The Cayman Islands Department for International Tax Cooperation (DITC) has advised that it is in the final stages of preparing its FATCA data to be provided to the IRS. Information on US Reportable Account Notifications and 2014 Returns for US FATCA should now be completed and successfully submitted. It is… – Continue reading
The Internal Revenue Service loses billions of dollars annually because of offshore tax evasion. For years, a number of American taxpayers have evaded federal income taxes by channeling income into secret foreign or offshore bank accounts in some 70 countries. An award-winning investigative series by the Tribune-Review, $hadow Economy ,… – Continue reading
After years of commentary on FATCA from a distance, this writer got a little taste of it up close. It left a very unpleasant aftertaste and is taking a long time to go down. FATCA is bad for America. While knowing of, and criticising FATCA for years, it finally became… – Continue reading
Acting U.K. Overseas Territories Minister Grant Shapps said Thursday he is hopeful that Cayman and the Mother Country can reach some form of agreement on requirements to list the beneficial owners of companies registered here. “There’s more than one way to skin a cat,” Mr. Shapps said during a brief… – Continue reading
The IRS today publicly released two new “practice units”—i.e., training aids intended to describe for IRS agents leading practices for specific international and transfer pricing issues and transactions—providing overviews of foreign-to-foreign transactions under section 367(b) and the transfer pricing rules under section 482. The two new practice units (release date… – Continue reading
Introduction Transfer pricing methods and tested parties Troubling trend Tools for taxpayers Introduction In some recent transfer pricing audits the Internal Revenue Service (IRS) has ‘flipped the tested party’ after examining transactions between related US and foreign companies. Typically, this practice results in the attribution of a larger portion of… – Continue reading
The Deputy Premier and Minister of Finance Bob Richards today [Aug 28] commented on a report that Bermuda has been named to a new tax haven list drawn up by the District of Columbia in the US. While such changes would first have to be reviewed by the US Congress… – Continue reading
The Bank of Israel asked Bank Leumi Le-Israel Ltd. to set up an independent committee to examine management performance and bonuses after the lender agreed in December to pay a fine to U.S. authorities in a tax probe. Leumi, Israel’s second-largest lender, agreed the $400 million fine after a seven-year… – Continue reading
The two top Republican tax writers in Congress are warning the Treasury Department not to get ahead of Congress as it negotiates new international tax rules, questioning whether the administration is seeking to wield power it does not have. Senate Finance Committee Chairman Orrin Hatch (R-Utah) and House Ways and… – Continue reading
Regulator demands Bank Leumi investigate top management in wake of U.S. tax-evasion settlement. Bank Leumi should take back bonuses it paid three former senior executives after the lender was forced to pay a huge penalty to the United States for tax violations that occurred under their watch, Banks Supervisor David… – Continue reading
The Cayman Islands as one of the leading offshore financial centres have a great level of uncertainty in its future with all the recent developments around tax compliance. One looming uncertainty is the European Union’s (EU) Alternative Investment Fund Managers Directive (AIFMD) passport. The AIFMD is one of several measures… – Continue reading
Pakistan has decided to revise obsolete convention of double taxation and provision of fiscal evasion convention with the United State of America (USA) aimed at bringing the treaty at par with neighbouring countries, well informed sources told Business Recorder. Pakistan and US signed a convention on the avoidance of double… – Continue reading
Taipei, Aug. 27 (CNA) Taiwan and Japan have nearly completed negotiations on a bilateral agreement to avoid double taxation, a Taiwanese official said Thursday. The date of its signing is still being discussed, the official said. The negotiations on the agreement have almost been concluded, Chou Shyue-yow (周學佑), deputy director-general… – Continue reading
This Annual Conference Provides Global Tax Compliance Experts With Insight on Adopting an Internationally Accepted Standard of Tax Transparency and Compliance NEW YORK, NY–(Marketwired – August 25, 2015) – marcus evans, the world’s largest event management group, will host the 4th FATCA and Global Tax Compliance Forum on November 4-6,… – Continue reading
US fund managers and other investment advisers would have to take steps to combat money laundering and report suspicious transactions to authorities under a long-awaited US Treasury rule proposed on Tuesday, reports Reuters. If made final the proposal by Treasury’s Financial Crimes Enforcement Network (FinCEN) would close a long-standing hole… – Continue reading
NEW DELHI: Regulator SEBI today asked market entities to ensure compliance with changed income tax regulations, with India becoming a signatory to FATCA as well as a global pact to check tax evasion. The latest directive comes close on the heels of the government signing FATCA with the United States… – Continue reading
New de-offshorization and capital amnesty laws could have widespread effects In an attempt to encourage “economic patriotism,” Russia recently adopted two new laws: (1) The De-Offshorization Law, which makes a number of major changes in the existing systems of corporate and personal taxation in Russia, particularly as they pertain to… – Continue reading
Security fears; Global authorities to begin sharing sensitive data If you have a bank account somewhere overseas, that information will make its way back to the Canada Revenue Agency (CRA) in a couple of years. In 2018, international tax authorities will begin automatically sharing financial information under the terms of… – Continue reading
The new head of Barclays Plc’s Swiss unit is pushing private bankers in Geneva and Zurich to double client assets in four years as international competitors exit the world’s largest hub for offshore wealth. James Buchanan-Michaelson, who joined from Coutts International in June, aims to increase Swiss assets, including loans,… – Continue reading
This month’s feature examines proposals for new tax information reporting requirements for large multinational businesses as part of wider and ongoing changes to the international tax system – proposals which have been described by international tax experts as the most significant development in the field of transfer pricing since TP… – Continue reading
After the leak of two major secret documents from HSBC’s Swiss private banking arm that revealed names of roughly 2,000 Indian account holders, the global bank itself has done it now. For the first time ever, HSBC Singapore shared a new list of 1,200 individuals all across the globe of… – Continue reading
Foreign Account Tax Compliance Act (FATCA) was enacted in 2010 by the Government of the United States of America (USA) (Govt. of US) with a view to combat tax evasion by U.S. citizens and residents through the use of offshore accounts. FATCA requires financial institutions globally to share information about… – Continue reading
Aug. 21 — A federal court will hold a hearing Sept. 4 on whether to stop the U.S. from requiring banks in four countries to report information on U.S.-owned accounts under the Foreign Account Tax Compliance Act. As the Sept. 30 deadline for that reporting approaches, the U.S. District Court… – Continue reading
India will soon settle international tax disputes with close to 120 American companies as well as entities from Japan and other such countries, according to the nation’s Revenue Secretary Shaktikanta Das. Earlier this month, India announced a Framework Agreement under the mutual agreement procedure provision of the India-US tax treaty… – Continue reading
MINISTER OF INTERNATIONAL Business, Donville Inniss is optimistic that given Barbados’ and Italy’s continued efforts at strengthening bilateral relations, Barbados could soon be removed from Italy’s blacklist. He made this disclosure this morning during his brief remarks at the end of a signing of a Double Taxation Agreement (DTA) between… – Continue reading
The United States has implemented laws and policies, such as the soon-to-be-activated FATCA legislation, which have redounded to the expense of Caricom territories. The Caribbean regional integration project is often described and criticised almost entirely on the uneven benefits of trade to member countries. But, important as it is, there… – Continue reading
A new paper shows that British banks engaged in more offshore banking than any other financial centre. Researchers examining the resilience of the world’s financial centres after the global economic crisis conclude that the future stability of the UK is perhaps the most uncertain of all. The paper concludes that… – Continue reading
India opposed the proposal saying it impinges on the sovereign rights of developing countries in taxation New Delhi: An international proposal to make arbitration mandatory and binding under mutual agreement procedures (MAP) in tax treaties has been dropped after India strongly opposed it. Last year, the Organisation for Economic Co-operation… – Continue reading
The Treasury Department today updated its FATCA webpage to report the signing of an intergovernmental agreement (IGA) between the United States and St. Vincent and the Grenadines The IGA [PDF 278 KB] signed between the United States and St. Vincent and the Grenadines is dated as having been signed on… – Continue reading
Amit Ramnani, director of Ipanema Wealth, an independent financial consultancy firm, discusses the key issues facing U.S. expatriates. RIO DE JANEIRO, BRAZIL – Many United States citizens living overseas are unaware of the potential tax liabilities they could be facing in near future. To help out the Rio-based firm Ipanema… – Continue reading
American residents or nationals, citizens and green card holders – persons of interest – living in Jamaica are required to file US tax returns and must, by voluntary disclosure, fill out a form to disclose ‘foreign assets’. The filing of a Foreign Bank and Financial Accounts Report (FBAR) is an… – Continue reading
Aug. 19 — Tax authorities and practitioners around the world are awaiting a Canadian court’s ruling on the legality of Canada’s legislation to comply with the Foreign Account Tax Compliance Act. The Federal Court of Canada is due to issue by Sept. 30 a ruling on the validity of the… – Continue reading
South African companies who do direct and indirect business with US organisations, whether in South Africa, Africa, Europe or further afield, must comply with the United States Foreign Account Tax and Compliance Act (FATCA,) or risk being excluded from lucrative markets the world over, reports the Cape Business News. This… – Continue reading
The IRS on 12 August 2015 released a revenue procedure—Rev. Proc. 2015-41—providing guidance and updated procedures regarding advance pricing agreements (APAs). Rev. Proc. 2015-41 addresses the process of how to request and obtain an APA from the IRS’s Advance Pricing and Mutual Agreement (APMA) program and with respect to the… – Continue reading
On August 17th, 2015, Ruling No. 1,580/2015 was published, containing amendments to Ruling No. 1,571/2015 concerning the “e-Financeira”, which is the tax return to be filed for the purpose of informing financial transactions of interest to the Federal Revenue Office. The deadline for filing the e-Financeira, in relation to triggering… – Continue reading
The IRS on 12 August 2015 released Rev. Proc. 2015-40 with respect to requesting competent authority (CA) assistance, and it is generally effective for CA requests filed on or after 30 October 2015. Rev. Proc. 2015-40 updates and supersedes Rev. Proc. 2006-54. The IRS concurrently released Rev. Proc. 2015-41 as… – Continue reading
In late July 2015, Treasury provided an initial notification of “more favorable terms” concerning “certain alternative procedures” under the Model 1 IGA. This notification has been updated, 18 August 2015. Read the updated Treasury notification [PDF 70 KB]
FATCA was enacted into law by section 501(a) of the Hiring Incentives to Restore Employments (HIRE) Act 2010 as a revenue offset to help pay for the continuation of unemployment benefits for workers laid off during the 2008-2010 financial crisis. In July 2008, the U.S. Senate Permanent Subcommittee on Investigations… – Continue reading
THE START OF THE implementation of the Foreign Account Tax Compliant Act on July 1, 2014, combined with the Organisation for Economic Cooperation and Development’s (OECD) adoption of the common reporting standard, the support by the European Union of the automatic exchange of information (AEI), and the strong support by… – Continue reading
Due to a little-noticed provision in the new highway appropriations bill signed into law on July 31 – the Surface Transportation and Veterans Health Care Choice Improvement Act of 2015 – the deadline for filing an FBAR (Report of Financial Bank and Financial Accounts) has been moved up from June… – Continue reading
Subsidiaries in Luxembourg of food group had no staff and assets at year’s end of €1.3bn In its 2014 accounts Glanbia Luxfin, a subsidiary of Irish food group Glanbia, reported profits of $14.2 million and tax of $4,175, while Glanbia Luxinvest reported profits of €2.9 million and tax of €38,863…. – Continue reading
In May of 2012, and soon before Facebook’s IPO, Eduardo Saverin renounced his U.S. citizenship. Saverin was a co-founder of the social-networking site, and the consensus was that he gave up his citizenship to avoid U.S. taxes that would be levied after the offering. Saverin was widely denounced for his… – Continue reading
In its Resolution of March 25, 2015, on the Annual Tax Report (2014/2114(INI)), the European Parliament renewed its commitment to combating tax havens and tax avoidance. To be sure, most aspects of the resolution have been discussed before. Bundling these aspects into one comprehensive package, however, provides an intriguing snapshot… – Continue reading
Recently, there’s been a lot of news about the difficulties that 2 banks in Belize have been having after their correspondent banking relationship was severed by the Bank of America. The Prime Minister has commented that it’s a situation that is lamentable, but inevitable. Not surprisingly, Opposition Leader Francis Fonseca… – Continue reading
In DIT vs. M/s. Lufthansa Cargo India: TS- 299-HC-2015, the Delhi High Court held that payment made by assessee (an Indian company) to German company for carrying out overhaul repairs to aircrafts was fees for technical services (“FTS”) under section 9(1)(vii) of the Income Tax Act, 1961 (“the IT Act”)… – Continue reading
The private equity industry has long been known for its ability to take advantage of tax rules. But international changes are set to have an impact on their businesses. After a string of multinationals such as Apple, Google and Starbucks came under fire for paying minimal tax on their British… – Continue reading
There have not been too many applicants in the first month seeking to avail of the three-month long compliance window being offered by the government to come clean on unaccounted money in foreign shores, Justice (retd) MB Shah, who is heading the Special Investigation Team (SIT) on black money told… – Continue reading
The Tax Department of Cyprus has annouced that the FATCA reporting deadline has been moved to 31 August 2015 (from 14 August 2015). The FATCA Agreement between Cyprus and the United States was signed on 2 December 2014. FATCA seeks to obtain information on accounts held by U.S. taxpayers in… – Continue reading
FEEDBACK FROM MY LAST ARTICLE, From The Frying Pan, was encouraging. Our past Prime Minister Errol Barrow asked us, “What is your mirror image of yourselves”. A searching question. Our response to FATCA can throw some light on the matter. Encouraged by the USA, the UK, and soon others, are… – Continue reading
New data from Juniper Research has found that more than one in 10 adults worldwide will engage in some form of mobile or online gambling by 2019, with nearly half of adults in UK and Italian markets playing by that time. While to some extent the finding can be attributed… – Continue reading
