Category: Jurisdiction

Burger King-Tim Hortons: Is Canada becoming a corporate tax haven?

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

U.S. businesses moving overseas to dodge taxes

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

‘Tax haven’ Monaco experiences luxury-housing boom

LONDON: Monaco, the tax haven on the French Riviera, is experiencing a luxury-housing boom that includes the world’s most expensive penthouse as developers prepare for an influx of millionaires and billionaires escaping higher taxes or a loss of banking privacy.A “flow” of new residents is emigrating from Switzerland, where financial-secrecy… – Continue reading

The Global Crackdown on Profit Shifting

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

Fake reception prompts probe

A political candidate has sparked the Reserve Bank and the Financial Markets Authority to visit a foreign-owned company offering “secret” offshore accounts. Grace Haden, an independent standing for election in Epsom, raised concerns with the regulators about Breder Suasso, which is referred to on overseas websites as a New Zealand… – Continue reading

Double Tax Arrangements in Nigeria: Imperatives for a wider network

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

Bosses flee Vietnam, ignoring debts and taxes

VietNamNet Bridge – The bad news about tax evasion and debt repudiation cases by foreign invested companies has darkened Vietnam’s foreign direct investment (FDI) landscape. Tuoi Tre newspaper has reported that Austrian Harald Biebl, director of the HCM City-based Bach Hop Company, operational in Vietnam since 2005, has fled the… – Continue reading

G20 to press for ‘rapid timeline’ for exchange of tax information

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

FATCA Alert: IRS Issues Final Version of the Form W-8BEN-E and Accompanying Instructions

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

Review of patent tax regimes in EU has Irish support

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 Admits Keeping $92 Billion Offshore to Avoid Paying $29 Billion in U.S. Taxes

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

5 Year Prison Sentence for Former LR Attorney for Mail Fraud, Tax Evasion

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

Billionaire Eugene Melnyk: I’m a ‘whistleblower’ on tax allegations against Valeant

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

First landmark ruling on Indian indirect transfer taxes! Delhi High Court restricts their applicability

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

Richard Kaplan: Additional Rauner tax-return disclosures probably won’t reveal much

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

Scottish Parliament passes legislation establishing Scotland’s first tax collection system for 300 years

Legislation which will establish and govern Scotland’s first tax collection system in 300 years has been passed by the Scottish Legislation which will establish and govern Scotland’s first tax collection system in 300 years has been passed by the Scottish Parliament.21 Aug 2014 The Revenue Scotland and Tax Powers Bill… – Continue reading

Leading Liverpool tax specialist aids guidance in new HMRC tax fraud policy

Those committing tax evasion could face stricter consequences due to the change in government tax legislation, according to a top city accountant. Des Veney, Director of Haines Watts Chartered Accountants on Victoria Street, believes that as a result of the stern regulation, which came into effect earlier this month, UK… – Continue reading

Gibbons: New companies trend show Bermuda ‘moving in right direction’

Education and Economic Development Minister Grant Gibbons said yesterday the Registrar of Companies’ data on new company incorporations for the second quarter of 2014 continues to show a strong positive trend in the number of new company registrations. Results following the close of the quarter in June showed that the… – Continue reading

Must Have Been A MASH Fan: Hot Lips Was Code Name For Man’s Hidden Offshore Account

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

Glencore report: European Investment Bank must drag its secrets into the light

Reasons given by the bank for refusing to publish findings of an investigation into alleged tax evasion remain unconvincing When commodities giant Glencore publishes its half-yearly report on Wednesday, it is unlikely to mention what may be a significant victory for the firm. This relates to an investigation into allegations… – Continue reading

Russell-linked tax avoidance case in High Court

Companies with links to John George Russell are accused of entering into “tax avoidance” arrangements and are in a $3.5 million fight with the IRD. Russell – who developed a template that the Court of Appeal called a “blatant tax-avoidance scheme” – is a 79-year-old accountant being chased by the… – Continue reading

The implications of FATCA in South Africa

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

New UK measures to counter avoidance schemes involving transfer of corporate profits

A new section 1305A of the UK Corporation Tax Act 2009 (CTA 2009) has been introduced by the UK Finance Act 2014 that applies to payments made from March 19, 2014 under avoidance schemes involving the transfer of corporate profits within a group. This new measure applies if: two companies… – Continue reading

Offshore incorporations up in Cayman and worldwide

Despite the political and media pressure on offshore financial centers, new incorporations of offshore companies worldwide continue to grow. A new report on offshore company incorporations by law and fiduciary firm Appleby shows that new company registrations increased in most offshore jurisdictions in the second half of 2013. “As the… – Continue reading

Cayman included on FCA high-risk list

The Cayman Islands, an important international business competitor for Bermuda, is expressing “consternation” that they have been included on a new list of high risk jurisdictions for financial crime. There are a total of 95 countries listed including Brazil, Afghanistan, Cuba, Russia, China, Iraq, the Republic of Congo and Jamaica…. – Continue reading

Serbia To Protect Taxpayers’ Rights Under FATCA

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

10 Facts About FATCA, America’s Manifest Destiny Law Changing Banking Worldwide

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

EBT scheme’s defeat will protect £2.4m, says HMRC

A tax avoidance scheme that routed a film financing venture’s profits via Employee Benefit Trusts at the behest of the venture’s owner, an ex-accountant, has been blocked by a tribunal. Operated by John Dryburgh, a former partner with Deloitte & Touche, the scheme  involved extracting profits from a series of companies named… – Continue reading

Another French footballer on tax evasion radar

Switzerland is cooperating with French tax authorities over an investigation of alleged tax fraud involving former French footballer Marcel Desailly. The notice of Swiss cooperation was published on Tuesday in the Federal Gazette. Desailly, captain of the French football team from 2000 to 2004, allegedly holds or has held assets… – Continue reading