Fund managers dealing with funds in Model 1 IGA countries must start focusing now on the application of FATCA to these funds. The U.S. Foreign Account Tax Compliance Act (“FATCA”) is becoming a reality. Fund managers around the world over are facing requests from U.S. withholding agents for FATCA documentation… – Continue reading
In the history of the old west when gun fighters survived a gun fight they might put a “notch” in their pistol as a badge of honor. Well the U.S. Department of Justice can put another notch in its weapon of choice, threat of prosecution” because Deutsche Banks’ Swiss unit… – Continue reading
The IRS updated its streamlined offshore compliance program to provide procedures taxpayers residing both inside and outside the United States should use to participate in the program. The streamlined offshore compliance program is for taxpayers whose failure to comply with requirements to report offshore assets is nonwillful. It is designed… – Continue reading
(Reuters) – Portugal’s government will maintain its budget deficit goal of 2.5 percent of gross domestic product next year and any income tax cuts would depend on clamping down on tax evasion and would only be made after the end of the year, two sources said. Portugal’s center-right government approved… – Continue reading
(Reuters) – Italian Prime Minister Matteo Renzi on Monday promised sweeping tax and spending cuts to help boost growth and jobs next year, as the European Commission considers whether to reject his budget plan for reducing debt too slowly. Speaking to a conference of business leaders, Renzi said he would… – Continue reading
(Reuters) – Italian and Swiss ministers clashed on Monday over the failure to reach an agreement aimed at fighting tax evasion that foresees Switzerland opening up its bank databases to Italian tax authorities. Both Italian Economy Minister Pier Carlo Padoan and Swiss Finance Minister Eveline Widmer-Schlumpf said they spoke on… – Continue reading
Undeclared offshore income and assets must be disclosed by 19 December 2014 The Australian Taxation Office (ATO) is reassuring taxpayers that disclosing under Project DO IT will not give them a “red flag”. Project DO IT, the ATO’s offshore voluntary disclosure initiative, offers considerable benefits to taxpayers who bring their… – Continue reading
Inter vivos and testamentary trusts are used frequently in Canada to implement a variety of estate and tax planning strategies. Over the past few years, however, amendments to Canada’s Income Tax Act (the ITA), and case law have altered the effectiveness of the use of trusts in certain circumstances. In… – Continue reading
Tax authority set a target of 1,165 people a year by 2014/15, but analysis of the last tax year shows it prosecuted just 795 £119.4bn of UK tax went unpaid, avoided or evaded in the financial year 2013/14, with evasion totalling £82.1bn, according to campaigner Richard Murphy. Photograph: Daniel Lynch… – Continue reading
Americans for Tax Reform is one of 20 taxpayer and free market groups from 15 countries which have signed a letter to world leaders to outline their opposition to transnational tax initiatives and any increase or harmonization of excise taxes. In 2012, the World Health Organization proposed to raise certain… – Continue reading
The NDA government is sending a high-level delegation to Switzerland in a bid to persuade them to assist with details of the 700-odd Indians who have bank accounts with the HSBC Bank in Geneva. This is being seen as the last-ditch attempt by the Indian government since the Swiss authorities… – Continue reading
Compliance is China’s latest Hot Topic. Until recently, many Western managers accepted that some flexibility on legal issues was needed to thrive in the complex Chinese legal environment. Practices to strengthen relationships such as luxurious dinners and karaoke evenings, sponsored travel, red-pocket money and the like, have often been regarded… – Continue reading
Moshe Asher is seeking information about accounts in Switzerland belonging to Israelis. The Israel Tax Authority is stepping up it efforts to combat overseas tax shelters for Israelis. Sources inform “Globes” that Israel Tax Authority director Moshe Asher is expected to travel to Switzerland next week in order to meet… – Continue reading
It is time for an inquiry into HMRC’s competence, policy, decision-making processes and duty to provide transparency Thomas Paine’s observation that what first was plunder later assumed the name of revenue is well-understood by those who have chosen to make their living abroad. Individuals move for various reasons: career development,… – Continue reading
Tax Justice Network Africa, which campaigns against harmful tax policies that favour the wealthy and perpetuate inequality, has moved to the High Court to stop a double-taxation treaty between Kenya and Mauritius. Mauritius is a popular tax haven for companies with multinational operations, tilting scales against countries that sign bilateral… – Continue reading
The Internal Revenue Service announced changes to one of its limited-amnesty programs for U.S. taxpayers with undeclared offshore accounts. The revisions are to the “streamlined procedure,” which was announced in June and is for taxpayers who weren’t intentionally hiding money abroad. Participants in the streamlined program who live in the… – Continue reading
Say judge may find evidence inadmissible because it was supplied by a whistleblower As the AFIP tax bureau starts reviewing information it recently obtained from the French government on undeclared bank accounts held by Argentines in Switzerland, tax experts have warned that using the data might be harder than it… – Continue reading
Ireland’s finance ministry officials are weighing phasing out a tax device used by multinational companies including Google Inc., according to a person with knowledge of the matter, as the European Union looks into the practice. Ireland is considering whether to eliminate a technique known as the “Double Irish,” which allows… – Continue reading
A tax civil society has sued National Treasury Secretary Henry Rotich over an ‘illegal’ agreement signed with Mauritius, in a major litigation that could affect thousands of companies operating in Kenya. The suit filed at the High Court by Tax Justice Network-Africa (TJN-A) demands that Rotich withdraws a taxation treaty… – Continue reading
* Dublin set to change tax residency rules in Oct. 14 budget * Companies already in Ireland to be given time to adjust * Measures due to be signed off by cabinet next Tuesday By Padraic Halpin DUBLIN, Oct 10 (Reuters) – Ireland is set to announce legal changes next… – Continue reading
Introduction Action 1: the digital economy Action 2: hybrid mismatch arrangements Action 5: harmful tax competition Action 6: preventing tax treaty abuse Action 8: guidance on transfer pricing and intangible assets Action 13: transfer pricing documentation and country-by-country reporting Action 15: developing a multilateral legal instrument Next steps Introduction On… – Continue reading
This week brings a wealth of news in the FATCA arena, which we summarize in today’s post. First, former acting IRS Commissioner Steven Miller speaks out against FATCA and suggests that the benefits of the new information reporting regime imposed by FATCA may not outweigh its costs. An article published… – Continue reading
The meeting took place at the official residency of the Egyptian ambassador, in Brasília, and focused on ways to further trade ties between Brazil and the Arab countries. Marcos Carrieri* marcos.carrieri@anba.com.br São Paulo – Ambassadors and chargés d’affaires from 18 Arab countries and the Arab League met last Thursday (9th)… – Continue reading
For a large majority of the ever-increasing number of British expatriates with pensions which remain in the UK, a Qualifying Recognised Overseas Pension Scheme (QROPS) provides a viable and sometimes integral role in retirement planning. This counts for those now residing in Europe, Asia and the Middle East, however arguments… – Continue reading
On October 8, 2014, Swiss officials announced that they intend to negotiate a reciprocal Model 1 FATCA IGA to replace the Model 2 IGA that they signed in 2013. The motivation for the change is unknown, but the automatic exchange of information under Model 1 is more in line with… – Continue reading
Two Canadian women mounting a legal challenge to FATCA have expanded their action to include the Minister of National Revenue as a defendant. Gwen Deegan, a graphic designer from Toronto, and Ginny Hillis, a retired lawyer from Windsor, claim the Canadian federal government doesn’t have the constitutional authority to comply… – Continue reading
TORONTO, Oct. 10, 2014 /CNW/ – The Global Citizen Forum 2014, hosted in Toronto, proved to be a launch platform for significant initiatives. On October 3, 2014, its second day, in front of more than 260 delegates, Mykolas Rambus, CEO, Wealth-X, announced the establishment of the Global Residence and Citizenship… – Continue reading
Advisers should notify their insurers early if they think they may be facing claims from advice to invest in tax avoidance schemes, a professional indemnity insurance (PII) lawyer has warned. Solicitor at commercial claims resolution firm Triton Global, James Field, said acting late could mean advisers risk “falling between the… – Continue reading
NEW DELHI: India and Japan will soon sign an advance-pricing agreement (APA), a move that will provide certainty to investors at a time the country is looking to attract big Japanese investment. “I am happy to mention here that APA between India and Japan in a particular company’s case has… – Continue reading
Both the Securities Industry and Financial Markets Association (SIFMA) and Mindtree, a global technology services company, have pointed out the immense global compliance costs and issues posed by the Foreign Account Tax Compliance Act (FATCA) to the financial services industry. Enacted by the US Congress in 2010, and effective from… – Continue reading
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. Email ftsales.support@ft.com to buy additional rights. http://www.ft.com/cms/s/0/ba95cff0-4fcd-11e4-a0a4-00144feab7de.html#ixzz3G77zeNBz Brussels is challenging the “double Irish” tax avoidance measure prized by big US tech… – Continue reading
There are reportedly about to be major moves in the fight against tax evasion within the European Union. The region’s finance ministers are said to be close to an agreement on automatic sharing of bank data so that the authorities could spot tax dodging or illicit money flows more easily…. – Continue reading
The question has often arisen whether “international law” is an oxymoron – whether “obligations” in income tax treaties and other international agreements are really binding upon the parties, when they are not buttressed by some sort of enforcement mechanism. That question has never been more relevant in the tax world… – Continue reading
As a part of the OECD/G20 project to combat base erosion and profit shifting (“BEPS”), the OECD released the first set of reports and recommendations on September 16, 2014. These reports address seven of the actions described in the 15-point action plan to address BEPS published in July 2013 (the… – Continue reading
Overview I have mentioned in prior articles that I was a Spanish and Portuguese major as an undergraduate. During the time that I was attending law school at the University of Miami, the early 1990’s, the Brazilians had yet to arrive in South Florida in a significant manner. The Brazilian… – Continue reading
The UK Finance Act 2014, enacted in July 2014, contains new legislation to deal with cases of purported tax avoidance, which marks a radical departure from previous policy in this area. Until Finance Act 2014, it was generally the case that where a taxpayer contested a direct tax assessment made… – Continue reading
Colombian and Panamanian finance ministers met on Wednesday to resolve a lingering tax dispute between the two nations. On Tuesday, the Colombian government included Panama in its “gray list” after the Central American nation failed to sign a tax information exchange agreement within the allotted time period. Mauricio Cárdenas and… – Continue reading
The Internal Revenue Department has fined or warned scores of businesses for failing to pay taxes but has yet to file criminal charges against a single tax evader, said Min Htut, its director-general. Fines for tax evasion range from 10-150 per cent of taxes owed, he said, adding that the… – Continue reading
MOSCOW, October 8. /TASS/. The Russian Finance Ministry has drafted a decree that will exclude Malta from the black list of offshore jurisdictions. The decision followed the enactment of the convention between the governments of Russia and Malta of May 22, 2014 on the avoidance of dual taxation and prevention… – Continue reading
OPINION: How often do you hear governments say ‘we’re not sure if it will work, but we’ll give it a shot’? Not a lot, Chalkie would say. Lack of evidence that a policy will produce the desired effect is generally its death knell, particularly if said government was not keen… – Continue reading
The non-legislative measures put forward by the Treasury Department on September 22, to deter multinationals from using corporate inversions to move their tax residence abroad and move away from the high United States tax rate, have so far produced a mixed bag of results. The measures are aimed at preventing… – Continue reading
Changes dateline, updates with Panama’s response) Panama on Wednesday rejected its inclusion on Colombia’s list of tax havens and said it will take retaliatory action against its neighbor. Panama has “a competitive and sound tax system, and therefore the national government categorically rejects any tax-haven designation,” the Central American nation’s… – Continue reading
MOSCOW, October 8. /TASS/. The Russian Finance Ministry has drafted a decree that will exclude Malta from the black list of offshore jurisdictions. The decision followed the enactment of the convention between the governments of Russia and Malta of May 22, 2014 on the avoidance of dual taxation and prevention… – Continue reading
Colombia on Wednesday declared Panama a tax haven for individuals and businesses as the government looks to curb tax evasion and seeks to pressure the Central American country to sign a financial information-sharing agreement. The move could push Colombian investors and businesses to pull out of Panama, since assets stored… – Continue reading
Simon Carter Prime Minister David Cameron pledged at Tory party conference to make tax cuts to assist 30 million “hardworking families”. However, according to tax experts, the main beneficiaries won’t be the claimed 30 million but only the rich. According to the Institute of Fiscal Studies only 15% of the gains from increasing… – Continue reading
HM Revenue and Customs (HMRC) is consulting on draft regulations that will exclude two types of persons from the definition of “promoter” for the purposes of the Promoters of Tax Avoidance legislation. The regulations are intended to meet concerns raised during the development of the primary legislation. They are relieving… – Continue reading
The taxman is willing to “negotiate and strike a balance” with multinationals being audited for transfer pricing misconduct, a drive it says has a potential to realise over Sh30 billion. The Kenya Revenue Authority told a workshop organised by the Association of Chartered Certified Accountants in Nairobi that this will… – Continue reading
Eight of the top 200 companies publicly listed on the Australian stock exchange (ASX200) paid no taxes on profits averaging $50 million to more than half a billion dollars over the decade to 2013! More than 20 (10 percent) corporations paid an average tax rate of five percent or less…. – Continue reading
In Starr International Company, Inc., v. United States, the taxpayer (“Starr International Company, Inc.” or “SICO”) filed a complaint in the United States District Court for the District of Columbia seeking a tax refund from the IRS of approximately $38 million. The refund is allegedly due to an overpayment of… – Continue reading
The relationship between the IRS and Canadians is not great. Groups like the Alliance for the Defense of Canadian Sovereignty want relief from the horrendous double filing and higher taxes Ameri-Canadians often face. Add to that the Canadian suit to block Canada’s FATCA deal with the U.S. It adds up… – Continue reading
