Countries that work together like Ireland and the US “need to be cognisant” of the impact their tax policies have on each other, new US Ambassador to Ireland Kevin O’Malley said in a speech yesterday. He said cross-border mergers can make the Irish and American economies stronger, but that “these… – Continue reading
On June 18, 2014, the Internal Revenue Service introduced significant changes to both its Offshore Voluntary Disclosure Program (OVDP) and its Streamlined Filing Compliance Procedures (Streamlined) and posted updated Frequently Asked Questions on its website.1 These changes apply to new OVDP “submissions” (which most practitioners believe refer to the Offshore… – Continue reading
Irish Finance Bill 2014: Last Sunday The New York Times in an editorial following the decision in Budget 2015 to eliminate the Double Irish tax dodge from 2021, said “Ireland, which for years used policies like the Double Irish to attract multinational businesses, appears uninterested in true reform. It will… – Continue reading
In a decision on June 11, 2014, the French Administrative Supreme Court held that a French national residing in Monaco may be subject to social taxes on property income (dividends, interest, property income, etc.) if the French national qualifies as French tax resident under French national law (Article 4 B… – Continue reading
Democratic House and Senate candidates seem likely to lose the votes of a large constituency they rarely think about over a law that most Americans have never heard of. The issue is FATCA — the Foreign Account Tax Compliance Act — passed by Congress and signed into law in 2010…. – Continue reading
On October 15th, 2014 the Minister for Finance announced the Luxembourg Budget 2015. The announcement followed the presentation made the day before by the Prime Minister Xavier Bettel who presented a policy statement entitled “Package for the Future” which provides some overall public finances policy statements for the period 2015… – Continue reading
Estonia will issue identity cards allowing access to its digital services to people residing outside the Baltic nation as it seeks to boost foreign investment. Lawmakers in the capital Tallinn voted unanimously with no abstentions to let foreigners seek e-residence status to be able to set up a company in… – Continue reading
In determining the optimum gateway for investing into India, reliance on industry data may be the most prudent opening gambit. Data released by India’s Department of Industrial Policy & Promotion peg Mauritius and Singapore as the top two destinations through which foreign direct investment and private equity capital is routed… – Continue reading
Senate Finance Committee Chairman Ron Wyden has indicated that, as companies appear to be reconsidering inversions following the administrative measures put forward by the Treasury Department last month, he is focused on reforming the US tax code, rather than pressing for immediate anti-inversion legislation. “While it looks like the rush… – Continue reading
A Residence Programme (“TRP Rules”) has been introduced with effect from 1 July 2013 for individuals who are nationals of the EU, EEA or Switzerland (but not Maltese nationals) in terms of Legal Notice 270 of 2014 and Articles 56(23) and 96 of the (Malta) Income Tax Act, Chapter 123… – Continue reading
The Council agreed last tuesday, at a meeting of the Economic and Financial Affairs Council , on a draft directive extending the scope for the mandatory automatic exchange of information between tax administrations, enabling them to better combat tax evasion and to improve the efficiency of tax collection. The proposal… – Continue reading
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
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
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
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
A million Canadians are migrating to the southern United States for the winter. Before you cross the border, buy travel medical insurance. Learn how U.S. income tax rules affect you if you stay in the U.S. for more than four months. Buy travel medical insurance coverage before leaving Canada for… – Continue reading
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
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
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
* 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
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
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
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
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
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
(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
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
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
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
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
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
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
(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
A good way to build a stronger economy is to create a fairer and more efficient tax code — one that promotes business investment and job creation in the United States. That is why the President has proposed business tax reform that will simplify the tax code by lowering the… – Continue reading
Corporate financial accounting and taxation are complex subjects. For this reason, many people tune out when issues that involve corporate tax practices rise to the level of public debate. Unfortunately, many legislators shy away from these issues for similar reasons. But while corporate taxation can be mind-bogglingly complex, nontax experts… – Continue reading
WASHINGTON/NEW YORK, Sept 23, (Agencies): Tough new US rules on corporate “inversions” on Tuesday sent a chill through the market for the tax-avoidance deals, both pending and potential, with share prices falling sharply in nearly a dozen companies on both sides of the Atlantic. As investors sold stocks involved in inversions,… – Continue reading
India’s desire to have a global system, which will ensure tax-evaders will have no sanctuary anywhere, received a shot in the arm when finance ministers of G-20 nations took a concrete step in this regard. At their meeting in Australia on Sunday, they endorsed a plan to exchange tax information… – Continue reading
Majority Whip Dick Durbin (D – Illinois) and Sherrod Brown (D – Ohio) have introduced a bill – the Pay What You Owe Before You Go Act of 2014 – into the Senate that would require multinational corporations to settle their United States tax bill before using corporate inversions to… – Continue reading
Plans to curb tax avoidance will hit Ireland. Most countries are set to force multinationals to pay more tax and as the political controversy grows, our own role in these activities will come under ever increasing scrutiny On Tuesday the OECD, the Paris-based club of the world’s richest economies, published… – Continue reading
GORDON BROWN AND DAVID CAMERON HAVE PROMISED GREATER DEVOLUTION OF TAX AND WELFARE POWERS TO SCOTLAND. With the amount of coverage for the Scottish vote today it can’t have gone unnoticed that Scotland is remaining a part of the UK – for now. But that doesn’t mean that there aren’t… – Continue reading
While Senate Democrats continue to examine specific legislative proposals to deter US multinationals from using corporate inversions to move their tax residence abroad, Republicans remain insistent that any specific anti-inversion legislation should be explicitly linked to comprehensive tax reform. A new bill has been put forward by Charles Schumer (D… – Continue reading
On September 16, 2014, the Organisation for Economic Co-operation and Development (OECD) released its first seven of 15 deliverables under the OECD/G20 base erosion and profit shifting (BEPS) project (the 2014 BEPS Package). The 2014 BEPS Package arises from the Action Plan on Base Erosion and Profit Shifting (the BEPS Action Plan),… – Continue reading
The Obama Administration, along with a couple senators, have been leading a campaign of moral indignation against “inversions.” In tax terms, inversions are a U.S. incorporated company changing its residence to a lower tax country to reduce the tax burden on its income. Because U.S. companies are taxed in the… – Continue reading
Now that we have new cabinet ministers to drive the economy forward, the next expectation is for martial law to be lifted so that foreign investors and tourists can feel more comfortable about returning to Thailand. Meanwhile, the junta is determined to quickly show the people some signs of genuine… – Continue reading
A recent Tax Court decision1 addressed the tax consequences to a Finnish citizen of wages she received while working as an employee in the United States on behalf of her country’s Permanent Mission to the United Nations. The case involves Sole Abrahamsen, a Finnish citizen, who began working at Finland’s Permanent… – Continue reading
From 6 April 2013 an individual’s residence status for UK tax is determined using the statutory residence test (SRT). The SRT flowchart overleaf is designed to assist in determining the residence status of individuals. The legislation and guidance is lengthy and the flowchart and notes can only give a brief… – Continue reading
A ruling by the European Court of Justice that Spanish inheritance tax breaks the law by charging more to foreigners, could lead to a change in Spanish property taxation, lawyers believe The European Union’s highest court has ruled that Spanish inheritance tax breaks the law by charging foreigners more –… – Continue reading
Alex Lemond is among a new wave of New Yorkers trading in their Manhattan condominiums for beachside villas in Puerto Rico. The former hedge fund honcho moved to San Juan from New York last year, and his company, the Encanto Group, is investing hundreds of millions of dollars in developing… – Continue reading
