Category: Offshore Trusts

Five things agents and developers need to know about the non-dom tax changes

From 6 April 2017, non-dom owners of UK property will be liable to inheritance tax (IHT) at 40% on any UK residential property they own. This has always been the case where a non-dom (broadly an individual who is resident in the UK but who has their permanent home abroad)...

New Zealand: New Zealand To Enact Tighter Foreign Trust Disclosure Rules

The New Zealand Parliament has passed a Bill which, following royal assent, will meaningfully increase disclosure obligations for NZ resident trustees of NZ foreign trusts. The Taxation (Business Tax, Exchange of Information, and Remedial Matters) Bill, was passed by Parliament on 14 February 2017. The Bill contains important provisions relating...

Foreign person NRA tax withholding

Nonresident Alien NRA tax withholding is applicable to U.S sourced income paid to foreign person and does not apply to payments made to U.S. persons. Foreign persons include nonresident alien individual, foreign partnerships, foreign corporations, foreign estates, and foreign trusts. The tax generally must be withheld from the payment made...

New tax measure takes aim at Offshore Trusts

A bombshell hidden in the detail of the 2017 Budget review relates to the taxation of offshore trusts. It refers to the 2015 Budget review in which it was announced that measures would be introduced to the tax treatment of foreign companies held by interposed trusts. No specific countermeasures were...

UK: Offshore Trust Deadline Looming For UK Non-Doms

Individuals who will be deemed UK domicile from 6 April 2017 should be considering their options with regard to offshore trusts as a matter of priority. On 5 December 2016, the UK Government published the Reforms to the taxation of non-domiciles: further consultation outcome, which provided clarity on the following...

Final Response to Non-Dom Consultation Published

In Depth There is mixed news for affected individuals, including far-reaching changes relating to offshore trusts and a further wait (possibly until March 2017) for the rest of the draft legislation. The following are highlights from the government’s response and the draft legislation. Deeming Provisions Deemed Domiciled: Non-doms will become...

Tax Agreements: From Double Taxation To Double Evasion

The issue of tax havens is inherently international in scope. As a result, the government can use tax agreements to fight tax avoidance schemes. Unfortunately, tax agreements haven’t been used for that purpose. On the contrary, they have facilitated the outflow of Canadian money to offshore financial centres, and have...

Panama Papers and US initiatives to identify entity beneficial owners

In early April 2016 files leaked from a large Panama-based law firm (known as the ‘Panama Papers’) brought to the attention of many the ways in which offshore companies and structures can be used to obscure the identity of beneficial owners, some of whom have used such entities to avoid...

Practically Untouchable: Going Offshore Still Has Benefits

THE RECENT LEAK of millions of documents from Panamanian law firm Mossack Fonseca served as a reminder of what wealthy Americans should already know: Hiding assets offshore can be risky and hiding them from Uncle Sam is a crime. Yet law-abiding folks continue to stash money offshore for reasons that...

UK: Proposed Changes To The Non-Dom Regime From April 2017

The tax treatment of non-domiciled individuals is changing again from April 2017. The changes were first announced in the 2015 Summer Budget, and a Consultation document was issued in September 2015 setting out further details. The proposed changes target three key areas: The taxation of non-domiciled individuals who have been...

Panama Papers Row Fails To Deter Trust Buyers

The Panama Papers row has failed to deter Permira and TPG from bidding for offshore trust firms, Sky News learns. Some of the world’s biggest buyout firms are queuing up to buy a string of offshore trust administrators despite the escalating global furore about the leaked Panama Papers. Sky News...

U.S. launches ‘criminal investigation’ involving Panama Papers

A federal prosecutor in New York has opened a criminal investigation involving the Panama Papers — a trove of materials from a Panamanian law firm that show a massive, secretive world of offshore industry. In a letter to the International Consortium of Investigative Journalists (ICIJ), U.S. Attorney Preet Bharara wrote...

For tax evaders tax amnesty could be bad news and good news

The push for a tax amnesty has attracted a fair amount of criticism and even rebuke from analysts, the International Monetary Fund, the Organization for Economic Cooperation and Development (OECD), the World Bank and even the Corruption Eradication Commission (KPK). Yustinus Prastowo, a respectable tax analyst, went so far as...

Call to tighten UK’s new property law to crack down on ‘dirty money’

Rules should require foreign owners of prime London homes to come clean about beneficiary owners, say anti-corruption groups Large parts of London’s Baker Street, including the Beatles store, are owned by offshore trusts. New laws that aim to stop the UK being a magnet for money launderers – by forcing...

Taxman is on the prowl for cheaters overseas

An unnamed Korean, according to the National Tax Service (NTS), was living a luxurious life with properties and investments inherited from his father. This inherited fortune, which included stocks overseas, high-end residences as well as diverse financial assets, was not only unreported to the Korean tax agency but was managed...

Birmingham Post Rich List 2016: More taxing times for non-domiciled individuals

The taxation of ‘non-UK domiciled’ individuals has been a thorny political issue as successive governments have sought to crack down on those enjoying what some have seen as an excessively benign tax regime The taxation of ‘non-UK domiciled’ individuals has been a thorny political issue as successive governments have sought...

HMRC to repay tax to thousands of banking and IT contractors

Banking and IT contractors forced to stump up tens of thousands of pounds to settle contested tax debts last year are now in line to be repaid, after the UK tax authority accepted it should not have issued payment demands. HM Revenue & Customs has withdrawn so-called accelerated payment notices...

HMRC to repay tax to thousands of banking and IT contractors

Banking and IT contractors forced to stump up tens of thousands of pounds to settle contested tax debts last year are now in line to be repaid, after the UK tax authority accepted it should not have issued payment demands. HM Revenue & Customs has withdrawn so-called accelerated payment notices...

Investor group buys Barclays’ offshore trust business

Barclays (BARC.L) has sold its offshore trust business to an independent investor group but will keep a 20 percent stake in the new company, renamed as ZEDRA, for at least three years. The sale marks another step in the British bank’s efforts to simplify its wealth and investment management activities....

Taxi King found to have evaded lenders via offshore trusts

Things just keep getting worse for Gene the Taxi King. A federal judge ruled Tuesday that New York taxi mogul Evgeny “Gene” Freidman illegally transferred more than $60 million in real estate assets into offshore trusts as a means of evading ex-lender Citibank. The ruling, which cited “numerous and glaring”...

2016 CHALLENGES FOR COMPANIES OPERATING IN JERSEY

Last year Jersey cemented its position as a leading centre for companies looking to list – as reflected in the rise in volume and value of Jersey companies listed on exchanges around the world. Here are some challenges that lie ahead in this jurisdiction over the next 12 months. In...

Ireland: the Tax Haven that Dare Not Speak Its Name

‘We’re not a tax haven, we have never been involved in any kind of tax malpractice’ – Michael Noonan, Irish Minister for Finance 5th October 2015 If your top political figures need to constantly state that your country is not a tax haven, then the chances are it probably is...

MPs given exemption from tax avoidance

The Government introduced legislation on ‘disguised remuneration’ in the Finance Bill last week to target the practice of using third party vehicles such as offshore trusts to allow employees to avoid or defer the payment of income tax or national insurance contributions. However, it has emerged that MPs will not...

Tax Amendments 2015

INTRODUCTION The Taxation Laws Amendment Act, 2015 and the Tax Administration Laws Amendment Act, 2015 have now both been passed by Parliament, but await signature by the President. Once again, and for the second year running, the number and scope of the changes to the various fiscal Acts (mainly the...

Tax amendments – 2015

INTRODUCTION The Taxation Laws Amendment Act, 2015 and the Tax Administration Laws Amendment Act, 2015 have both now been passed by Parliament, but await signature by the President. Once again, and now for the second year running, the number and scope of the changes to the various fiscal Acts (mainly...

More than 50 banks which helped American clients dodge tax in Swiss bank accounts receive immunity from criminal prosecution in US

More than 50 banks which helped American clients dodge tax in Swiss bank accounts have received immunity from criminal prosecution in the US. The firms, which include UK giant Standard Chartered, Germany’s biggest lender Deutsche Bank, and France’s BNP Paribas, have reached plea bargains with the US Department of Justice....

UK launches campaign warning offshore tax evaders

The UKtoday launched a campaign warning offshore tax evaders that the governmentwill soon receive details on UK taxpayers from more than 90 countries under new global agreements. The campaign by David Gauke, the Financial Secretary to the Treasury says that the government is giving people one last chance to come...

Hong Kong: Crackdown On Caribbean Tax Havens A Surprise Boon For Hong Kong

Hong Kong is tipped to become the world’s largest offshore corporate services centre by 2020, helped ironically, by the industry’s own struggles against reform demands coming from western governments and pressure groups. On notice after high profile money laundering and tax avoidance scandals, traditional offshore havens like the British Virgin...

The Offshore Wrapper: a week in tax justice #71

Now that’s what I call a Big Tax Case A long running court case that has become known as the ‘Big Tax Case’ appears to be reaching a conclusion. It involves Scottish football club Rangers, who went bust in 2012. After it failed, a new company was created. It bought...

Crackdown on Caribbean tax havens a surprise boon for Hong Kong

Hong Kong is tipped to become the world’s largest offshore corporate services centre by 2020, helped ironically, by the industry’s own struggles against reform demands coming from western governments and pressure groups. On notice after high profile money laundering and tax avoidance scandals, traditional offshore havens like the British Virgin...

African leaders reject EU ‘charity’ over ‘investment’

Macky Sall, the Senegalese president, tells journalists on the sidelines of the Malta migrants summit that Africa would have no need of handouts if wealthy governments stopped multinationals avoiding legitimate taxation in their countries African leaders have rejected a European Union bid to curb migration with aid payments as “not...

Reforms to taxation of non-domiciled individuals: consultation published

Introduction On September 30 2015 Her Majesty’s Treasury published its long-awaited consultation on two of three proposed changes to the taxation of individuals domiciled outside the United Kingdom. The three measures – announced by Chancellor George Osborne in the 2015 Summer Budget published on July 8 – are intended to...

Private Client 2015: Trust & Advisory Services Analysis

In this edition we also include the leading trustees, private bankers and accountants serving the private client industry. RBC Wealth Management leads our research in trust and advisory services with an impressive 18 names recommended. Alan Binnington specialises in establishing and administering trust and fiduciary structures for high net worth...