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
For Europeans looking for a slice of the good life, Spain has long been the most popular destination. At the time of the last census in Spain, almost 12% of the country’s population was born overseas, up from less than 1% only a few decades earlier. These days Spain is… – Continue reading
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
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
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
NAIROBI, Oct. 7 (Xinhua) — Kenya and Finland are set to sign a double taxation agreement in order to promote trade and investment relations, a Finnish envoy has said. Finland’s Ambassador to Kenya Sofie From-Emmesberger told Xinhua that a draft agreement has already been prepared and is waiting approval from… – Continue reading
For Europeans looking for a slice of the good life, Spain has long been the most popular destination. At the time of the last census in Spain, almost 12% of the country’s population was born overseas, up from less than 1% only a few decades earlier. These days Spain is… – Continue reading
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
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
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
Over the past few years, the issue of “tax avoidance” has dominated agendas at both Canadian and international tax conferences. The issue has also received considerable news coverage as a result of the actions of certain large companies with complicated tax structures that were seen not to be paying their… – Continue reading
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
On the sidelines of the UN General Assembly in New York yesterday, Latvian Foreign Minister Edgars Rinkevics (Unity) met with the economy minister of Qatar Sheikh Ahmed bin Jassim Al Thani, during which the two sides signed an agreement on the avoidance of double taxation, LETA was informed by the… – Continue reading
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
PORT LOUIS: Mauritius has provided details on majority of information requests received from Indian authorities in the last one year, according to a government official. India has concerns that Mauritius, which is one of the top sources of foreign direct investments into the country, is being used for round-tripping of… – 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
European Union Tax Commissioner Algirdas Šemeta has welcomed a raft of new measures to combat international tax avoidance, in agreement between the finance ministers of the G20 at a meeting in Cairns, Australia. The ministers have agreed on a several recommendations that were made to address key areas which were… – Continue reading
PORT LOUIS: Dispelling ‘misperceptions’ that Mauritius is a tax haven, its financial sector regulator has said the island nation is in discussions with India to address concerns and make changes to the bilateral tax treaty. Emphasising that the country provides stability and predictability for investors, Mauritius’s Financial Services Commission (FSC) sought to… – Continue reading
Prime Minister Narendra Modi is expected to rollout a red carpet for investors during his visit to the US at a time when his ambitious “Make in India” campaign, which is aimed to turn the country into a global manufacturing hub, needs huge investments. In meetings over the past month… – Continue reading
ABU DHABI: President His Highness Sheikh Khalifa Bin Zayed Al Nahyan has issued a number of federal decrees with respect to ratifying agreements with a number of brotherly and friendly countries and setting up new consulates abroad. The decrees were published in the recent issue of the federal official gazette.Khalifa… – Continue reading
The Swiss Federal Council has launched a consultation on changes to the flat-rate tax credit, which seeks to ensure double tax relief for permanent establishments of companies that are located in Switzerland. The proposed change affects permanent establishments in Switzerland that are part of a company domiciled in a country… – Continue reading
The French and Luxembourg governments have signed a new amendment to the French-Luxembourg tax treaty that will significantly impact the investment structures involving Luxembourg vehicles holding French real estate assets. This amendment, signed early in September, will come into force once the ratification process by the respective parliaments of both… – Continue reading
The Organisation for Economic Co-operation and Development (OECD) published a discussion draft in March 2014 on proposals for addressing perceived abuse of tax treaties. The draft recommended extensive changes to the OECD Model Treaty together with suggested domestic law provisions targeted at treaty abuse or abuse of domestic law where… – Continue reading
The Treasury Department today came out with a series of arcane new tax regulations in the hopes of stemming corporate inversions. Inversions happen when U.S. companies merge with a foreign company while usually retaining U.S. operations. Their purpose is to avoid punitive U.S. double taxation on income earned overseas. The… – Continue reading
Brazil signed a tax information exchange agreement with the United States to prevent tax evasion, the South American country’s finance ministry said on Tuesday, a step long sought by businesses that was held up by a spy scandal last year. The pact opens the door to a tax treaty to avoid the double… – Continue reading
The Organisation for Economic Co-operation and Development (OECD) published a discussion draft in March 2014 on proposals for addressing perceived abuse of tax treaties. The draft recommended extensive changes to the OECD Model Treaty together with suggested domestic law provisions targeted at treaty abuse or abuse of domestic law where… – Continue reading
Last week the Tax Foundation released its annual International Tax Competitiveness Index for 2014. The United States ranked 32 out of 34 OECD countries surveyed. Only Portugal and France got lower competitiveness scores, and not by much. As if that were not bad enough, the competitiveness score is only half… – Continue reading
Multinational companies could be robbing Uganda of billions of shillings through double taxation treaties (DTTs), a new survey has revealed. The study, DTTs in Uganda: Impact and Policy Implications, by Seatini Uganda and ActionAid, shows that many companies are extracting resources and selling their goods and services in Uganda, but… – Continue reading
Multinational companies could be robbing Uganda of billions of shillings through double taxation treaties (DTTs), a new survey has revealed. The study, DTTs in Uganda: Impact and Policy Implications, by Seatini Uganda and ActionAid, shows that many companies are extracting resources and selling their goods and services in Uganda, but not… – Continue reading
The issue of international assignees was, for a long time, limited to a small number of companies – meaning only those that operated on an international scale. But in recent years, global expansion has shifted into focus for the larger business community. As a result, the challenges and best practices… – Continue reading
The new global standard, as formulated by OECD in July, would be common for all countries The G20 on Sunday decided to put in place a mechanism for automatic exchange of tax information between various countries by 2017, a development which will help India in dealing with the menace of… – 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
Despite their high payouts, international stocks and funds can come with big tax bills, but there are ways to offset those hefty levies. There is no denying the appeal of foreign equities. The dividend yield on the stocks as of mid-September in the MSCI EAFE Index are more than 3%,… – Continue reading
THE CLAMPDOWN on tax avoidance by multinational corporations has been bolstered by a series of recommendations made by the OECD. Companies including Google, Amazon and Starbucks have been in the firing line for their use of offshore jurisdictions to drive down their UK tax liabilities. In particular, the companies have… – Continue reading
HONG KONG – The government of Hong Kong has recently announced that it will support the Organization for Economic Cooperation and Development’s (OECD) new global standards on the automatic exchange of information for the purpose of enhancing tax transparency and combating cross-border tax evasion. Earlier this year, the OECD released… – Continue reading
Cyprus has accepted a key condition put forward by India on effective exchange of information on tax avoiders Cyprus has accepted a key condition put forward by India on effective exchange of information on tax avoiders, hoping its move, which comes amid continuing talks on amending their mutual tax treaty,… – Continue reading
The Organization for Economic Cooperation and Development has released its first set of recommendations for a coordinated international approach to combat tax avoidance by multinational enterprises, under the OECD/G20 Base Erosion and Profit Shifting Project. The OECD and the Group of 20 finance ministers hope to create a single set… – Continue reading
India has seemingly reached an impasse with both Cyprus and Mauritius over the re-negotiation of their respective double taxation avoidance agreements (DTAA). For the former, the disagreement relates to Cyprus’s status as a notified jurisdictional area (NJA) in India, whilst for the latter, it pertains to the update of their… – Continue reading
A proposed clampdown on global tax avoidance took a step forward on Tuesday with a leading global think tank releasing key recommendations ahead of a G-20 meeting later this month. The practice of companies shifting their profits to other country’s jurisdictions to avoid paying tax has drawn criticism from governments… – 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
Introduction On July 25, 2014, Switzerland and Cyprus signed a new agreement for the avoidance of double taxation (DTA) with respect to taxes on income and capital. It is the first DTA between the two countries, and will contribute to the development of bilateral economic relations. The agreement will come… – Continue reading
With an eye to next year’s federal election, the Harper government has begun to sprinkle tax-relief treats across the country. Small businesses got theirs last week with a break on employment insurance premiums. Sometimes, however, what governments don’t do can be as telling as their actions. The Finance Department has… – Continue reading
New Delhi: Talks between India and Cyprus on amending their bilateral tax treaty appear to be deadlocked over India’s demand to include a limitation of benefit (LOB) clause, which restricts benefits under the agreement to genuine resident investors of the Mediterranean island-nation. As a result, it may take longer than… – Continue reading
Using foreign stocks to diversify your portfolio can be a good move for investors looking to collect dividends and protect capital. But owners of dividend paying foreign stocks can find themselves being hit by another type of tax: foreign dividend withholding tax. Keeping as much of your dividends as possible… – Continue reading
Factors to consider in deciding which type of incorporation is best for you AS TAX LAWS continue to evolve, so do choices of entity. Being mindful of the alternatives is critical to achieving tax benefits. Both S corporations and Limited Liability Companies (LLC’s) are flow-throughs, which have long been a… – Continue reading
The French and Luxembourg Finance Ministers signed, on 5 September 2014, a Protocol amending Article 3 (the “Protocol”) of the France-Luxembourg double tax treaty for the avoidance of double taxation and the establishment of rules of reciprocal administrative assistance with respect to taxes on income and fortune (the “Tax Treaty”)…. – Continue reading
On 5 September 2014, the Governments of France and Luxembourg signed an amendment to the France-Luxembourg treaty dated 1 April 1958 (the “Treaty”), which will have an impact in the future for certain investments in French real estate. Indeed, the amendment introduces new provisions under Article 3 paragraph 4, allocating… – Continue reading
The tax authorities of the United Kingdom and Canada are to deepen cooperation to establish a stronger mutually beneficial relationship, senior officials from both Government have said. Canada’s Revenue Minister, Kerry-Lynne D. Findlay, met with David Gauke, the UK’s Financial Secretary to the Treasury, in London on September 8. Findlay… – Continue reading
On 1 August 2014, the “Provisional Measures on the Collection of Tax on Non-Resident Taxpayers Engaged in International Transportation Business” (2014 No.37 Notice, the “New Regulations”) came into force. The New Regulations could have a significant impact on owners as they seek to streamline and tighten up the regulations in respect of… – Continue reading
The Federal Court has handed down its decision in the case of Task Technology v Commissioner of Taxation in relation to the tax treatment of specific software payments. The case related to payments made by Task to CaseWare International Inc (CWI) for the right to market and distribute CWI software to end users… – Continue reading
