While President Barack Obama’s new tax proposals may never see the light of day, given the Republican majorities in both the House and Senate, they have generated discussion among cross-border tax practitioners. Dual citizens living in Canada or Canadians who own U.S. properties may wonder whether they need to reopen… – Continue reading
A year in review: the far reach of the IRS in Canada – Foreign Account Tax Compliance Act What is FATCA? The Foreign Account Tax Compliance Act1 (“FATCA”) was enacted by the United States Congress in order to deal with non-compliance by US taxpayers using foreign bank accounts. FATCA requires… – Continue reading
The Foreign Account Tax Compliance Act (FATCA) is a new chapter in the US Internal Revenue Code. Chapter 4 was added by the Hiring Incentives to Restore Employment (HIRE) Act. It seeks to identify US taxpayers having accounts at foreign financial institutions (FFIs) and attempts to enforce reporting of those… – Continue reading
Fiji has proposed a Double Taxation Avoidance Agreement with Sri Lanka. The Fijian Attorney-General and Minister for Finance, Aiyaz Sayed-Khaiyum, confirming this said a draft agreement will be sent to Sri Lanka to initiate the discussions. Mr Sayed-Khaiyum met with the Sri Lankan Minister for External Affairs Mangala Samaraweera this… – Continue reading
NEGOTIATING A DOUBLE Taxation Agreement (DTA) with Israel was a major talking point when that country’s Ambassador to Barbados, Mordehai Bivas, paid a courtesy call on Minister of Foreign Affairs and Foreign Trade, Senator Maxine McClean at her Culloden Road headquarters. Senator McClean told the Ambassador: “One of the things… – Continue reading
Tax and estate planning usually takes place during a client’s lifetime. That said, there are post-mortem planning opportunities that you should discuss with clients. The goal of post-mortem planning is to reduce the overall tax liability for the estate and its beneficiaries. So create a customized plan to deal with… – Continue reading
New Delhi, Jan. 23: India and the US have failed to make much progress in the totalisation pact that addresses the the problem of the double payment of social security taxes by Indian software professionals in America, dampening expectations surrounding President Barack Obama’s visit this weekend. Top officials said discussions… – Continue reading
Industry body Assocham has urged the Government to clarify that MAT will not be levied on foreign companies that do not have any branch or a permanent establishment in India. Such a clarification is needed for incomes sourced out of India by such foreign companies, the chamber said in a… – Continue reading
Over the past few years, the European Union has targeted multinational corporations using tax planning strategies to reduce corporate tax burdens. Recently, the EU has launched an investigation into tax deals between Amazon (AMZN) and the country of Luxembourg. With an array of subsidiaries within European countries, Amazon’s European headquarters… – Continue reading
International accountant and shipping adviser Moore Stephens says companies in the offshore maritime sector could be among those hit by a 25% Diverted Profits Tax (DPT) charge under draft UK legislation scheduled to enter force in April 2015. Under the draft legislation published by the UK Government in December 2014,… – Continue reading
India has worked out a bilateral tax agreement with the United States, which could be signed during U.S. President Barack Obama’s visit, that would boost foreign investment and ease investors’ concerns raised by high profile cases against Vodafone and Shell. The pact, which industry executives say would specifically target the… – Continue reading
The Fiji Revenue and Customs Authority (FRCA) has announced two six-month amnesty programs, for undeclared offshore assets and for persons struggling to pay tax dues. The first amnesty will enable taxpayers who disclose assets held offshore to be liable for unpaid taxes only. Initially announced by the Fijian Minister for… – Continue reading
Premier Li Keqiang (Left) meets with Simonetta Sommaruga, president of the Swiss Confederation, in Davos, Switzerland, Jan 21, 2015.[Photo/english.gov.cn] China will give Switzerland an investment quota of 50 billion yuan ($8.05 billion) under its Qualified Foreign Institutional Investors (QFII) scheme to support the establishment of the Zurich offshore renminbi market,… – Continue reading
Lobby groups representing Google, Amazon and other powerful US tech multinationals have launched a fierce attack on global plans to stamp out artificial corporate structures used to avoid tax. In responses to the latest stage of a two-year, G20-led programme of international tax reform, lobbyists for the US tech industry… – Continue reading
Malta Qualifying Recognised Overseas Pension Schemes (QROPS) are jumping on the flexible access bandwagon. The Malta Financial Services Authority as amended local regulations in favour of QROPS based on the Mediterranean Island following the new flexible access pension rules administered by HM Revenue & Customs (HMRC) in the UK from… – Continue reading
With the city-state revising its earlier avoidance of double taxation agreement with France and signing a new one with Uruguay recently, a boost in cross-border trade is inevitable. Singapore (PRWEB) January 22, 2015 In what can be termed as two important milestones in Singapore’s trade relations with Europe and Latin… – Continue reading
In the first of this two part article, we outlined what businesses must do to comply with India’s transfer pricing laws, while stressing the key reforms introduced by the new government to bring certainty to the domestic tax system. Here, we discuss if and how India should respond to the… – Continue reading
The US Foreign Account Tax Compliance Act (FATCA) is in the vanguard of a global movement towards the automatic exchange of information on tax matters. The US enacted FATCA in 2010 to tackle the problem of tax evasion by US citizens and residents who under-report or fail to report income… – Continue reading
NEW DELHI: India and the US have finalised a framework to resolve transfer pricing cases, some of them pending for five years, in what could end tax trauma for more than 50 American MNCs such as Microsoft, IBM and Oracle by the fiscal year-end and send a strong signal to… – Continue reading
NEW DELHI: Dabur promoter Pradip Burman, whose name has cropped up in the blackmoney list, was today once again stopped from going abroad by a Delhi court which said there was an apprehension that he could flee. Additional Chief Metropolitan Magistrate (ACMM) Devendra Kumar Sharma, rejected Burman’s application saying no… – Continue reading
Just as UK firms grasp the requirements of the US-led Foreign Account Tax Compliance Act (Fatca), China appears to be joining the ranks as another nation seeking to up its tax-take from citizens living abroad. China has announced plans to implement a law that is similar to Fatca. This legislation… – Continue reading
NEW DELHI: India’s software product startups plan to approach the finance ministry this week to get the ambiguity cleared in this Union Budget on the pending issue of whether software sold in the country should be classified as a product or service. Tax officials have been levying both value-added tax… – Continue reading
To comply with unconstitutional pseudo-treaties negotiated by the Obama administration without the consent of Congress or any semblance of constitutional authority, the IRS announced that it will be sharing private financial information on U.S. bank account holders with foreign powers. No warrant is needed for foreign governments or tyrants to… – Continue reading
Lobbyists representing firms including Google, Amazon and Apple claim ‘fundamental flaws’ in G20-led reforms The World Economic Forum in Davos, where Google, Microsoft and Facebook executives will discuss the digital economy on Thursday. Photograph: Fabrice Coffrini/AFP/Getty Images Lobby groups representing Google, Amazon and other powerful US tech multinationals have launched… – Continue reading
Companies in the offshore maritime sector could be among those hit by a 25 percent Diverted Profits Tax (DPT) charge under draft UK legislation scheduled to enter force in April 2015, international accountant and shipping adviser Moore Stephens said. Under the draft legislation published by the UK government in December… – Continue reading
2014 was a year replete with new legislative and regulatory initiatives impacting federally regulated financial institutions. The key initiatives introduced or implemented in 2014 are outlined in our annual year in review. PRUDENTIAL REGULATION: GUIDANCE FROM OSFI Proposed New Bail-in Regime for Large Banks On August 1, 2014, the Government… – Continue reading
Stakeholders in Real Estate Investment Trusts (REITs) have identified double taxation as challenge to investment in the sector, even as they clamour for enabling legislation. In order to make the Real Estate Investment Trusts (REITs) a tax-effi¬cient vehicle for invest¬ment, there is an urgent need for an enabling leg¬islation, they… – Continue reading
SUCCESSFUL INTERNATIONAL STRUCTURES in most cases begin with choosing the right jurisdiction to host a company that will form part of an international business. Depending on the company’s activities, the choice will depend on the range of double taxation treaties and the availability of tax reliefs followed by a host… – Continue reading
On October 29, 2014, through the OECD “Global Forum on Transparency and Exchange of Information for Tax Purposes,” both the OECD and G20 countries endorsed a new Standard for Automatic Exchange of Financial Account Information in Tax Matter. 59 countries are so-called “early adopters” and are committed to undertaking their… – Continue reading
Democratic lawmakers Tuesday pushed legislation to stop U.S. companies from reincorporating overseas to reduce their tax bills, saying a wave of so-called inversions last year has nearly doubled the revenue the federal government will lose from those moves over the next decade. The bill would make it tougher for U.S…. – Continue reading
Decree-law no. 7/2015, dated 13 January, introduced important changes to the taxation system of revenues obtained by investors in all funds located and operating in Portugal. Taxation in Portugal had hitherto been levied on gains and other revenues earned by funds irrespective of costs incurred in achieving them. One of… – Continue reading
In December 2014, the Canada Revenue Agency (CRA) issued a letter to a sample of taxpayers to remind them of the criteria for filing a T1135-Foreign Income Verification Statement and to review their income tax filings to ensure they have been properly reporting the relevant assets and income. All Canadian… – Continue reading
The thrust of the Indian government’s economic policy is encouraging, particularly the tax reform of proposed introduction of goods and services tax. NEW DELHI, JAN 20: Germany has made a case for ‘respecting the secrecy’ of any information shared with India for tax administration purposes. This stance assumes significance given… – Continue reading
Voltaire wrote “If you see a Swiss banker jumping out of a window, follow him, there is sure to be a profit in it”. Following this train of thought India is seen to be ruined by a cartel of Swiss bankers, terrorists and corrupt industrialists. Unlimited black money is apparently… – Continue reading
On Dec. 12, 2014, Rep. John Delaney (D-MD) proposed a new version of his “repatriation holiday” tax plan. The latest version would require multinational corporations to pay a token amount of taxes on their accumulated offshore profits and exempt those profits from any further U.S. income tax. Delaney’s new plan… – Continue reading
Voltaire wrote “If you see a Swiss banker jumping out of a window, follow him, there is sure to be a profit in it”. Following this train of thought India is seen to be ruined by a cartel of Swiss bankers, terrorists and corrupt industrialists. Unlimited black money is apparently… – Continue reading
As significant changes take effect with pensions, offshore tax evasion and property, 2015 looks like it will be an interesting year. However, there are still opportunities to be found despite the ongoing upheaval. As we all start a fresh new year, many advisers will be starting to think about the… – Continue reading
After almost three years’ negotiations over untaxed Italian assets in Swiss banks, Switzerland and Italy have reached an agreement in principle on future cooperation in tax matters. The agreement between Switzerland and Italy was initialled on 19 December 2014 The two governments are currently preparing the signature of a Protocol… – Continue reading
Congressional Democrats are preparing new efforts to curb the offshore tax deals that drew the ire of President Obama last year. Senate Minority Whip Dick Durbin (D-Ill.), Sen. Jack Reed (D-R.I.), Rep. Sandy Levin (D-Mich.) and Rep. Lloyd Doggett (D-Texas) will introduce legislation on Tuesday seeking to stop the maneuver… – Continue reading
Observers of offshore financial centres will know that post 2008 they have been weathering a perfect storm. Firstly, reduced transactional flows, simply because there is less money available for structured finance and investment generally. Secondly, a constant barrage of negative publicity, which deliberately seeks to conflate tax evasion and tax… – Continue reading
Kansas Governor Sam Brownback had championed the largest tax cuts in the state’s history, eliminating taxes on non-wage earnings for nearly 200,000 small businesses. Just like all Republicans these days, Brownback had made cutting taxes and shrinking government the centerpieces of his government. Now the great State of Kansas has… – Continue reading
Introduction Malta is increasingly becoming a financial services centre of repute looked at by a number of financial services operators as the ideal platform to set up their private pension schemes. Malta’s success is attributable to the flexible and prudent manner in which the industry is regulated, providing the desired… – Continue reading
A recent clarification issued to Foreign Portfolio Investors (FPIs) clarified that fund managers of FPIs who are present in India would not be treated as permanent establishments in India, addressing the concern that the FPIs may be taxable in India to the extent attributable to permanent establishments. An extension of… – Continue reading
A person who earns income must pay tax in the country he earns in as well as the country he resides in. In order to avoid this, India has signed Double Taxation Avoidance Agreements (DTAAs) with many countries so that the income is taxed only once. To claim this benefit,… – Continue reading
Although the Swiss authorities are poised to initiate formal talks for the return of the plundered money, the Pakistani government remains dilatory to sign a formal agreement for the purpose; it was learnt here on Saturday. Sources said that government in order to avoid face-off with Pakistan Peoples’ Party (PPP)… – Continue reading
Italy and Switzerland have agreed an amendment to their double tax agreement to enhance tax information exchange provisions. It is hoped that the agreement will be signed before the March 2 deadline set by Italy’s new voluntary disclosure program to enable Switzerland’s removal from Italy’s “black list.” After three years… – Continue reading
No issue dominates this year’s legislative and regulatory agenda of the risk management and property/casualty insurance community as reauthorization of the federal terrorism insurance backstop did even several weeks ago. Extension of the program, which lapsed several days before Congress reinstated it in early January, united the industry around a… – Continue reading
We commissioners have vowed to clamp down on evasion and fraud to make sure all companies pay their fair share 2014 was the year the world discovered there is no whisky in a double Irish and no cheese in a Dutch sandwich. Discussions about fair taxation and tax avoidance featured… – Continue reading
City Residents Forced Into Double Taxation Unfortunately, Lewis County officials seem to conveniently forget that “city” resident/taxpayers are entitled to the same consideration given to resident/taxpayers who live in the unincorporated area of Lewis County — something akin to an “us vs. them” situation.
Switzerland and Italy have reached an agreement in principle on future cooperation in tax matters. Negotiations with Italy over untaxed Italian assets in Swiss banks have been running for two and a half years. The agreement will facilitate the processing of the Italian voluntary disclosure programme recently adopted by Italy’s… – Continue reading
