevitable as pressure from clients and regulators increases costs, McKinsey & Co said in a study published yesterday. Pressures on profit margins could force private banks to cut costs and review the number of booking centers they operate, the New York-based consultancy said. The… – Continue reading
The largest producer of nitrogen-based fertilizer in the United States, CF Industries, is considering merging with a Dutch competitor and moving its headquarters overseas to avoid the “double taxation” of profits earned by overseas subsidiaries going to the domestic company. Curtis Dubay, a tax and economic research fellow with The… – Continue reading
Administrators of tax-qualified retirement plans (or their delegated payor) are responsible for both withholding on distributions and for reporting the tax withheld. If taxes are under-withheld, the administrator/delegated payor may be subject to penalties. Although the rules governing withholding on distributions to US citizens and resident aliens are clear and… – Continue reading
(Bloomberg) — Grupo BTG Pactual, the only publicly traded investment bank in Brazil, said it’s willing to consider more acquisitions in Switzerland after completing the purchase of BSI, the Swiss private-banking unit of Assicurazioni Generali SpA. “We are looking. We are always looking,” Renato Cohn, a BTG partner and member… – Continue reading
Google’s CEO may be “proud” of the way his company avoids taxes, but a Canadian tax watchdog group thinks the tech giant’s tax practices should disqualify it from partnering in a Canadian election debate. The Globe and Mail is hosting a leaders’ debate on the economy Thursday night in partnership… – Continue reading
The Department of Justice announced today that Bank La Roche & Co AG has reached a resolution under the department’s Swiss Bank Program. “Today’s agreement is yet another example of a foreign financial institution coming forward, acknowledging its criminal conduct, taking the necessary steps to resolve its criminal exposure, cooperating… – Continue reading
The number of banks with deferred prosecution agreements with the U.S. government keeps growing. The subject is tax evasion involving American account holders. Today, under FATCA, banks everywhere want to know if you are compliant with the IRS. And the IRS keeps updating its list of foreign banks where offshore… – Continue reading
Is Xi Jinping (習近平)’s anti-corruption campaign crushing it or embarrassingly ineffective? You make the call. It was widely reported the year before Xi assumed office that upwards of 18,000 corrupt officials had fled China since 1990 with about US$120 billion. In early 2012, the Ministry of Supervision released figures saying… – Continue reading
An increasing number of Americans renounced their citizenship and cut-off long term residencies during the initial three months of 2015 due to a crackdown in the foreign tax rules. The exit wave went down a little in the second half, but has continued. The Internal Revenue Service and Treasury Department… – Continue reading
Note: This article was published by Bloomberg BNA in Tax Planning International European Tax Service Vol. 17 No. 7 July 2015 Introduction The recent LuxLeaks scandal has once again focused political attention on tax planning practices of multinationals (“MNEs”). It comes in the wake of the European Commission investigation of… – Continue reading
Seven leading Democrat lawmakers wrote a letter on September 12 to US Treasury Secretary Jack Lew urging him to publish an annual list of companies that have undertaken corporate tax inversions, and to use the Administration’s executive authority further to discourage the use of inversion techniques. Tax inversion techniques are… – Continue reading
The decree of 2015 in accordance with the Assessment and Collection of Taxes Law (Exchange of Information within the framework of the Agreement for the Foreign Account Tax Compliance Act) has been issued and published in the official Gazette of the Republic of Cyprus dated 28th August 2015 (Decree 281/2015)… – Continue reading
It may be a common misunderstanding that a U.S. citizen or permanent resident (Green Card holder) can give up their citizenship or surrender their Green Card and then as a non-U.S. taxpayer make gifts or pass their estate to U.S. taxpayers free of estate and gift tax. The IRS recognized… – Continue reading
A wave of wealthy Asians is hurriedly moving assets to the United States – to school their children, invest in property or even avoid political uncertainty in China. But few of those immigrants know just how much of their money will eventually end up in the hands of the feds…. – Continue reading
Many countries have enacted a patent box regime in order to spur innovation and create domestic manufacturing jobs. Simply stated, a patent box regime provides a lower tax rate on income from the exploitation of patented goods than for other income. Among the countries that have patent box regimes are… – Continue reading
Panama in May 2014 indicated its intentions to enter into an intergovernmental agreement (IGA) with the United States, for purposes of implementing the FATCA regime. The Panama agreement would follow the Model 1 IGA. As of early September 2015, Panama has yet to sign the IGA. In preparing for implementation… – Continue reading
Budgeting battle But like much of the budgeting in Washington, D.C., it gets complicated. The Congressional Budget Office contends the Ex-Im Bank’s surpluses are the result of the accounting method the bank uses and would disappear — or require a taxpayer subsidy — if the bank used a more appropriate… – Continue reading
Democratic lawmakers urged the Obama administration to take a more aggressive stance toward the offshore tax deals known as inversions. Seven congressional Democrats in all called on Treasury Secretary Jack Lew to take executive action against a technique known as earnings stripping that makes the offshore deals more attractive. They… – Continue reading
An initiative intended to catch tax dodgers could have a negative impact on those with perfectly legitimate bank accounts. Tax expert Howard Bilton offers advice The draconian Foreign Account Tax Compliance Act (FATCA), introduced by the US Government to tackle tax evasion by its citizens, has already affected Britons living… – Continue reading
Indonesians hold $300 billion in Singapore; controversial tax amnesty on the cards. Indonesia’s finance minister Bambang Brodjonegoro told Euromoney earlier this year that tax collection falls way short of targets and must improve to provide funding for infrastructure and other projects It doesn’t take much for Indonesia’s government officials to… – Continue reading
India’s Ministry of Finance, Department of Revenue (Foreign Tax and Tax Research Division) on 31 August 2015 released guidance notes with respect to implementation of the reporting requirements under rules 114F to 114H of the Income tax rules. Rules 114F to 114H implement the intergovernmental agreement (IGA) between India and… – Continue reading
As traders are set to stage a strike on Wednesday (today) following a call given by the All Pakistan Anjuman-e-Tajran against the withholding tax on banking transactions, Lahore Chamber of Commerce and Industry has supported the traders and decided to join the strike. Traders’ leaders warned that the protest could… – Continue reading
In a July 17, 2015 report released today, the Treasury Inspector General for Tax Administration (TIGTA) recommended that the IRS coordinate with the Social Security Administration to identify U.S. citizens and resident aliens working in a foreign country and resident aliens working in the United States who may have improperly… – Continue reading
The Department of Justice announced today that Valiant Bank AG has reached a resolution under the department’s Swiss Bank Program. “Offshore enforcement remains a top priority of the department, and banks seeking to avoid prosecution pursuant to the terms of the Swiss Bank Program continue to accept responsibility, provide a… – Continue reading
LONDON–Royal Bank of Scotland Group PLC (RBS.LN) has sold a portfolio of corporate-loan commitments related to its banking business in China for 498 million pounds ($755.1 million), as part of the bank’s strategy to focus mainly on U.K. and European customers. RBS said it has reached an agreement with China… – Continue reading
Policies are urgently needed for the legalization of the underground economy,” said Representative Oh Je-se of the New Politics Alliance for Democracy, who belongs to the Planning and Financial Committee of the National Assembly on Sept. 10. Rep. Oh added that Korea places sixth among OECD member countries in terms… – Continue reading
Recently the Curaçao Minister of Justice, Mr. Nelson Navarro, approved the so-called Investor’s Permit to accommodate bonafide high net worth persons and entrepreneurs who seek admission to Curaçao. The purpose of the Investor’s Permit is for the investor to provide real economic benefit to Curaçao by increasing employment opportunities and… – Continue reading
NEW DELHI: To ensure compliance with FATCA — the new US law to check offshore tax evasion — regulator Sebi today asked all market intermediaries to follow reporting requirements prescribed by Income Tax Department in this regard. Under Foreign Account Tax Compliance Act (FATCA), foreign financial institutions that fail to… – Continue reading
China appeared to expand efforts Thursday to bolster its currency in what traders said is an attempt to align its exchange rates at home and abroad. The yuan rose a record 1.2 percent in the offshore market amid speculation the People’s Bank of China was again acting to contain the… – Continue reading
Superstar-laden FC Barcelona might be among the top teams in the Spanish Liga BBVA this season but the team is making news – again – for a more undesirable reason: tax investigations. As Lionel Messi awaits trial on tax evasion charges, another Barcelona star may be joining him. Spanish news… – Continue reading
The EB-5 Visa program has been widely promoted as a legal basis for foreign business owners to gain conditional residency followed by permanent residency in the United States. The program is a great solution to the proposition “I want to live in America.” The decision to become a permanent resident… – Continue reading
Individuals and business wishing to establish a business in Canada need to familiarize themselves with the laws concerning forms of organization, FDI, competition, taxation, labor, privacy, the environment, and more. Canada has weathered the recent period of international uncertainty and volatility better than most other advanced industrialized nations. It is… – Continue reading
The US State Department has issued an interim final rule that would extend the increase in its processing fees payable for renouncing US citizenship to those who relinquish their US nationality through other methods. While the majority of individuals giving up their US citizenship do so by “making a formal… – Continue reading
(CNS Business): US taxpayers and Caymanian status holders Lee and Sheila Aronfeld are seeking a judicial review of a decision by the Cayman Islands Tax Information Authority (CITIA) to give their information to the IRS in the United States in connection with a criminal tax probe. Shareholders in three Cayman… – Continue reading
The Treasury Department has pushed American-based corporations to lobby against a tax provision prized by their foreign counterparts, according to people who have heard the pitch. One senior Treasury official in particular, Danielle Rolfes, urged domestic companies to more aggressively target an incentive for interest expensing during a March tax… – Continue reading
Not going to make this easy The amazing Yahoo! / Alibaba / SpinCo tax structure has suffered a blow: America’s Internal Revenue Service has refused to say whether or not it approves or disapproves of Yahoo!’s tax-avoidance chicanery. And that usually spells trouble. Back at the start of the year,… – Continue reading
