Category: USA

The New Money-Laundering Sting: Come to the U.S., Get Arrested

Lawyer Patrick Poulin says he helped clients set up offshore corporations in the Caribbean. And that’s what he was working on when he flew to Miami from the Turks and Caicos last year to meet with two Americans who wanted him to invest $2 million from a real estate deal…. – Continue reading

The Implications for International Tax Planning From the Looming Fiscal Crisis

The international financial sector faces a perilous future. Major challenges loom over an uncertain global economy, while a decidedly negative political climate poses an existential threat to the offshore financial community. With each passing year, thanks to demographic changes and poorly designed fiscal policies, politicians from high-tax nations will be… – Continue reading

IRS Gets Tax Data From India As Black Money Hunt Hits Americans Too

Indian Prime Minister Narendra Modi promised to bring home millions of dollars of illicit money stashed abroad. Indians call undisclosed money ‘black money,’ and how much there is remains unclear. But it isn’t just billions. It could be hundreds of billions to more than $1 trillion. It isn’t merely offshore… – Continue reading

Transfer pricing remains thorny issue for international trade

Multinational companies are facing far more expansive and complex audits by tax authorities fighting over the same pot of profits as budget deficits continue to increase, reports BD Live. An inevitable outcome of efforts globally to prevent tax bases from erosion is double taxation and increased disputes over adjusted assessments… – Continue reading

Antigua-Barbuda takes protest over tax haven listing to Capitol Hill

Antigua and Barbuda’s ambassador to the United States, Sir Ronald Sanders, has written to the mayor of the District of Columbia, Muriel Brower, and several members of the US congress calling for the removal of Antigua and Barbuda from a list of alleged “tax havens”, reports Caribbean News Now. Antigua… – Continue reading

Guernsey: What Guernsey Can Offer Chinese HNWIs’

In September 2014, the Hurun Research Institute published its annual listing of the richest people in China. It showed that IT tycoon Ma Yun had increased his personal fortune during the last year by 500% to $25 billion and in doing so, had climbed to first position on the list…. – Continue reading

Managing the transfer pricing of intangibles in the oil and gas sector

Intangible assets in the oil and gas industry have become incredibly valuable. Taxpayers need to understand how to manage compliance to mitigate their transfer pricing risks What do recent Western economic sanctions against Russia; the US’ growing energy independence; and ultra-deepwater oil and gas (O&G) discoveries off the coast of… – Continue reading

The Federation of Saint Kitts and Nevis and the United States of America Sign Agreement to Improve International Tax Compliance and to Implement FATCA

Saint Kitts and Nevis, BASSETERRE, (September 08, 2015) – The Governments of the Federation of Saint Kitts and Nevis and the United States of America (USA) on August 31, 2015, signed an Inter-Governmental Agreement (IGA) that will facilitate compliance by financial institutions in the Federation with the USA’s Foreign Account… – Continue reading

Implementation Of The Multilateral Competent Authority Agreement And Foreign Account Tax Compliance Act

SEBI on August 26, 2015 released a notification on the captioned head. It informed the intermediaries that India has joined The Multilateral Competent Authority Agreement (MCCA). Further on July 09, 2015, the Governments of India and United States of America signed an agreement to improve international tax compliance and to… – Continue reading

G20 finance communique: Long on reassurance, light on policy

G20 Finance Ministers and Central Bank Governors released their third communique of 2015 over the weekend. Their rhetoric is notable for the calm statement of positive reassurance on the macroeconomic environment, although the direct policy commitments appear to be light on. In the communique, Ministers and Governors recognised the significant… – Continue reading

Firms told to prepare for FATCA implementation

THE BUREAU of Internal Revenue (BIR) has advised Philippine financial institutions to start preparing for the implementation of a United States law requiring the reporting of bank accounts held by American taxpayers locally. In an advisory, the BIR said the start of reporting will not yet take place at the… – Continue reading

Israeli banks named in Australian tax evasion affair

Former Nudie Juice CEO Andrew Binetter allegedly sought the destruction of incriminating files at Bank Hapoalim. The names of Israeli banks Bank Hapoalim (TASE: POLI) and Israel Discount Bank (TASE: DSCT) have been mentioned in the Australian press as involved in alleged tax fraud in the millions of dollars by… – Continue reading

Colleen P. Waddell, Managing Director, Outlier Solutions to Speak at the Knowledge Group’s FATCA Event

New York, NY, September 05, 2015 –(PR.com)– The Knowledge Group/The Knowledge Congress Live Webcast Series, the leading producer of regulatory focused webcasts, has announced today that Colleen P. Waddell, Managing Director, Outlier Solutions will speak at the Knowledge Group’s webcast entitled: “Latest Regulatory Developments Under FATCA: Best Compliance Practices Uncovered… – Continue reading

Supreme Court finds taxpayer entitled to double tax treaty relief on share of Delaware LLC profits

On 1 July 2015, the Supreme Court (in Anson v HMRC4) held that a taxpayer was entitled to treaty relief on his share of a Delaware LLC’s profits. This casts doubt on HMRC’s published position (though each case must be judged on its own facts). The taxpayer, a UK “non-domiciled”… – Continue reading

Troy Kelley Hit With New Money Laundering, Tax Evasion Charges

Washington State Auditor Troy Kelley faces additional charges of money laundering and tax evasion. The U.S. Attorney’s office announced the new charges Thursday afternoon. The charges are contained in a superseding indictment against Kelley. The first-term Democrat now faces a total of 17 federal charges, including five new counts of… – Continue reading

Fortune 500 Corporations Are Likely Avoiding $600 Billion in Corporate Tax Using Offshore Tax Havens

As Labor Day weekend approaches, a tanned and rested Congress is poised to return to Washington to hash out corporate tax changes. Much of the debate over corporate tax reform in Washington sensibly focuses on how to encourage Fortune 500 corporations to repatriate and pay U.S. taxes on the $2.1… – Continue reading

Reports of overseas financial accounts rise in 2015

SEJONG, Sept. 3 (Yonhap) — More South Koreans reported their overseas financial accounts to authorities in 2015 than a year earlier as the government turns up the heat on individuals and companies to disclose hidden assets, the tax office said Thursday. The government has taken a firmer stance toward people… – Continue reading

Multinationals ‘exaggerated’ research activity to lower tax bills

Depeartmental review indicates contentious tax credit plays vital role in supporting jobs Several multinational firms have been found to be aggressively and improperly claiming tax credits for research and development to lower their corporation tax bills. A Government scheme gives firms up to 25 per cent of their expenditure on… – Continue reading

IRS Offshore Account Penalties Increase, Hunt Continues

The number of Swiss banks that have entered deferred prosecution agreements with the U.S. government keeps growing. The subject is tax evasion involving American account holders. Today, banks everywhere want to know if you are compliant with the IRS. Under FATCA, the entire world is lending the IRS a hand…. – Continue reading

Survey: Business leaders would pay more tax for greater clarity

Three-quarters of global business leaders would accept higher taxes in exchange for greater clarity on acceptable tax planning, the Grant Thornton International Business Report has found. The survey of 2,580 businesses in 35 countries noted a significant increase from the last time the question was asked – last year –… – Continue reading

LUXEMBOURG: FINAL VERSION OF FATCA GUIDANCE

The Luxembourg tax authorities released a final version of an administrative circular and an updated administrative circular to implement provisions under the FATCA (Foreign Account Tax Compliance Act) regime concerning the automatic exchange of information between Luxembourg and the United States. An intergovernmental agreement (IGA), that follows the Model 1… – Continue reading

Irish Gambler John McManus seeks $5.22 Million tax refund from IRS citing international treaty

One of Ireland’s richest persons, John P. McManus, seeks $5.2 million from the U.S. government after it was wrongfully withheld from his $17.4 million gambling winnings to cover taxes. In a complaint filed Monday in the U.S. Court of Federal Claims, McManus accuses the withholding agent of erroneously withholding the… – Continue reading

Pan-American Life Shares FATCA Best Practices With Local Insurance Association Members

WILLEMSTAD – Pan-American Life Insurance Company of Curaçao and Sint Maarten, a member of Pan-American Life Insurance Group (PALIG), facilitated a discussion yesterday with other members of the local insurance association about the practical implications of the U.S. Foreign Account Tax Compliance Act (FATCA) which was introduced in July 2014…. – Continue reading

IRS implements final changes to competent authority process

On August 12, 2015, the IRS issued Rev. Proc. 2015-40, which revises the procedures for obtaining competent authority (CA) assistance concerning issues arising under U.S. income tax treaties. This revenue procedure replaces current guidance, which was last updated almost 10 years ago, in Rev. Proc. 2006-54. Revisions to the former… – Continue reading

FATCA List – September 1, 2015

Almost 173,500 financial institutions from around the world have signed up to report customer information to the US Internal Revenue Service (IRS) under the Foreign Account Tax Compliance Act (FATCA). Around 2,230 registered with the FATCA portal in the past month, according to the IRS. At least one financial institution… – Continue reading

FATCA for Hedge Funds: Eight Common Pitfalls

For hedge funds in most jurisdictions, the first wave of registration and reporting deadlines surrounding the Foreign Account Tax Compliance Act (FATCA) is now in the rearview mirror, but a significant amount of work likely remains. Due to the staggered approach regarding the definition of a reportable investor in 2014… – Continue reading

Tax-dodger hunt neutralises Swiss bank secrecy, U.S. envoy says

Swiss banking secrecy is no longer viable as the U.S. Justice Department closes in on agreements with most of the institutions that may have helped Americans evade taxes, according to the top American diplomat in Switzerland. Negotiations with about one-third of Swiss lenders, known as Category 2 banks, to finalise… – Continue reading

Hatch, Ryan again seek answers to Base Erosion, Profit Shifting project concerns

U.S. Sen. Orrin Hatch (R-UT), chairman of the Senate Finance Committee, and U.S. Rep. Paul Ryan (R-WI), House Ways and Means Committee chairman, sent a letter on Tuesday to Treasury Secretary Jack Lew, outlining concerns regarding the country-by-country (CbC) reporting requirements in the works at the Treasury Department. The letter… – Continue reading

Canadians Owning Property in the U.S. Could Cash in on the Weak Loonie

For the past few years, Canadians have been taking advantage of our dollar being worth about the same as the U.S. dollar. From buying up real estate to cross-border shopping, being on par with the U.S. dollar has had its advantages. However, in the last few months, economic factors have… – Continue reading

Tax law seen as driving Americans to renounce citizenship

Stanley Amland threw it off. So did Ingrid Bracke. Rhoda May Derksen ditched hers, too. The names, picked at random for this article from the Federal Register, are among the 3,415 Americans who renounced their U.S. citizenship or relinquished their residency permits last year. As a national debate rages about… – Continue reading

$1.8 Billion IMF Ukraine Bailout Money Deposited in Ukraine Oligarch Kolomoyskyi’s Cyprus Offshore Bank Account

Funds Discovered in Kolomoyskyi’s Cyprus Kitty Investigative reporters have discovered that IMF bailout funds intended for Ukraine have mysteriously found their way to a Cyprus bank account controlled by notorious Ukrainian oligarch Ihor Kolomoyskyi. A huge chunk of the $17 billion in bailout money the IMF granted to Ukraine in… – Continue reading

Cross-Border M&A Is Hot, but There’s a Trap for Tax Planners: Picking the Wrong Way to Value Intangibles Can Irk Authorities

NEW YORK, NY–(Marketwired – Aug 31, 2015) – Cross-border mergers and acquisitions are at their hottest pace since before the financial crisis. In fact, M&A volume was $1.10 trillion in 2014, up from $775.3 billion in 2013 and the highest since 2008. And intangible assets like intellectual property and goodwill… – Continue reading

CORPORATE CLOSE-UP: LICENSING SUBSIDIARY THAT FELL PREY TO ADDBACK REQUIREMENT MUST ALSO FILE RETURN, NEW JERSEY RULES

Shifting of income between parent and subsidiary companies for the purpose of avoiding taxation has been a consistent concern for state departments of revenue. States have enacted a variety of rules to ensure that the entities involved file and pay taxes accurately. In Spring Licensing Group, Inc. v. New Jersey… – Continue reading

India: FATCA Reporting Deadline Extended

On 25 August 2015, the Indian Ministry of Finance released an order extending the Foreign Account Tax Compliance Act (FATCA) reporting filing deadline for Indian Financial Institutions to 10 September 2015 (from 31 August 2015). The FATCA Agreement between India and the United States was signed on 9 July 2015…. – Continue reading

Taxing multinationals: Patently problematic

Proposals for consistent global rules on company tax cause worries all round CLARITY or chaos? Supporters of the Base Erosion and Profit-Shifting (BEPS) project, being worked on by the OECD, argue that it will bind multinationals to a consistent set of global tax rules, providing them with less licence than… – Continue reading