Category: USA

What Indo-U.S. Bilateral APAs Entail For U.S. Investors

India’s decision to negotiate bilateral advance pricing agreements (APAs) with the U.S. is a welcome move. Prospectively, negotiations will increase certainty and uniformity in the application of India’s transfer pricing laws to related-party transactions carried out by U.S. multinational corporations (MNCs). In this article, we discuss some of the important… – Continue reading

Tax Policy Update

NUMBER OF THE WEEK: 3,415. The number of people who renounced their citizenship in 2014 according to IRS data. This is one of the five highest totals on record since the U.S. Congress passed the Foreign Account Tax Compliance Act in 2010. In the past five years, more than 10,000… – Continue reading

Le Perigord owner pleads guilty in tax case

NEW YORK â?? A founder of famed New York City restaurant Le Périgord faces a potential three-year prison sentence that could take him away from the paragon of traditional French cuisine after he pleaded guilty to hiding income in offshore bank accounts. Georges Briguet, 77, admitted during a Brooklyn federal… – Continue reading

Bernie Sanders attacks Business Roundtable, offshore tax havens

Sen. Bernard Sanders took aim at some of America’s biggest corporations Wednesday in his crusade to raise taxes on the wealthy, accusing the companies of “legalized tax fraud” for using off-shore banks to avoid U.S. taxes. Mr. Sanders, the ranking member on the Senate Banking Committee, released a report that… – Continue reading

Leaked Documents Reveal HSBC Bank’s Dirty Dealings with Tax Dodgers, Drug Traffickers and Arms Dealers

A team of journalists from 45 nations who investigated documents leaked by a former systems engineer working for banking giant HSBC’s Geneva, Switzerland branch, found HSBC managed secret bank accounts for criminals, drug traffickers, tax dodgers, politicians and celebrities. The documents, covering the period from 2005 to 2007 revealed, according… – Continue reading

Shire structure puts spotlight on tax

Drug firm has come out fighting after allegations it engaged in tax avoidance on an industrial scale Ireland’s largest drug company has come out fighting following allegations that, with its tax adviser PricewaterhouseCoopers, it has engaged in tax avoidance on an industrial scale – as alleged by the public accounts… – Continue reading

UK financial watchdog investigates HSBC over claims of aiding tax evasion

An FCA spokesman said the regulator faced difficulty in pursuing action against HSBC because the behaviour publicised so far involved its Swiss unit, HSBC Private Banking (Suisse) SA, which the spokesman said was beyond the FCA’s jurisdiction. Britain’s financial watchdog said it was investigating HSBC following reports it helped clients… – Continue reading

Multinationals yearn for better service

Firms need clear rules, certainty to remain in compliance with tax law, says expert Heightened scrutiny of foreign companies’ tax practices is a sign of China’s effort to modernize its taxation system to keep up with the fast-changing international business environment, but there is another dimension that concerns the foreign… – Continue reading

UAE banks to comply with Fatca before deadline

Financial information to be passed to IRS in September Abu Dhabi: The UAE’s financial institutes are set to comply with the US’s Foreign Account Tax Compliance Act (Fatca) before the deadline at the end of the second quarter of this year, officials confirmed on Sunday. The information will then be… – Continue reading

The major Irish firms in tax haven territory

Some of the biggest listed Irish firms have subsidiaries in so-called ‘tax havens’, like the British Virgin Islands, Jersey or Luxembourg. They say it’s not to reduce their tax bills – so why are they there? The subsidiaries are registered in well-known offshore tax havens, such as the British Virgin… – Continue reading

Don’t believe the hype about expat Americans ditching their passports

In the last several years, a “record” number of Americans abroad have been giving up their passports: That’s supposedly due to the demands of the Foreign Account Tax Compliance Act, known as FATCA, a US law enacted in 2010 to fight tax evasion by forcing foreign banks to share information… – Continue reading

India to boost trade ties with US, commits to adopt FATCA soon

NEW DELHI: Committing to boost trade ties, India and the US today resolved to enhance cooperation, remove obstacles to investment flows and work towards early adoption of FATCA to facilitate automatic flow of tax information. “We are committed to share our experiences in tackling offshore tax evasion and avoidance. We… – Continue reading

Committed to Tackling Offshore Tax Issues

NEW DELHI: India and the US on Thursday committed to take the renewed India-US partnership forward through “shared effort and progress for all” when Finance Minister Arun Jaitley and Jacob J. Lew, US Secretary of the Treasury, met in the Capital for the Fifth Annual India-US Economic and Financial Partnership…. – Continue reading

Ackman Says Tax Inversion Rules Could Lead to U.S. Drugmakers Selling to Overseas Buyers

(Bloomberg) — The backlash against acquisitions meant to skirt U.S. tax laws could spur more midsize U.S. drugmakers to sell to overseas buyers, Bill Ackman, the billionaire activist hedge fund manager, said Thursday. Takeover activity in 2014 was highlighted by U.S. companies — including Medtronic Inc. and Pfizer Inc. —… – Continue reading

US Accountants Call For DTA Approvals

In a recent letter to the Committee on Foreign Relations, the American Institute of Certified Public Accountants (AICPA) requested that the US Senate urgently approve all pending bilateral double taxation agreements (DTAs) and protocols. The AICPA pointed out that the full Senate has not approved any DTA or protocol since… – Continue reading

HSBC files: Swiss bank hid money for suspected criminals

Documents detail customers who faced allegations including drug-running, corruption, doping and money laundering This article is the subject of a legal complaint made on behalf of Anura Perera. HSBC’s Swiss bank concealed large sums of money for people facing allegations of serious wrongdoing, including drug-running, corruption and money laundering, leaked… – Continue reading

HSBC admits its Swiss private bank may have been involved in tax avoidance

HSBC is under fire, after a large cache of leaked bank files revealed that it helped clients evade taxes and conceal millions of dollars. The files, which cover the period 2005-07, amount to the biggest banking leak in history, shedding light on some 30,000 accounts holding almost $120bn. HSBC was… – Continue reading

British Revenue Chief Is Faulted on HSBC’s Efforts to Aid Tax Evasion

LONDON – The chief executive of Britain’s tax agency was questioned by politicians over leaked documents that describe how HSBC’s Swiss private banking arm helped clients, including politicians, rock stars and dealers of illicit diamonds, hide billions of dollars before 2007. Members of Parliament criticized Lin Homer, the chief of… – Continue reading

HSBC Charged with Being “Tax Evasion Service” for Int’l Criminal Ring

According to the analysis of clandestine files belonging to British banking giant HSBC, it appears that the Swiss banking branch of the conglomerate played a pivotal role in assisting affluent depositors evade taxes on their mega million. A report released on Sunday, Feb 8, by a cadre of  reporters representing… – Continue reading

Venezuela Outdoes All LatAm Nations in HSBC Tax-Evasion Scheme

Latin-American politicians Horacio Cartes (president of Paraguay), Álvaro Noboa (former president of Ecuador), and Alejandro Andrade (Venezuela’s ex-national treasurer) have one thing in common: they all possessed, until at least 2007, secret accounts with HSBC’s private Swiss bank. This according to the Swissleaks report published on Sunday, February 8, which… – Continue reading

Ministers stash $270m in foreign bank

WASHINGTON DC — An international banking giant, HSBC, made huge profits by allegedly engaging in shady deals of over $270 million with some Zimbabwean citizens seven years ago, in the process, disadvantaging the poor southern African nation of the much-needed foreign currency, documents in Studio 7’s possession have revealed. BY… – Continue reading

Leaked Files Link Abdulsalami Abubakar, Chris Garba to $182m Halliburton Bribery Scandal

Davidson Iriekpen with agency report New records obtained by the Paris-based Le Monde newspaper and the International Consortium of Investigative Journalists (ICIJ) have unveiled more details on the $182 million Halliburton bribery scandal in Nigeria that indicted several top government official, in the country who received the bribes, but for… – Continue reading

BDA boss Webber responds to Miliband threat

Bermuda’s well-documented financial services regulation, international partnership treaties, and lack of bank secrecy legislation ought to be recognised by the UK Labour Party, the Bermuda Business Development Agency (BDA) said today. The BDA echoed the Bermuda Government’s weekend response to UK Opposition Leader Ed Miliband following a warning letter issued… – Continue reading

HSBC Sends Letters to US Taxpayers – re: FBAR (Report of Foreign Bank and Financial Accounts)

There are millions of Americans with unreported offshore bank and financial accounts. Under the new FATCA legislation, foreign financial institutions will soon be required to report account holders with ties to the United States. (FATCA is short for the Foreign Account Tax Compliance Act, a 2010 Obama initiative designed to… – Continue reading

The rise of pass-throughs

Call it the pass-through revolution. The U.S. has been losing about 60,000 conventional corporations a year, according to the Tax Foundation. It’s lost 1 million since 1986, the foundation said. Meanwhile, the number of pass-through entities has exploded. “More than 60 percent of U.S. business profits are now taxed under… – Continue reading

Australian banks defend their corporate tax affairs after Swiss HSBC revelations

Australia’s largest banking and finance institutions have defended their corporate tax affairs and have rejected claims the tax system is “fundamentally flawed”, in submissions to a Senate inquiry. On Monday an international investigation exposed how the Swiss arm of the HSBC bank helped wealthy clients dodge taxes around the world…. – Continue reading

Clinton foundation received up to $81m from clients of controversial HSBC bank

The charitable foundation run by Hillary Clinton and her family has received as much as $81m from wealthy international donors who were clients of HSBC’s controversial Swiss bank. Leaked files from HSBC’s Swiss banking division reveal the identities of seven donors to the Bill, Hillary and Chelsea Clinton Foundation with… – Continue reading

U.S. companies may not be fleeing due to high tax rate, Reuters analysis shows

(Reuters) – When a series of big U.S. companies last year moved to reincorporate abroad in inversion deals, some Republican lawmakers and tax policy critics blamed the high U.S. corporate tax rate. Lowering it, they said, would keep companies from fleeing the country. But a Reuters analysis of the taxes… – Continue reading

Bulgaria approves USA’s FATCA agreement

Bulgaria’s cabinet has approved an agreement with the United States on the US’s Foreign Account Tax Compliance Act (FATCA), which targets tax non-compliance by US taxpayers with foreign accounts, Sofia Globe wrote. The cabinet approved the agreement, reached in December 2014, and said that it would ask the National Assembly… – Continue reading

“FATCA Finally Takes Effect, Subject to Transition Rules”

After several years of delays, the Foreign Account Tax Compliance Act (FATCA) finally took effect on July 1, 2014. Congress enacted FATCA as part of the Hiring Incentives to Restore Employment Act in 2010 to stop U.S. taxpayers from evading U.S. taxes through undisclosed offshore accounts and investments. FATCA requires… – Continue reading

Tax row engulfs Rexam predator Ball Corporation as a third of the US giant’s subsidiaries are based in tax havens

The US giant trying to take over Britain’s biggest drinks can maker in a £4.3billion deal is a serial user of tax havens. Ball Corporation is in talks to buy FTSE 250-listed Rexam that would create an industry goliath. The deal could be finalised as early as this week, and… – Continue reading

AICPA Urges Senate to Act on International Income Tax Treaties

The nation’s largest organization of accounting and tax professionals is urging the Senate to approve income tax treaties between the U.S. and various countries. In a February 3 letter to Senator Bob Corker (R-Tenn.), chairman of the Senate Committee on Foreign Relations and Senator Robert Menendez (D-N.J.), the committee’s ranking… – Continue reading

Guest Post: Transfer Prices Are an Evidentiary Gold Mine for Patent Defendants

Guest Post by Andrew Blair-Stanek, Assistant Professor of Law at University of Maryland Carey School of Law Patent owners routinely tell the IRS, under penalties of perjury, that their patents have little value.  Litigators representing defendants should take advantage of these remarkable admissions. IP has become the world’s leading tax… – Continue reading