Category: USA

FATCA documentation for disregarded entities

Introduction The Foreign Account Tax Compliance Act (FATCA) requires entity account holders to document their status for US withholding tax purposes (Chapter 3 status) and their status for FATCA due diligence purposes (Chapter 4 status). In the case of a non-US entity account holder that has made an entity classification… – Continue reading

Disgraced Fifa Boss Stashed $1m At Cibc Bahamas

A disgraced senior FIFA official has agreed to forfeit 50 per cent of the $1 million he had stashed away in a secret CIBC FirstCaribbean International Bank (Bahamas) account, court documents have revealed. The plea agreement between the US federal authorities and Charles (Chuck) Blazer, which was unsealed late on… – Continue reading

EU releases tax haven blacklist

The European Union has published its first list of international tax havens as part of a crackdown on multinational companies trying to avoid paying tax in the 28-nation bloc. The list of 30 territories includes Hong Kong and Brunei in Asia, Monaco, Andorra and Guernsey in Europe, and a series… – Continue reading

Will not use coercive methods to recover MAT from FIIs: CBDT chairperson Anita Kapur

CBDT chairperson Anita Kapur said that the income tax department will ensure that chronic evaders are not able to get away without facing court cases. The Central Board of Direct Taxes (CBDT) on Tuesday said that the tax department will not resort to coercive methods to recover the minimum alternate… – Continue reading

Julius Baer Starts Probe Amid FIFA Corruption Allegations

Julius Baer of Switzerland became the latest bank to start an internal probe of money transfers linked to an investigation of FIFA, world soccer’s ruling body. Julius Baer joined banks including the U.K.’s Standard Chartered Plc in reporting that it began an inquiry. The Zurich-based firm was named as one… – Continue reading

Wal-Mart Has $76 Billion in Overseas Tax Havens, Report Says

Wal-Mart Stores Inc. owns more than $76 billion of assets through a web of units in offshore tax havens around the world, though you wouldn’t know it from reading the giant retailer’s annual report. A new study has found Wal-Mart has at least 78 offshore subsidiaries and branches, more than… – Continue reading

US companies regain their appetite for tax inversion deals

US companies have regained their appetite for controversial foreign takeovers that allow them to move overseas and escape US taxes, in spite of a White House crackdown to restrict so-called tax inversions last year, reports the Financial Times. According to several senior corporate advisers in the US and Europe, demand… – Continue reading

United States: KMT’s David Klein Considers Pennsylvania’s New Online Gambling Bill

Odds improve for online gaming Regulate or delegate — that’s the question facing Pennsylvania legislators as bills to legalize online gambling gain traction. A new bill in the state Senate — SB 900, allows the state, among other things, to license operators to conduct Internet gaming. It’s a practice many… – Continue reading

Can The United States Kill BEPS?

The United States is through trying to needle the OECD’s base erosion and profit-shifting project with pinpricks. Last week, Robert Stack, U.S. Treasury deputy assistant secretary (international tax affairs), abandoned the subtle digs Treasury had been using to attack BEPS and flat-out said the United States is extremely disappointed in… – Continue reading

HSBC, JPMorgan may move parts of businesses to Luxembourg – The Times

HSBC Holdings Plc and JPMorgan Chase & Co are in talks to relocate parts of their businesses to Luxembourg from the UK as they weigh the possibility of a British exit from the European Union, the Times reported. JPMorgan is close to setting up a bank based in Luxembourg to… – Continue reading

Financial Industry Fears Fatca Start With No Legislation

The Bahamian financial industry is concerned it will have to start reporting information for the US Foreign Account Tax Compliance Act (FATCA) without the necessary legislation being in place, Tribune Business can reveal. Lawrence Lewis, a Deloitte & Touche (Bahamas) partner and accountant, confirmed to Tribune Business that there was… – Continue reading

Fund administration – opportunities for offshore and alternative investment funds

Following the implementation of the EU Alternative Investment Fund Managers (AIFM) Directive (2011/61/EC) and associated legislation, Cyprus now lays claim to being a growth jurisdiction within the European Union for the establishment and servicing of boutique and low cost alternative investment funds based locally or offshore. The choice of fund… – Continue reading

‘Zero tolerance’ for tax evasion, Ottawa claims

Report on ‘poor’ neighborhoods full of mansions sparks calls for tax enforcement, residency documentation OTTAWA — The Canadian government takes a “zero tolerance” stand on tax evaders and is currently conducting audits on property owners in B.C., according to the Canada Revenue Agency. But Vancouver immigration lawyer Samuel Hyman said… – Continue reading

Birth of a New Era in Private Wealth

As the financial world continues its march towards a more transparent and open environment, regulations governing private wealth are under scrutiny. The traditional is changing for good while new players emerge. Once was a time, not too long ago, the words “Swiss bank” conjured up evocative imagery: secret deals; bank… – Continue reading

Divisions in US over OECD corporate tax proposals

Senior Republicans voice concerns over Obama administration’s response to plan Political divisions are opening up in Washington over the US response to the overhaul of international tax rules by the global powers, an initiative with big implications for Ireland’s corporate tax regime. The Republican leaders of the two tax-writing committees… – Continue reading

Bank of Mingo charged with failing to develop, maintain anti-money laundering program

U.S. Attorney Booth Goodwin announced Monday the Bank of Mingo has been charged with failing to develop, implement and maintain an effective anti-money laundering program. According to a news release, the bank failed to implement internal controls that would have resulted in the bank obtaining “know-your-customer” information, failed to prevent… – Continue reading

Treaties likely on exchange of tax information

ISLAMABAD: Several amendments have been proposed to the tax laws in the Finance Bill 2015-16 to empower the federal government to enter into agreements for exchange of tax-related information with provinces and other countries. The new sections proposed to be inserted in the Finance Bill will empower Islamabad to enter… – Continue reading

Candidates’ plans to repatriate profits only encourage corporate tax avoiders

The last time the US tried repatriation – in 2004 – companies took the tax breaks and fired American workers. Better to close loopholes and invest in infrastructure If you had a spoiled 10-year-old at home who you found rifling through your wallet, what would you do? Would you spank… – Continue reading

Malta:FATCA Reporting Deadline Extended Again

The Maltese Commissioner for Revenue has announced a further extension in relation to the deadline on reporting for FATCA purposes from 15 June 2015 to 3 July 2015. The FATCA reporting deadline in Malta is normally 30 April. The Commissioner has confirmed that this exception will apply for reporting in… – Continue reading

Financial institutions must prepare for ‘FATCA on steroids’

Financial institutions around the world must ‘get their act together’ for the introduction of the OECD’s Common Reporting Standard (CRS) in seven months, Linedata has warned. Justin Hayes, product manager at the international software provider, dubbed the automatic exchange agreement between an initial 58 countries “FATCA on steroids’ and an… – Continue reading

FactCheck: Christie’s tax dodge

He has distorted the facts about the nation’s current tax system. Chris Christie repeatedly has said that U.S. corporations are taxed twice on income earned abroad, claiming in one speech that IRS officials “don’t recognize the tax you paid to a foreign country.” That’s false. It’s true that the U.S…. – Continue reading

Governments risk falling short of FATCA demands

Governments around the world could find themselves under-resourced when the Foreign Account Tax Compliance Act deadline for collecting information on US clients arrives in September, one expert has said. Ellen Zimiles, managing director, head of global investigations at US firm Navigant, said governments will be handed an “unprecedented” amount of… – Continue reading

IRS Reminds of June FBAR, FATCA Deadlines

The Internal Revenue Service Wednesday reminded taxpayers with offshore accounts of two important June deadlines related to Foreign Bank and Financial Accounts filings and the Foreign Account Tax Compliance Act. All taxpayers with a FBAR filing requirement must report their foreign assets by June 30, with those taxpayers living abroad… – Continue reading

Bermuda: Minister Richards examines global tax threats

Speaking at the Insurance Day 2015 Summit on 10 June 2015, Minister of Finance Bob Richards told attendees that “the more we drive home that the insurance sector in Bermuda is not a stereotypical tax haven gimmick to key onshore decision makers the less the threat from IRS and other… – Continue reading

Vatican agrees to share tax info with the US in new step to improve bank’s transparency

VATICAN CITY – The Vatican has agreed to share tax information with the United States in its latest move to improve the reputation of its scandal-marred bank and crack down on tax cheats. Vatican and U.S. officials signed an agreement Wednesday in which the Holy See committed to comply with… – Continue reading

Update: key ruling affecting Maryland taxpayers with out-of-state income – tax refund opportunity now available

Maryland residents who pay income tax to other states may be entitled to a refund of local income taxes paid in prior tax years. The U.S. Supreme Court in Comptroller of the Treasury of Maryland v. Wynne et ux. recently affirmed a Maryland Court of Appeals ruling that the state’s… – Continue reading

Israel: Renewing Your US Passport? The IRS Will Know About It

Individuals who renew their US passport need to take into consideration that their Social Security Number (SSN) and country of residency will be forwarded to the IRS. Since July 2014, the passport renewal instructions forms have dedicated a specific paragraph detailing this new procedure: “Section 6039E of the Internal Revenue… – Continue reading

Swiss government wants banks’ extra care to avoid untaxed money

Switzerland’s government wants banks to toughen up checks to avoid accepting untaxed assets, possibly including a refusal to do business with a client who can’t show the money has been regularized, reports Bloomberg. For clients from countries that aren’t covered by automatic exchange of information agreements, banks will need to… – Continue reading

United States: International Tax Reform Heats Up

Top congressional lawmakers have ramped up discussions over international tax reform as the outlook for business and comprehensive reform has dimmed. The president has flatly rejected individual rate cuts, and efforts toward business-only reform have flagged as the pass-through community has rejected most proposals that would leave it out of… – Continue reading

Tax consequences of foreign companies rendering services in South Africa

Where a foreign company renders professional services to a South African company, it is important that the foreign entity considers whether, as a result of rendering such services, the foreign company will create a permanent establishment in South Africa. The reason why this becomes important is that where a foreign… – Continue reading

Investment Funds Update – Europe: Legal and regulatory updates for the funds industry from the key asset management centres and primary European fund domiciles: UK

MiFID II – FCA Issues Discussion Paper on MiFID II Implementation Measures The FCA issued a discussion paper (DP15/3) on 26 March 2015, asking firms for their views on a range of MiFID II implementation measures, including on: The revised inducements standards. Receipt of commissions and other benefits by discretionary… – Continue reading