Category: USA

IRS Boss Warns OECD About Corporate Profit Shifting Plan

Law360, New York (June 03, 2014, 7:10 PM ET) — Internal Revenue Service Commissioner John Koskinen said Tuesday that an international plan to squash corporate profit shifting will create headaches for administrators and hurt U.S. taxpayers.Addressing the Organization for Economic Cooperation and Development, Koskinen said the plan would create tens… – Continue reading

Liechtenstein, US Sign FATCA Deal

Liechtenstein and the US have signed an intergovernmental agreement (IGA) for the implementation of the US Foreign Account Tax Compliance Act (FATCA), the Liechtenstein Government has announced. The IGA requires the Liechtenstein Tax Administration and the US Internal Revenue Service (IRS) to exchange information automatically on accounts held by US… – Continue reading

Credit Suisse Offers Map to 13 Swiss Banks in U.S. Tax Probe

Suisse Group AG (CSGN) set a new standard for punishment in the U.S. crackdown on offshore tax evasion. Julius Baer Group Ltd., Zuercher Kantonalbank and the Swiss unit of HSBC Holdings Plc (HSBA) are among those seeking to avoid pleading guilty to helping Americans cheat the Internal Revenue Service —… – Continue reading

Canada-U.S. tax agreement raises some concerns

CALGARY – A Calgary-based United States tax expert has recommended to the federal government that Canada follow the lead of other countries and include certain Canadian trusts within the definition of organizations subject to reporting under the recent Intergovernmental Agreement between the Canada and the U.S. “This would eliminate the… – Continue reading

Cyprus: Cyprus Signs Model 1 IGA With US Treasury

The Inland Revenue Department of Cyprus (“IRD”) will proceed with the signing of Model 1 IGA (Inter Governmental Agreement) with the US Treasury, following the Foreign Account Tax Compliance Act (FATCA). The Model 1 IGA requires Foreign Financial Institutions (FFIs) to report all FATCA-related information to their own governmental agencies,… – Continue reading

What Happens When FATCA Kicks In

There’s a bill that will go into effect on July 1. It’s known as H.R. 2847 which contains FATCA (the Foreign Account Tax Compliance Act of 2010). H.R. 2847 also known as HIRE (the Hiring Incentives to Restore Employment Act) was a law passed in March 2010 which will go into… – Continue reading

FOREIGN WITHHOLDING TAXES: HOW TO ESTIMATE THE HIDDEN TAX DRAG ON U.S. AND INTERNATIONAL EQUITY INDEX FUNDS AND ETFS

Course summary: Justin Bender of PWL Capital and Dan Bortolotti of PWL Advisors explain the ins and outs of foreign withholding tax on U.S. and international equity index funds and ETFs. INTRODUCTION Canadian investors get an enormous benefit from diversifying their portfolios with US and international stocks. But this benefit… – Continue reading

Foreign Financial Industry Retaliation Will Be Coming Soon

The United States is targeting so-called offshore tax havens by claiming that billions of dollars of taxes are being evaded. The Foreign Account Tax Compliance Act was passed in 2010 as a revenue raiser, with the simple expectation that the United States can force the world’s financial industry to disclose otherwise… – Continue reading

Azerbaijan, U.S. reach compromise on exchanging information on U.S. citizens’ accounts

Azerbaijan and the U.S. Internal Revenue Service (IRS) agreed to conclude an intergovernmental agreement on implementation of the Foreign Account Tax Compliance Act (FATCA) by Azerbaijani banks, the Ministry of Taxes of Azerbaijan said on May 21. Starting from July 1, 2014 the banks in all countries should join the… – Continue reading

Russia Mulls ‘Limitations’ On Information Exchange With U.S. Under FATCA

The Russian government may place “limitations” on the amount of information that Russian banks can render to U.S. tax authorities under FATCA, a U.S. federal law intended to crack down on tax avoidance by U.S. citizens, Deputy Finance Minister Alexei Moiseyev said Thursday. Moiseyev told journalists in St. Petersburg that Russia will not become “tax agents for the Americans, that… – Continue reading

Foreign Account Tax Compliance Act will result in heightened tax scrutiny of NRIsForeign Account Tax Compliance Act will result in heightened tax scrutiny of NRIs

In recent years, the US Congress and the US Department of Treasury have come to believe that many US taxpayers (including US citizens and green card holders in India) have not been complying with the tax law that requires reporting of worldwide income, including income held in non-US financial institutions…. – Continue reading

Top 12 tax havens for US companies

US corporations are making record profits in tax havens like Bermuda, the Cayman Islands, and the British Virgin Islands (BVI). Some of the profits exceed the GDP of the host country, with Bermuda’s offshore profits 1643% of total economic output. As a share of Gross Domestic Product (GDP), profits from… – Continue reading

Tax Benefits of Moving Abroad for a Job

Moving abroad to start a new job can be one of the most exciting yet stressful experiences of your life — but it can also end up saving you a bundle in federal income tax. This is because U.S. expatriates frequently take advantage of the foreign earned income exclusion to… – Continue reading

Tax Chauvinism: Who Cares Where a Firm is Incorporated?

Following the recent offer by U.S drugmaker Pfizer to acquire British pharmaceutical firm AstraZeneca, congressional Democrats are proposing new limits on the ability of U.S.-based firms to establish foreign residence and thus cut their U.S. corporate tax bill. Even before this latest flap, the Obama Administration proposed curbs on this… – Continue reading

Report: Bank of America among US companies saving on taxes by keeping profits offshore

Bank of America tops the list of Charlotte-based companies avoiding big tax bills by keeping profits offshore, according to a new report by a nonprofit tax research and advocacy group. Citizens for Tax Justice found that 301 U.S. Fortune 500 companies disclosed holding nearly $2 trillion in profits offshore. By… – Continue reading

Swiss banking giant pleads guilty to aiding tax evasion

WASHINGTON — European bank Credit Suisse AG pleaded guilty Monday to helping wealthy Amer­icans avoid paying taxes through secret offshore accounts and agreed to pay about $2.6 billion. The Justice Department said it was the largest penalty imposed in any criminal tax case. It is also the largest bank to… – Continue reading

US pivotal to OECD tax plan

IT’S BECOMING increasingly apparent that the OECD’s plan to reduce tax base erosion and profit-shifting, as laudable as it is, is hugely reliant on the US making significant and drastic alterations to its corporate regime if it is to be successful. The cases of Starbucks and Google have shown us… – Continue reading

Three Things Credit Suisse’s Guilty Plea To Tax Evasion Teaches Big Banks

Credit Suisse is pleading guilty to criminal charges and paying a $2.6 billion fine for helping American clients cheat on their taxes over the past decade. The firm helped tens of thousands of Americans hide their wealth, kept lists of companies and accountants who could facilitate tax evasion for clients, and actively recruited U.S…. – Continue reading

U.S. extends time limit for FATCA

The U.S. has extended the time limit for compliance withFATCA, the reporting of its citizens’ financial accounts outside of the country,to the years 2014 and 2015. The Treasury Department of the United States, through the inland revenue service (IRS) has announced that it will take into account the “good faith”… – Continue reading

Latest from the U.S. on Five of the OECD BEPS Action Items

Robert Stack, deputy assistant secretary for international tax affairs with the U.S. Treasury, gave an update on several items in the OECD’s project to combat base erosion and profit shifting at the American Bar Association Section of Taxation’s May meeting. As reported more fully by Transfer Pricing Report’s Kevin Bell, Stack,… – Continue reading