Category: Tax Laws

FATCA Alert

In recent years, the United States has increased initiatives to counter tax evasion committed by U.S. persons who are not reporting and paying U.S. income tax on earnings derived from foreign financial assets. The Foreign Account Tax Compliance Act (“FATCA”) represents the latest major initiative in this regard, having been… – Continue reading

FATCA Tracker – October 01, 2014

Nearly 105,000 financial institutions are listed on the US Internal Revenue Service (IRS) database of Foreign Account Tax Compliance Act (FATCA) organisations complying with the tax reporting rules for US citizens. The latest list was published on October 1, 2014 by the IRS and shows 104,344 financial organisations have signed… – Continue reading

Black money row: Left says BJP and Centre stand exposed

New Delhi: Communist Party of India (Marxist) leader Brinda Karat on Saturday criticized the Prime Minister Narendra Modi-led NDA Government at the Centre for not disclosing the names of persons having money stashed away in safe havens abroad, and alleged that it exposed the utter hypocrisy and double standards of… – Continue reading

Panama, Colombia to hold uninterrupted talks to resolve tax-haven spat

PANAMA CITY –  Panama and Colombia said they will talk uninterruptedly to resolve a dispute that erupted after Bogota included the Central American nation on its list of tax havens. Panama’s vice president and foreign minister, Isabel De Saint Malo de Alvarado, and Colombia’s foreign minister, María Angela Holguín, delivered… – Continue reading

IMDO Launch Report on Irish Tonnage Tax Opportunities for International Shipping Industry

IrishTonnageTax – The Irish Maritime Development Office (IMDO) has released a report Irish Tonnage Tax: Opportunities for the International Shipping Industry. The Irish tonnage tax regime has been established for over 10 years and offers one of the most competitive on-shore corporate tax rates to international shipping companies. The tonnage… – Continue reading

Irish Budget 2015 – Rate, Regime, Reputation

Our Reaction The Irish Minister for Finance delivered his Budget 2015 (the “Budget”) speech this week. There was considerable domestic and international anticipation in advance of the Budget against a backdrop of significant recovery in the Irish economy and also international focus (including, in particular, under the OECD BEPS project)… – Continue reading

Confusion over Fatca deadline for trusts

High quality global journalism requires investment. Please share this article with others using the link below, do not cut & paste the article. See our Ts&Cs and Copyright Policy for more detail. Emailftsales.support@ft.com to buy additional rights. Trustees of private family trusts are being urged to register with the US tax… – Continue reading

Australia: Project Do It: Disclose unpaid tax from offshore income now

“It is the world’s best tax amnesty, “ says Morris Maroon, Head of the National Tax Team of law firm Rockwell Olivier. “There are only months before the best opportunity to turn foreign wealth tax-clean will come to an end. We will then see if the predictions of a particularly… – Continue reading

Bermuda: Super-Powered Settlors

The reservation or grant of certain powers by settlors has always been possible under Bermuda’s trust law but, historically, there was some uncertainty about exactly how far settlors could go without calling the validity of the trust structure into question. The recently passed Trusts (Special Provisions) Amendment Act 2014 (TAA… – Continue reading

Bombay High Court ruling on taxability of share premium in the Vodafone India case

The much-awaited decision of the Bombay High Court was pronounced on October 10. Transfer pricing adjustment carried out in Shell/Vodafone case has been at the centrestage of every public discussion on Indian transfer pricing legislation. The incredulous stand taken by the tax authorities has evoked a strong response from investors… – Continue reading

Ministers reassuring key foreign firms on closure of ‘Double Irish’

Budget measures including new foreign direct investment incentives discussed State agencies and Government Ministers and officials have launched a co-ordinated campaign of letters and phone calls to senior executives of foreign multinationals, to reassure them that Ireland remains a top destination for investment following the budget, Minister for Enterprise Richard… – Continue reading

Nigeria: Transfer Pricing Africa (Part II)

n this second part of our overview of current transfer pricing regulations on the African continent, we focus on relevant provisions in, amongst others, Ghana, Nigeria and Uganda. The Ghanaian Transfer Pricing Regulations, 2012 (L.I.2188) (the Ghanaian Regulations) were introduced by the Ghana Revenue Authority (GRA) on 27 July 2012,… – Continue reading

Why Apple And Google Won’t Care About Irish Tax Law Changes

Ireland has this week moved to change its tax law, closing the “double Irish” tax avoidance technique widely used by multinational enterprises including Google and Microsoft. Picture: Getty Images In very broad terms, the current Irish tax law allows a company incorporated in Ireland to be a tax resident of… – Continue reading

Strong rules on transfer pricing on agenda in many countries

AMONG several proposals for tax reform, the director-general of the Revenue Department has said the agency would propose an amendment to the Revenue Code concerning transfer pricing, aiming to provide greater clarity on the determination of fair transfer prices. The director-general has indicated that in past years many multinational companies,… – Continue reading

IRS Modifies Offshore Filing Procedures

The IRS has issued FAQs relating to the new streamlined procedures for offshore compliance, and for Delinquent International Information Return Submission Procedures. The FAQs for the streamlined program provide more detailed guidance on how the 5% penalty will be computed, how 100% owners of an incorporated business will be treated,… – Continue reading

What Does Closing the ‘Double Irish’ Tax Loophole Mean for Pharma?

As the Irish government considers closing an infamous tax loophole for corporations, Wall Street has been scrambling to gauge the effect on the pharmaceutical industry. So far, the prognosis seems that damage will largely be minimal. Known as the ‘Double Irish,’ the loophole allows companies to send royalty payments for… – Continue reading

OECD targets diesel and company cars

Taxes on fuel and corporate benefit need to rise significantly, says agency The Organisation for Economic Co-operation and Development (OECD) has launched a war of words on diesel fuel and company cars, claiming that the taxation levels on both are costing governments billions and seriously harming the environment. “The cost… – Continue reading

Fourth protocol to Canada-UK Treaty eliminates withholding tax on arm’s length interest, but preserves tax exemption for gains on disposition of shares and interests deriving value from Canadian real property

On July 21, 2014, the governments of Canada and the United Kingdom signed the fourth protocol (Protocol) amending the Convention between the Government of Canada and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion… – Continue reading

Harper Government Strengthens Tax Collaboration with India

Minister Findlay meets with Indian counterpart during trade mission to India DELHI, INDIA–(Marketwired – Oct. 15, 2014) – Canada Revenue Agency The Honourable Kerry-Lynne D. Findlay, P.C., Q.C., M.P., Minister of National Revenue, met today with Nirmala Sitharaman, India’s Minister of State for Commerce and Industry and Minister of State… – Continue reading

3rd LD Writethru: EU FinMins agree on taxation information exchange

LUXEMBOURG, Oct. 14 (Xinhua) — EU finance minister meeting concluded on Tuesday with breakthrough in taxation exchange information to fight against tax avoidance. Italian finance minister Pietro Carlo Padoan, whose country holds the presidency of the EU, told press after the meeting that the EU has planned to build a… – Continue reading

Tokyo District Court Allows Tax Saving from Share Repurchase

On May 9, 2014, the Tokyo District Court reversed a large tax that had been imposed on a large U.S. multinational’s Japanese holding company (“Japan HoldCo”). Under the Japanese Corporate Tax Law, if a shareholder returns shares to an issuing company (i.e., the issuing company acquires treasury shares), a portion… – Continue reading

Freeman Tax Law Is The Keynote Speaker About FATCA At The American Chamber Of Commerce In Shanghai

The presentation on October 17, 2014 will discuss how FATCA has changed the world and provide perspectives for financial institutions and expatriates  SHANGHAI, China, Oct. 14, 2014 (GLOBE NEWSWIRE) — via PRWEB – As of June 30, 2014 China has signed Model 1 IGA (Intergovernmental Agreement) in cooperation with FATCA… – Continue reading

Malta Holding Companies 2014/15

Malta, like Cyprus, has been obliged to dismantle its old ‘offshore’ companies regime as a trade-off for joining the European Union. EU membership has, however, brought about certain benefits for Maltese companies trading across borders, and, coupled with investment-friendly government policies and some interesting tax planning opportunities, Malta remains one… – Continue reading

Firms Expect Transfer Pricing Policy Impact From BEPS Project

A vast majority of companies headquartered in the United States expect increased scrutiny of their transfer pricing practices in the short-term as a result of the Organisation for Economic Cooperation and Development’s (OECD’s) base erosion and profit shifting (BEPS) project. A recent EY survey, Connecting The Dots, concluded that 30… – Continue reading

Monaco Signs OECD Multilateral Tax Convention

Monaco has become the 84th jurisdiction to commit to strengthen international tax cooperation through its participation in the Multilateral Convention on Mutual Administrative Assistance in Tax Matters. Welcoming the signing by José Badia, Monaco’s Minister for Foreign Affairs and Cooperation, the Organisation for Economic Cooperation and Development’s (OECD’s) Secretary-General, Angel… – Continue reading

International tax avoidance: Is it eroding Canada’s tax base and how should we respond?

TORONTO , Oct. 2, 2014 /CNW/ – Aggressive international corporate tax avoidance by multinational corporations has become the subject of intense political scrutiny. U.S. politicians have called out some American multinationals, including Apple, Amazon, Starbucks and Google, for relocating profits abroad to avoid U.S. taxes. More recently, politicians accused Burger… – Continue reading

UPDATE 3-Ireland calls time on austerity, “Double Irish” tax dodge

* Ireland to end tax regime that saved multinationals billions * Swift upturn ushers in tax cuts rather than austerity * Government faces backlash over uneven nature of recovery (Adds finance minister interview, Google comment) By Padraic Halpin and Conor Humphries DUBLIN, Oct 14 (Reuters) – Ireland will phase out… – Continue reading

Swiss pledge to review business taxation

The Swiss finance minister, Eveline Widmer-Schlumpf, and her counterparts from European Union member states have signed a joint statement aimed at ending a controversy over corporate taxes. The declaration, signed in Luxembourg on Tuesday, includes the Swiss government’s plans to push ahead with abolishing certain preferential tax regimes for foreign… – Continue reading

Tax relief scheme for tech firms under threat from Europe

Hitech firms are being warned that they should take advantage of tax relief on patent related profits now before a threatened clamp down by the European Union according to Richard Hopes, Partner at Alliotts accountants based in Surrey and London. Richard Hopes, Partner at Alliotts accountants and a specialist in… – Continue reading

The Big Picture: Wealth and Estate Planning in Argentina

It is said that Argentina faces an economic and political crisis every 10 years. Whenever a crisis arises, Argentinians’ right of ownership is at risk. Devaluation, asymmetric pesification and the current foreign exchange restrictions are a few examples of the challenges we face. What’s more, according to a recent OECD… – Continue reading