Contrary to FATCA, accounts under $50,000 have been disclosed The Canada Revenue Agency has been transferring information about Canadian bank accounts worth under $50,000 U.S to the U.S Internal Revenue Service but cannot say how many accounts below that threshold have been shared with the Americans. Under a controversial information-sharing… – Continue reading
Hundreds of policymakers, business executives, and senior tax officials met at the OECD International Tax Conference to discuss the recommendations proposed under the base erosion and profit shifting (BEPS) project and their impact on trade and investment. The conference, which was held in Washington DC on June 6-7, 2016, was… – Continue reading
Multinational companies doing business in Italy, Italian companies doing business abroad and non-resident companies which intend to invest in Italy may use the new international tax ruling procedure to reach an advanced agreement with the Italian Tax Authorities regarding the taxation of income derived from cross-border transactions. Recently, Legislative Decree… – Continue reading
HMRC believe that that they have turned a corner in catching companies trying to avoid paying corporation tax after subjecting large businesses “to an exceptional level of scrutiny”. Data released following a Freedom of Information Act request by UHY Hacker Young showed 15 per cent decrease in the number of… – Continue reading
A CLAMPDOWN on tax planning, a transformation of its services for taxpayers and delivering a professional, efficient and engaged organisation are the three key objectives for HMRC in its updated single departmental plan. The government department has outlined its main visions and objectives for the period between 2015 and 2020,… – Continue reading
Asia Pacific The January – March edition of tax highlights for the Asia Pacific region highlights industry developments from Australia, China, Hong Kong, India, Indonesia, Korea, Malaysia and Singapore including: Australia’s new tax system for Managed Investment Trusts The final stage of China’s B2V reform to be rolled out from… – Continue reading
The EU’s Economic and Financial Affairs Council (ECOFIN) has been unable to reach agreement on the European Commission’s proposed anti tax avoidance directive. The issue has therefore been postponed until the next ECOFIN meeting in June. The European Commission announced its proposed anti-tax avoidance directive (ATAD) in January. The proposed… – Continue reading
NEW DELHI: While seeking information from a foreign country in connection with black money stashed abroad by Indians, the CBDT has decided to refrain from invoking a specific treaty clause of not informing the person, except in special cases, in a bid to avoid delays. The clause called “refrainment from… – Continue reading
Sweden will appoint an inquiry to study whether tax advisers should be required to inform the Swedish Tax Agency about tax planning schemes as part of an action plan to combat tax avoidance, which also urges companies to maintain their own tax policies at board level. According to the Government,… – Continue reading
Bank of Ireland has lost a £27m (€34.2m) tax avoidance case in the UK after an attempt to exploit a loophole that did not exist. HM Revenue and Customs challenged the attempt to avoid corporation tax by Bank of Ireland through a subsidiary, the former building society Bristol and West,… – Continue reading
The tax treatment of non-domiciled individuals is changing again from April 2017. The changes were first announced in the 2015 Summer Budget, and a Consultation document was issued in September 2015 setting out further details. The proposed changes target three key areas: The taxation of non-domiciled individuals who have been… – Continue reading
US disregarded entities owned by foreign persons would be treated as domestic corporations under regulations proposed by the US Internal Revenue Service (IRS) on Friday (REG-127199-15). The new rules would apply for purposes of the reporting, record maintenance, and other compliance requirements that apply to 25% foreign-owned domestic corporations under… – Continue reading
Hot off the heels of the Panamanian documents leak, 5 EU countries announced last month that they have agreed to exchange beneficial ownership information. France, Germany, Italy, Spain and the UK will now automatically exchange information on the ultimate beneficial owners of companies and trusts. These 5 EU countries are… – Continue reading
The UK Government has launched a consultation on plans to make the disclosure of value-added tax avoidance schemes (VADR) system more closely resemble the Disclosure of Tax Avoidance Schemes (DOTAS) regime. According to the consultation, “VADR should be more closely aligned with DOTAS to provide early information on new avoidance… – Continue reading
The government of the British Virgin Islands (“BVI”) has recently clarified the filing deadlines under the various automatic exchange of information regimes in a number of bulletins and press releases. UK FATCA / UK CDOT The BVI government has advised that BVI Reporting Financial Institutions will be able to enrol… – Continue reading
On January 27, 2016, 31 Countries (among them Mexico) signed the Multilateral Competent Authority Agreement for automatic exchange of Country-by-Country reports (the “Agreement”) to be received from their taxpayers as part of the implementation of Action 13 of the Base Erosion and Profit Shifting Action Plan issued by the Organisation… – Continue reading
Each year the IRS comes out with a list of the most notable tax scams, informing the public on what to be on the lookout for come tax season. Each year the IRS comes out with list of tax scams called the Dirty Dozen, which is used to bring public… – Continue reading
THE OECD, IMF, World Bank and the UN have formed a platform for collaboration on tax to improve tax systems around the world and strengthen BEPS’ grip on developing nations. Designing and implementing standards for international tax matters is high on the agenda for the new platform, with the four… – Continue reading
Genesis of CbC Reporting and How it will Affect U.S. Multinational Enterprises Country-by-country (CbC) reporting is essentially exactly what it sounds like: a report that shows every country where a multinational enterprise (MNE) operates and allocates income, earnings and pays taxes. The CbC report regulations proposed by the Internal Revenue… – Continue reading
The French taxman, Le Fisc, has apparently decided to send McDonald’s MCD -0.24% France a tax bill for €300 million ($341 million). It’s not entirely obvious that this is a correct demand: nor, in fact, necessarily a legal one. If there were no European Union and no rules about the… – Continue reading
In amove towards a more progressive taxation policy the revenue officials have set an aggressive target of resolving about 100 transfer pricing issues by signing advance pricing agreements (APAs) with multinationals this fiscal, people close to the development said. The government, through the Central Bureau of Direct Taxes (CBDT), had… – Continue reading
Overview If you have been reading my articles on JD Supra for a while, you will know that I love Afro-Cuban and Brazilian music. Nevertheless, the Hall and Oates song Private Eyes, is a more fitting song to describe the state of offshore planning in Tax Havens than “Oye Como… – Continue reading
The Revenue has published its consultation on proposing to make companies criminally liable for failing to prevent their staff facilitating tax evasion The offence was first proposed in the 2015 Budget and was expected to come into effect in 2020. The Panama papers leak and subsequent scandal has put significant… – Continue reading
To provide relief to corporates having income abroad, the tax department today proposed simplified ‘Foreign Tax Credit’ rules allowing companies to claim credit for taxes paid overseas. The Central Board of Direct Taxes (CBDT) in its draft FTC rules said tax credit will be available to entities paying taxes in… – Continue reading
Firms waiting for govt to come out with revised safe-harbour rules Although the conclusion of ahead-of-time transfer pricing agreements gained momentum in FY16, applications foradvance pricing agreements (APAs) with the tax authorities fell to the lowest in four years at 130. This could be attributed to companies, especially those in… – Continue reading
HMRC complicite in tax avoidance scheme after it emerged it rents its own office from tax haven based company A day on, the world is still reeling from the revelations of the Panama Papers leak, the full repercussions of which are yet to be felt. Eleven million documents leaked from… – Continue reading
Most small and mid-sized companies can qualify for tax incentives if they claim to be developing, engineering, designing, modifying, researching or evaluating new products or product alternatives. Among those incentives is the research and development tax credit. The R&D credit is a way for companies to access cash and reduce… – Continue reading
The Panama Papers–the biggest leak of financial data in history–has blown the lid off offshore tax havens, again. This time, those in the limelight include twelve current or former world leaders, many celebrities, and wealthy persons who are using offshore tax havens to hide their wealth. In scope, this is… – Continue reading
Is there a serious risk that Scotland’s tax revenues would be hit hard by people fleeing south to avoid the new top rates of tax advocated by Labour or the Scottish Greens? HM Revenue & Customs is not convinced that there is. With a new Scottish rate of income tax… – Continue reading
The tax world is clearly becoming more interconnected and globalized with countries exchanging financial information about each other’s citizens through FATCA or the upcoming Common Reporting Standard (CRS). Every international decision a taxpayer makes – whether or not he or she is residing in the U.S. – can trigger something,… – Continue reading
The proposed Article 26 (exchange of information) of the convention on Avoidance of Double Taxation, being renegotiated between Pakistan and Switzerland, would bound the Swiss tax authorities to exchange all requested information, including confidential bank account information of Pakistanis maintaining Swiss accounts. Sources told Business Recorder here on Tuesday that… – Continue reading
Investors alerted to risks of higher payments as crackdown closes loopholes A global crackdown on tax avoidance has forced a surge of warnings by multinational companies that higher payments are set to hit their earnings. A Financial Times analysis of company filings revealed that more than twice the number of… – Continue reading
The Swiss Federal Administrative Court has ruled that no administrative assistance can be provided by Switzerland in response to a group request submitted by the tax authority in the Netherlands (in decision A-8400/2015). In upholding the appeal by a Dutch client of Swiss bank UBS, the court blocked the request… – Continue reading
US President Barack Obama’s Foreign Account Tax Compliance Act (FATCA) is really starting to bite on American taxpayers and expats with offshore bank accounts and investments. FATCA came reached the statute books in 2010, but did not come into force until July 2014. The law calls for hundreds of thousands… – Continue reading
Indonesia hopes its plans for a tax amnesty will dissuade companies from channelling profits through overseas tax havens and shopping around for the most advantageous tax treaties, its finance minister said on Wednesday. Bambang Brodjonegoro said he suspected Indonesian firms of setting up “special purpose vehicles” (SPVs) to benefit both… – Continue reading
In March 2010, the FATCA was enacted in the United States (“US“) for the purpose of preventing the non-compliance of US persons with US taxation laws through the participation and cooperation of foreign governments and financial institutions. FATCA Implementation in Malaysia On 30 June 2014, Malaysia reached an agreement in… – Continue reading
The Internal Revenue Service is offering up to $10,000 to the winner of a new competition to make its online tax information more understandable to taxpayers. The IRS issued a notice Tuesday outlining the requirements and procedures for the Tax Design Challenge, a crowdsourcing competition with cash prizes that the… – Continue reading
This article’s title may be shocking and antagonize Indonesia’s staunch position of opposing tax evasion by way of tax havens. But, let’s look deeper. While there is no standard definition of a tax haven, it is generally defined as a state, country or territory where tax rates are very low… – Continue reading
The American Institute of CPAs has written to the Internal Revenue Service recommending some changes in the IRS’s proposed regulations for country-by-country reporting by multinational corporations of financial information to curb tax avoidance. The proposed regulations were issued last December as part of an effort by the Organization of Economic… – Continue reading
Ireland’s 12.5 percent corporate tax rate has encouraged several major U.S. companies like Medtronic, Pfizer, Johnson Controls, and Baxalta to move there in tax inversions in recent months, saving them billions of dollars of taxes and protecting themselves from international competition in the process. The U.S. corporate tax rate, on… – Continue reading
The Knesset Constitution, Law and Justice Committee on Sunday advanced a bill to link tax evasion with money laundering. The bill would set certain types of tax evasion acts as predicate offenses, meaning they would be considered as part of the larger crime of money laundering. The bill, backed by… – Continue reading
Switzerland is barred from helping the Netherlands in a tax case that centres on a Dutch client of UBS (UBSG.S) after a Swiss court ruled that requested details were too broad to be covered by the information-sharing agreement between the countries. The Swiss Federal Administrative Court sided with a Dutch… – Continue reading
The GAAR guidelines should make it clear that it should be only used as a deterrent against tax avoidance schemes, and not a revenue gathering weapon in the hands of the tax officer. Accordingly, the guidelines should make it explicit that GAAR will be applicable only to artificial, abusive and… – Continue reading
The National Board of Revenue (NBR) has issued a guideline asking its income tax offices across the country to start ‘scrutiny assessment’ of the tax returns submitted for the tax year 2015-16. As per the guideline, the taxmen have to complete the scrutiny assessment known as ‘return process’ by December… – Continue reading
The Government of St. Kitts and Nevis, through its Inland Revenue Department has gone live with Vizor Software’s FATCA & AEOI solution, the FATCA Reporting Portal. Ottawa, Canada (PRWEB) March 17, 2016 Today, Vizor Ltd. announced that the Government of St. Kitts and Nevis has gone live with the Vizor… – Continue reading
HMRC and the Treasury should spend more effort on supporting compliant taxpayers with more considered tax policy and functioning tax legislation, and less on punishing those who have exploited loopholes that they helped create. According to the most recently released figures from HMRC, the taxman has now retrieved more than… – Continue reading
A record high 1,163,229 Report of Foreign Bank and Financial Accounts (more commonly, FBARs) were filed in 2015, up more than 8% from the prior year. That growth, however, is nothing new: FBAR filings have grown on average by 17% per year during the last five years , according to… – Continue reading
President Barack Obama is heading to Cuba next week. When Air Force One lands on that island nation on March 20, Obama will become the first U.S. commander in chief to visit Cuba in 88 years. In advance of that historic visit, which the administration hopes will eventually lead to… – Continue reading
For the last five years, the U.S. has waged a strong battle against offshore tax evasion. In 2010, America began its boldest crackdown with the enactment of the Foreign Account Tax Compliance Act (known widely as “FATCA”). FATCA requires foreign financial institutions (e.g., banks, investment houses, etc.) doing business in… – Continue reading
For several years now Google has been facing what appears to be a case of tax avoidance in the UK, at some point in time, the company went as far saying it did not make any money from business in the UK all in a desperate attempt to pay less… – Continue reading
