Foreign Account Tax Compliance Act (FATCA) has been in force for a month and still more countries are joining the tax network. So far, 101 countries and financial jurisdictions have either signed or agreed to join FATCA. FATCA is aimed at identifying US taxpayers with offshore bank accounts and investments. Overseas… – Continue reading
This article, by Chris Horlacher, was originally published by The Dollar Vigilante. Many Canadians, referred to as snowbirds, spend three to six months each year in the United States. If they think to consult a tax adviser at all, they’re usually told that as long as they spend less than… – Continue reading
Microsoft’s stash of cash stored overseas, not subject to US taxes, is growing. In its latest regulatory filing, the software giant said it has now stockpiled $92.9 billion offshore and that this money could have cost the company $29.6 billion in taxes, but didn’t. That compares to $76.4 billion from… – Continue reading
Potential inversion deal highlights dropping corporate taxes in Canada, now the lowest among 10 countries, with the U.S. in 5th place. Fast-food giant Burger King faced anger from both Washington and average Americans Monday, a day after it announced that it was in talks to buy Tim Hortons and relocate… – Continue reading
NEW YORK — There’s more than one way for a U.S. company to avoid taxes by claiming a foreign address. Consider the business founded in 1916 as General Plate Co., a maker of sensors and controls for everything from Fords and Frigidaires to the spaceship that first carried Americans to… – Continue reading
Several recent high profile deals have directed media and public attention to the topic of “tax inversion,” whereby a company moves its headquarters overseas (usually in an M&A deal) in order to reduce its tax burden. According to the Wall Street Journal (citing Thomson Reuters) there have been 22 such… – Continue reading
Burger King is moving to Canada, by way of Omaha. Warren Buffett is finally getting into the burger business. Buffett’s Berkshire Hathaway brk.a -0.00% has agreed to help finance Burger King’s BKW -4.32% purchase of Canadian coffee-and-doughnut chain Tim Hortons THI 8.47% . The deal, first reported by The Wall… – Continue reading
CFOs of multinationals need to prepare by assessing how much their companies engage in profit shifting to cut their taxes. Do you have responsibility, whether direct or dotted line, for the tax function in your company? Does your company have, or plan to have, operations outside the United States? If… – Continue reading
Microsoft is the most recent member of the get-your-money-out-of-the-country club. The technology giant is facing scrutiny amid findings that it is housing nearly $92 billion offshore in an effort to avoid as much as $29 billion in US taxes. Annual filings with the Securities and Exchange Commission exposed that the… – Continue reading
THE National Tax Policy (NTP) has identified double taxation as one of the major hindrances to the growth of the Nigerian economy. Double taxation has become an issue paramount to investors and top executives of multinationals as income is generally taxable both in source and residence countries. In order to… – Continue reading
NEW DELHI: G-20, a group of developed and developing nations, is likely to press for adoption of “rapid timelines” by different countries for automatic sharing of information with a view to curb tax evasion. The issue of automatic sharing of tax information would figure prominently during the meeting of G-20… – Continue reading
On June 25, 2014, the IRS finally issued the instructions to the new version of Form W-8BEN-E, an 8-page withholding certificate to be completed by foreign entities. Previously, foreign individuals and most foreign entities would provide a one-page Form W-8BEN to withholding agents to certify the foreign entity’s entity classification… – Continue reading
The Foreign Account Tax Compliance Act (FATCA) is an important development in U.S. efforts to improve tax compliance involving foreign financial assets and offshore accounts.Depending on the amount of the aggregate value of their assets, US individuals are required to file Form 8938 – Statement of Specified Foreign Financial Assets… – Continue reading
Ireland can adopt ‘wait-and-see’ approach on tax breaks, says Department of Finance Ireland supports the EU review of all patent box regimes – under which certain member states offer tax breaks for intellectual property – and has decided to take a “wait-and-see approach” on the issue until guidance is provided… – Continue reading
Microsoft Corp. is currently sitting on almost $29.6 billion it would owe in U.S. taxes if it repatriated the $92.9 billion of earnings it is keeping offshore, according to disclosures in the company’s most recent annual filings with the Securities and Exchange Commission. The amount of money that Microsoft is… – Continue reading
LITTLE ROCK, AR –Former Little Rock attorney David Patrick Henry, Sr., 71, has been sentenced to five years in prison followed by two years of supervised released, according U.S. Attorney Christopher Thyer. Henry, Sr. is also ordered to pay over a million dollars. On March 21, a federal jury found… – Continue reading
MONTREAL • Eugene Melnyk, the billionaire owner of the Ottawa Senators and founder of drug maker Biovail Corp., is waging war against the company that now controls his one-time business. Mr. Melnyk alleges that Valeant Pharmaceuticals International Inc. is masquerading as a Canadian company to make use of this country’s… – Continue reading
The Delhi High Court upholds the non-taxability of gains from sale of shares of overseas entities by the Copal Group to the Moody’s Group. Interpretation of the indirect transfer tax provisions in a restrictive manner. 50% threshold for substantiality based on guidance by OECD/ UN material and Shome Committee Report… – Continue reading
Various reporters, editorialists and politicians are clamoring for Bruce Rauner, the Republican candidate for governor of Illinois, to release more of his tax returns — specifically, the detailed schedules that accompany the “top sheets” that he already has released. They probably will be disappointed, even if Mr. Rauner complies with… – Continue reading
Using the code name Hot Lips with Swiss banking representatives, an 83-year-old Delray Beach man conspired to hide more than $1 million from the Internal Revenue Service in foreign bank accounts. Bernard Kramer pleaded guilty Tuesday in New York federal court before U.S. District Judge Alvin K. Hellerstein, admitting he… – Continue reading
The Foreign Account Tax Compliance Act (FATCA) was enacted in 2010 by the US to target non-compliance by US taxpayers using foreign accounts. FATCA essentially requires foreign financial institutions to report information about financial accounts held by US taxpayers, or by foreign entities in which such taxpayers hold a substantial… – Continue reading
Manila (AFP) – Philippine world boxing champion Manny Pacquiao has won a Supreme Court reprieve in his battle to avoid paying tens of millions of dollars in extra taxes, authorities said Thursday. Pacquiao will not have to post a cash bond of 3.3 billion pesos ($75.2 million) and the government… – Continue reading
Aug 21 (Reuters) – Leumi, Israel’s second-largest bank, reported a smaller-than-expected decline in quarterly net profit, as the lender’s bottom line was hit by a provision to settle a U.S. tax probe. Leumi said on Thursday it earned 290 million shekels ($82 million) in the second quarter, compared with 474… – Continue reading
Medtronic Inc’s Chief Executive Omar Ishrak has insisted that the company’s USD42.9bn deal to acquire Dublin-based Covidien Plc, and, thereby, move its tax residence from the United States to Ireland in a “corporate inversion,” is based on business logic and not corporate tax reduction. Medtronic is among a number of… – Continue reading
Serbia’s Information Commissioner has warned that banks must have the full consent of customers before information is passed to US tax authorities under the terms of FATCA, and that it would be illegal for customers to be declined services if they refuse to give consent. The comments were made by… – Continue reading
Never heard of FATCA? You will. FATCA—the Foreign Account Tax Compliance Act—is America’s global tax law. It was quietly enacted in 2010, and after a four-year ramp up, it’s finally in effect. What is most amazing is not its impact on Americans—although that is considerable—but its impact on the world…. – Continue reading
US has long tried to block tax inversions – with success – See more at: http://www.independent.ie/business/world/us-has-long-tried-to-block-tax-inversions-with-success-30520958.html#sthash.cT9EIpv4.dpuf US authorities have grappled for more than 30 years with corporate deals known as inversions by which American companies shift their tax domiciles abroad to avoid US taxes. Fifty-two substantial deals like this have occurred… – Continue reading
U.S.-China Agreement Requires Financial Institutions to Increase Transparency and Enhance Reporting Wolters Kluwer Financial Services recommends that financial institutions in China should take steps toward enhancing their data and reporting capabilities on financial accounts held by U.S. taxpayers in China as part of the Foreign Account Tax Compliance Act. This recommendation… – Continue reading
(Reuters) – The U.S. government has grappled for more than 30 years with corporate deals known as inversions in which U.S. companies shift their tax domiciles abroad to avoid U.S. taxes. Fifty-two substantial deals like this have occurred since 1983, about half of them since the 2008-2009 credit crisis, according… – Continue reading
Two women have challenged the constitutionality of a Canada-U.S. agreement to share the tax information of U.S. citizens resident in Canada, with the IRS. But an expert in U.S. tax law says that these individuals, most of whom consider themselves Canadians, could be worse off if the lawsuit succeeds. “If… – Continue reading
Law360, Washington (August 18, 2014, 5:20 PM ET) — Medical device manufacturer Zimmer Holdings Inc. is protesting a $79 million Internal Revenue Service assessment arising from transfer pricing adjustments that the agency made on transactions, including licensing agreements, between itself and a Dutch subsidiary, according to court records made public… – Continue reading
Minister of Finance Bob Richards confirmed this week that under the Bermuda-UK FATCA Intergovernmental Agreement [IGA] model 2, Bermuda and the UK have agreed the inclusion of a Limited Capacity Exempt Beneficial Owner Category in Annex II of the IGA. The effect of this amendment will mean that there will… – Continue reading
For years, chief executives have complained bitterly about the United States corporate tax code, arguing that it is too complicated and that rates are too high. The issue has reached a near boiling point this summer as many large American companies have sought to buy smaller foreign rivals so they… – Continue reading
To some, US companies switching their tax residency to gain a tax advantage are economic “traitors.” To others, they are victims of a United States tax code that effectively punishes them for investing at home and encourages them to look for opportunities overseas. In this Tax-News Topical Focus, we try… – Continue reading
SRINGFIELD — Republican Bruce Rauner not only has personal investments in the Cayman Islands, but he presided over his former private equity firm as it set up other investment vehicles in the Caribbean tax haven known for its secrecy. The Chicago Sun-Times verified through the Cayman Islands’ government-run online business… – Continue reading
USA Today published a story last week entitled “20 big profitable companies paid no taxes.” Using data provided by S&P Capital IQ, the newspaper identified 20 firms that paid no federal taxes in the second quarter of this year despite reporting $4.4 billion in second quarter profits. Collectively, these 20… – Continue reading
With new laws in place, recovery from Swiss banks can be little easier provided the government shows sincerity in taking action against tax dodgers Finance Minister Senator Ishaq Dar in recent days has expressed the government’s firm conviction to bring back untaxed money of “US$ 200 billion” stashed in… – Continue reading
The sharemarket has settled into a consolidation phase at between 5400 and 5600 index points, mirroring changes in overseas markets. While analysts are confident the current reporting period will not produce unexpected changes to their forecasts, international political instability makes further upward movement in prices unlikely. Compared with overseas markets… – Continue reading
Urges Illinois-Based Hospira Not To Turn Its Back On America To Dodge Taxes Senator warns of another potential corporate inversion at U.S. taxpayer expense [CHICAGO, IL] – In a letter to the CEO of Lake Forest, Illinois-based Hospira, U.S. Senator Dick Durbin (D-IL) urged the company not to turn its… – Continue reading
Barack Obama, presiding over an unusually dismal post-recession economy, might make matters worse with a distracting crusade against the minor and sensible business practice called “inversion.” Obama gave a 2013 speech regretting that Maytag workers in Illinois lost their jobs when the plant moved to Mexico but rejoicing that more… – Continue reading
Letter-writer Hank Brennan correctly states that tax inversion is a tax avoidance, rather than evasion (“Inversion not a crime,” Reader Forum, Aug. 11). However, like boards of directors off-shoring American corporations as they earlier off-shored American jobs, he is looking at only one stakeholder: stockholders. There are three other stakeholders… – Continue reading
Nobody likes paying taxes, but just how far would you go to avoid them? For some companies who market themselves as homegrown American brands, it’s better to move cash overseas than to pay federal taxes on billions of dollars of earnings. According to the New York Times, U.S. law states… – Continue reading
While the IRS is trying to find Lois Lerner’s emails and revising its rules governing inversions — the practice of multinational corporations (MNCs) moving their headquarters to avoid paying taxes — it has also endorsed a maneuver that will cut taxes for major telecom companies by billions of dollars. In… – Continue reading
HARRISBURG, Pa. — Walgreen’s drew protests this summer as the nation’s largest drug store chain mulled whether to move its headquarters overseas to avoid paying billions in corporate taxes. The practice is known as inversion and has been drawing more attention as companies consider reorganizing across the Atlantic to shield… – Continue reading
The banana giant rejected a $625 million buyout bid by Brazilian orange behemoth Cutrale Group and conglomerate Safra Group on Thursday and said it means to go ahead with a planned merger with Irish rival Fyffes. The combined company is then expected to register in low-tax Ireland in what is… – Continue reading
Two registries of significant interest to shipowners are the registries of the Republics of the Marshall Islands and Liberia. Significantly, insofar as it does not conflict with the statutory laws, each country has adopted the non-statutory general maritime laws of the United States. This gives added certainty to shipowners, particularly… – Continue reading
A former manager of a credit union was sentenced on Tuesday for bank fraud and tax evasion, announced U.S. Attorney Danny C. Williams, Sr. for the Northern District of Oklahoma and R. Damon Rowe, IRS-Criminal Investigation, Special Agent in Charge, Dallas Field Office. Eva Barroso, 54, Broken Arrow, was sentenced… – Continue reading
Tax competition isn’t just an international issue. While recent headlines have focused on how the high U.S. corporate rate is causing multinationals to relocate to jurisdictions that have cut their taxes or restructured their tax regimes to be more favorable to business (like Ireland and the United Kingdom), the effects… – Continue reading
An international bank executive formerly of Naperville has pleaded guilty to federal tax evasion charges and faces up to three years in prison at sentencing later this year. Aamir H. Khan, 43, was the managing director of a Middle Eastern bank based in Bahrain when he filed false income tax… – Continue reading
Swiss Banks Return To The United States by Julie Zaugg in New York, swissinfo.ch A handful of Swiss banking institutes have started to re-engage with the United States off-shore market – entirely within the law. Their assets under management (AUM) are seeing a spectacular increase. At UBS the AUM has risen… – Continue reading
