Category: Tax Laws

When FATCA Meets FIRPTA: Some Preliminary Comments

In view of the frenzy in the profession over compliance with the new FATCA rules, it seems appropriate to take an overview of how FATCA applies to a major source of inbound investment by foreign individuals – “FIRPTA” investments in U.S. real property. This commentary considers the extent to which… – Continue reading

Manny Pacquiao Ordered To Explain His Taxes In Court: Is Pacman Now Taxman?

On top of his many boxing titles, including world championships in eight weight classes, Manny Pacquiao is on tap for a possible Senate seat in 2016. First, he has to get his taxes resolved. The Supreme Court of the Philippines ordered the boxing champ and potential Senator to answer the… – Continue reading

Amazon faces European Union tax avoidance investigation

Amazon, the online retailer, is to face a formal investigation into its European corporate tax practices, the European Commission has announced. The Commission – the executive division of the 28-member European Union – says it will look at the tax agreement made between Amazon and Luxembourg. It suspects the deal… – Continue reading

Canada: Tax Court Of Canada Allows Foreign Tax Credit Generator Arrangement

Major changes have occurred with respect to foreign tax credit (FTC). The Department of Finance announced in the federal budget of March 4, 2010, a proposed legislation regarding FTC generators (FTCG) and released modified draft legislation on August 27, 2010. These new FTCG rules target the FTC per subsections 126(4.11)-(4.13)… – Continue reading

Manny Pacquiao Ordered To Explain His Taxes In Court: Is Pacman Now Taxman?

On top of his many boxing titles, including world championships in eight weight classes, Manny Pacquiao is on tap for a possible Senate seat in 2016. First, he has to get his taxes resolved. The Supreme Court of the Philippines ordered the boxing champ and potential Senator to answer the… – Continue reading

Death & Taxes: Bloomberg BNA’s 2014 Trust Nexus Survey Reveals Significant Issues for Unsuspecting Practitioners, Particularly Double Taxation

Double taxation of trust income is a very real problem. The issue arises because trusts are subject to state income taxes on their entire income when they are classified as resident trusts under a taxing state’s law. Each state has its own definition of “resident trust,” which leads to the… – Continue reading

OECD bolsters relationship with Ukraine

7/10/14 – The 34-member countries of the Organisation for Economic Co-operation and Development (OECD) welcomed a Memorandum of Understanding (MOU) between the OECD and Ukraine which will help Ukraine’s efforts to tackle corruption, strengthen its tax system and promote competitiveness. Announced today in Paris, the MOU seeks to tap OECD… – Continue reading

Ireland’s tax regime nurtures innovation in avoidance

A tax-based industrial policy will not produce an innovative economy, writes James Stewart 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/bde702e4-4d5e-11e4-bf60-00144feab7de.html#ixzz3HKJXRQha Irish… – Continue reading

US delegation calls for repeal of FATCA

(CS) As part of a European tour organised by Republicans Overseas, US Senator Mike Lee on Tuesday visited Luxembourg to rally support for the repeal of the Foreign Account Tax Compliance Act, more commonly known as FATCA. Luxembourg and the US signed FATCA as an inter-governmental agreement in March this… – Continue reading

Washington resists Hockey’s tax crackdown on Silicon Valley giants

OHN KEHOE The global tax plan being pursued by Australia as G20 president, to compel low-tax paying multinationals such as Google and Apple to ­contribute more revenue to government coffers, could be derailed by political resistance in the United States. A prominent US senator in congress who would likely become… – Continue reading

Korindo head probed for alleged tax evasion

By Jung Min-ho Seung Eun-ho Chairman of Korindo Group Prosecutors are investigating allegations that the head of Korindo Group, a Jakarta-based conglomerate, and his sons have evaded taxes. The Seoul Central District Prosecutors’ Office said Monday that the group’s Chairman Seung Eun-ho and his two sons are suspected of evading… – Continue reading

The Italian approach to intercompany loans

The Italian tax authorities have been intensifying their focus on transfer prices involving financial intercompany transactions such as loans. Multinational corporations frequently resort to such transactions to optimise and rationalise the financial management of the entire group. In certain cases, the said optimisation tools pertaining to intercompany financial resources may… – Continue reading

Asia-Pacific’s developing nations raise low govenment revenue: United Nations

NEW DELHI: Developing countries in Asia Pacific region are less successful in raising government revenue but greater regional cooperation can strengthen resource mobilisation, a report has said. “Countries across the Asia-Pacific region have significant potential for enhancing tax revenues … taxation is primarily a domestic policy issue, there are also… – Continue reading

UK government promises early consultation on new multinational tax avoidance rules

The UK government will shortly set out how it plans to implement globally agreed rules to prevent multinational companies from using artificial techniques to significantly reduce their tax bills, it has announced.06 Oct 2014 Tax Tax Disputes and Investigations UK Europe It has confirmed that it will consult on the… – Continue reading

United States: International Tax Alert – FATCA – Fund Managers: Be Aware Of Upcoming Deadlines

Fund managers the world over are facing the reality of the U.S. Foreign Account Tax Compliance Act (“FATCA”), encountering requests from U.S. withholding agents for FATCA documentation from funds and inquiries from potential investors regarding the status of FATCA compliance. A fund manager, tasked with assessing the FATCA status and… – Continue reading

Tax probes into wealthy foreigners stepped up

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/b2926d28-4b08-11e4-b1be-00144feab7de.html#ixzz3FSimy6uT The UK tax authority has significantly increased the amount of extra money it obtains… – Continue reading

Tax probes into wealthy foreigners stepped up

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/b2926d28-4b08-11e4-b1be-00144feab7de.html#ixzz3FSimy6uT The UK tax authority has significantly increased the amount of extra money it obtains… – Continue reading

Osborne proposals for anti-abuse tax rules could damage UK competitiveness, expert warns

Plans to tackle UK tax avoidance by international technology companies could damage UK competitiveness if they are brought in before international measures are finalised, a tax law expert has warned.02 Oct 2014 Corporate tax Tax Tax Disputes and Investigations TMT Advanced Manufacturing & Technology Services UK Europe Heather Self of… – Continue reading

‘Earnings stripping’: The next tax-dodging strategy in Obama’s crosshairs?

When the Obama administration clamped down last month on companies that reincorporate abroad to escape high U.S. taxes, it did not address a tax-dodging technique known as “earnings stripping,” leaving some to wonder if it is the next target. Earnings stripping is widely practiced and covers a range of financial dealings that… – Continue reading

Osborne bid to fight tax avoidance ‘may empty, not swell, state coffers’

British chancellor George Osborne’s promise to clamp down on a tax avoidance loophole widely used by multinational technology companies could actually result in a reduction in the amount of money the government takes in, the Chartered Institute of Taxation has warned. Patrick Stevens, the group’s tax policy director, admitted the… – Continue reading

EU’s investigation into Fiat deal an ‘all-out attack’ on Luxembourg’s tax practices

BRUSSELS : The European Union’s tax investigation of Luxembourg focuses on a single unit of the Italian auto company Fiat. But the implications of the inquiry could in some ways be more far-reaching for multinational companies and their tax accounting than the bloc’s separate Apple-Ireland inquiry, experts said Tuesday. “I… – Continue reading

Prada chiefs in tax evasion probe

Troubled Italian fashion giant Prada stonewalled questions over its tax affairs on Monday after it emerged that its top two executives are being investigated for allegedly not disclosing many millions in overseas earnings to Italian authorities. Chinese fashion titans look to Italy for value (29 Sep 14) Global fashion circus… – Continue reading

eBay pays just £620,000 tax on £1.3bn sales

eBay accused of tax avoidance, but insists it complies with letter of the law By Emma Woollacott, Sep 29, 2014Updated: September 30, 2014 7:24 AM Online auction site eBay got away with paying just £620,000 in tax on sales of over £1.3 billion last year, its latest accounts reveal. The… – Continue reading

Transfer pricing, tax evaders and IT: HMRC UK to assist FBR on tax reform initiatives

Her Majesty’s Revenue and Customs (HMRC) UK will assist Federal Board of Revenue (FBR) on tax and customs reform initiatives encompassing development of special skills to identify cases of transfer pricing, techniques to catch tax evaders and use of IT to control tax avoidance. It is learnt on Monday that the… – Continue reading

It’s Very Difficult To See How George Osborne’s Google Tax Could Possibly Be Legal

George Osborne, the Chancellor of the Exchequer over here in the UK, has just announced at the Conservative party conference that he’ll be changing the tax laws to make sure that Google GOOGL +0.16% and other tech multinationals (Facebook, Microsoft MSFT -0.17%, possibly Apple AAPL +0.64%, among them) end up… – Continue reading

Tax shelter shake-up hits home

A federal crackdown and a new act make life tougher for lawyers and accountants. Criminal tax attorney Robert Fink views the conviction and sentencing of his client Dr. Michael Canale—on tax fraud charges in New York state federal court in 2012—as representative of everything that’s wrong with the government crackdown… – Continue reading

United States and Brazil Sign FATCA Intergovernmental Agreement

The United States and Brazil have signed a “Model 1” intergovernmental agreement (“IGA”) with respect to the US Foreign Account Tax Compliance Act (“FATCA”). The Brazilian IGA is intended to simplify FATCA information reporting and reduce compliance burdens for Brazilian financial institutions.

How is Google Inc (GOOGL) Paying Service Tax and Facebook Inc (FB) Not Paying Any Taxes in India: Delhi High Court

Google Inc (NASDAQ:GOOGL) and Facebook Inc (NASDAQ:FB) are conducting their business operations in India. Former BJP leader, Govindacharya has filed a case, raising concerns against the usage of e-mail  services by offshore providers for official purposes by government officials. His Public Interest Litigation (PIL) also mentioned the tax evasion by… – Continue reading

Big business ‘shirks’ fair share of tax load

Almost a third of Australia’s largest companies are paying less than 10¢ in the dollar in corporate tax, a report that exposes a gaping hole in government revenues over the past decade shows. As Australia prepares to host world leaders at the G20 summit in Brisbane in November, where a… – Continue reading

Europe to probe Apple further over Irish tax deals

European regulators are set to examine whether Apple violated EU law by striking special tax deals with the Irish government. The European Commission opened an initial investigation into Apple’s tax affairs in June, looking at whether the company’s two percent tax rate in Ireland — far less than the standard 12.5… – Continue reading

Philippines signs convention to fight tax evasion

MANILA, Philippines – The Philippines has signed a multilateral agreement to boost its efforts in fighting tax evasion and improving compliance of taxpayers. Bureau of Internal Revenue (BIR) Commissioner Kim Henares, through special authority from the Office of the President, signed the Convention on Mutual Administrative Assistance in Tax Matters… – Continue reading

Osborne plans crackdown on tech groups with new anti-avoidance rules

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/f0564d62-4803-11e4-b5ad-00144feab7de.html#ixzz3EsBYd5vW Technology companies “that go to extraordinary lengths” to cut their tax… – Continue reading

Osborne vows crackdown on tax-avoiding tech firms

(Reuters) – British finance minister George Osborne said on Monday he was examining changes to clamp down on tax avoidance by multinationals which the government says are depriving Britain’s public coffers of hundreds of millions of pounds each year. “Some technology companies go to extraordinary lengths to pay little or… – Continue reading

New tax-dodge rules prompt AbbVie to seek more Shire financing: sources

(Bloomberg) — AbbVie Inc. is examining plans to raise additional financing to complete its takeover of Shire Plc, after U.S. officials imposed new obstacles to so-called tax inversion deals, people with knowledge of the matter said. AbbVie may seek to borrow as much as $7 billion more than it originally… – Continue reading

Another view: Low tax rates no way to build economy

Canada should not count on building its economy by luring U.S. multinationals over the border with low tax rates in light of an announcement from the U.S. Treasury Department this week. The department outlined new measures to block companies from escaping U.S. taxes by moving earnings outside the country. This… – Continue reading

Germany may close foreign ‘patent box’ tax loophole: report

German Finance Minister Wolfgang Schaeuble is working on closing a tax loophole whereby German firms use so-called “patent box” tax breaks available abroad on profits generated from patented research to minimize tax bills, according to a magazine report. Business weekly Wirtschaftwoche said a potential new restriction on the practice, similar to one in… – Continue reading