Category: Forms

Why Billions of Dollars in Estate Taxes Go Uncollected

They say the only certain things in life are death and taxes, but a large number of non-U.S. citizens may have found a way to avoid at least one of those. Under U.S. tax law, the estates of foreign holders of U.S. assets, such as stocks, real estate and valuables,… – Continue reading

US Justice Department Announces Banque Bonhôte & Cie SA Reaches Resolution Under Swiss Bank Program

The Department of Justice announced today that Banque Bonhôte & Cie SA (Banque Bonhôte) has reached a resolution under the department’s Swiss Bank Program. The Swiss Bank Program, which was announced on Aug. 29, 2013, provides a path for Swiss banks to resolve potential criminal liabilities in the United States…. – Continue reading

The US Foreign Account Tax Compliance Act; A concern for Ghana?

As of July 15 2015, 55 financial institutions and banks in Ghana have registered themselves to comply with FATCA. So, chances are that if you tried to open a bank account in Ghana, the bank now requires you to fulfil some United States (U.S.) reporting obligations in addition to the… – Continue reading

Critical Guidelines for Taxpayers with Foreign Bank Accounts & Amnesty Program Information

Ayar Law Group speaks about amnesty programs expiring as foreign banks comply with FATCA. Read more: Nov. 2, 2015 / PRZen / VANCOUVER, British Columbia — The unofficial period of grace to reveal foreign bank accounts to the IRS is ending for U.S. taxpayers. Those who don’t comply with… – Continue reading

Israel looks to join int’l anti-money laundering task force

A Financial Action Task Force (FATF) delegation visits Israel this week to consider Israel’s application for membership. “Israel is working tirelessly to upgrade its standing as a regional leader in the struggle against money laundering and financing of terrorism through persistent regulatory changes and a more effective regime. Up until… – Continue reading

Ayar Law Group Releases Critical Guidelines for Taxpayers with Foreign Bank Accounts

Ayar Law Group speaks about Amnesty Programs expiring as foreign banks comply with FATCA. Oct. 22, 2015 / PRZen / DELHI, India — The unofficial period of grace to reveal foreign bank accounts to the IRS is ending for U.S. taxpayers. Those who don’t comply with the law may soon… – Continue reading

Financial Information Month – FATCA

The local implications for the Foreign Accounts Tax Compliance Act (FATCA) are far reaching. So said First Caribbean International Bank (FCIB) representative Norlan Gabriel, who was a panel member on NBC Radio’s “Views on Issues” programme last Sunday. The latest edition of the radio programme was aimed at disseminating information… – Continue reading

China: Discussion Draft For The Implementation Measures For Special Tax Adjustments —A Brand-New Epoch For Transfer Pricing Administration In China

On 17 September, 2015, China State Administration of Taxation (SAT) released the Discussion Draft for the Implementation Measures for Special Tax Adjustments (“Discussion Draft”), as a complete revamp to the existing trial version of the Implementation Measures, i.e., Circular 2. Circular 2 has been serving as a backbone transfer pricing… – Continue reading

IRS Offshore Account Penalties Go Up, More Banks Sign U.S. Disclosure Deal

The number of banks with deferred prosecution agreements with the U.S. government keeps growing. The subject is tax evasion involving American account holders. Today, under FATCA, banks everywhere want to know if you are compliant with the IRS. And the IRS keeps updating its list of foreign banks where offshore… – Continue reading

FACTA and the New Frontier in Offshore Reporting Enforcement

FATCA was passed to prevent U.S. citizens from evading tax by focusing primarily on foreign financial institutions with U.S. account holders. The Foreign Account Tax Compliance Act (FATCA) was enacted as part of the 2010 Hiring Incentives to Restore Employment Act, and its provisions became effective as of 7/1/14. FATCA… – Continue reading

The cost of tax evasion

Tax evasion is a massive global industry. Of every hundred dollars people put in bank accounts and investments, eight are socked away in tax havens such as Switzerland and Singapore, according to work by the UC-Berkeley economist Gabriel Zucman. While only the very wealthy can afford to play this international… – Continue reading

Colleen P. Waddell, Managing Director, Outlier Solutions to Speak at the Knowledge Group’s FATCA Event

New York, NY, September 05, 2015 –(– The Knowledge Group/The Knowledge Congress Live Webcast Series, the leading producer of regulatory focused webcasts, has announced today that Colleen P. Waddell, Managing Director, Outlier Solutions will speak at the Knowledge Group’s webcast entitled: “Latest Regulatory Developments Under FATCA: Best Compliance Practices Uncovered… – Continue reading

FATCA Update: IRS Issues Guidance Regarding Electronic Transmission of Forms W-8 and Updates Information Reporting Guides

The Internal Revenue Service has issued additional informal guidance regarding implementation of the Foreign Account Tax Compliance Act (FATCA). First, the IRS published a new “Frequently Asked Question” on its website addressing form and documentary evidence received by facsimile or email. The text of the guidance, which states that withholding… – Continue reading

US Tax Law Worries for Chinese Families and Companies

The U.S. and China enjoy increasingly strong connections. Yet virtually no Chinese family or business relishes dealing with the Internal Revenue Service (IRS). American tax laws are famously complex, and dealing with the IRS can be like quicksand. Of course, whether they like it or not, U.S. citizens and green… – Continue reading

Tax disclosure programme has some flaws, say experts

HE Voluntary Disclosure Programme introduced in 2012 to encourage taxpayers to regularise their affairs has some flaws that need addressing to be able to expose the real amount of money that has left SA illegally. Tax experts warn that the process in SA is relatively expensive, there are uncertainties because… – Continue reading

Justice Department Announces Two Banks Reach Resolutions under Swiss Bank Program : Banque Pasche SA Will Pay $7.229 Million Penalty and ARVEST Privatbank AG Will Pay $1.044 Million Penalty; Both Continue to Cooperate With Department of Justice

Washington, DC—(ENEWSPF)—July 9, 2015. The Department of Justice announced today that two banks, Banque Pasche SA and ARVEST Privatbank AG, have reached resolutions under the department’s Swiss Bank Program. “Banque Pasche and ARVEST have provided detailed information regarding the ways in which Swiss banks helped U.S. taxpayers conceal foreign accounts… – Continue reading

Putin fishing to pull oligarchs’ cash back to Russia

President Putin coined a new word in his state of the nation address at the end of 2012, when he called for new measures for the “deoffshorisation of our economy”, reports the International Business Times. This was to become a major addition, not just to the Russian vocabulary but to… – Continue reading

Costa Rica, the OECD and FATCA: What You Should Know

Now that Costa Rica has been formally invited to go through the process of becoming a candidate nation worthy of joining the Organization for Economic Cooperation and Development (OECD), financial advisors and legal professionals are starting to ponder how their clients will be impacted by this new chapter in our… – Continue reading

A place in the sun: Retiring overseas requires careful tax planning

Jason Porter explores the tax regimes in Portugal, France, Malta and Cyprus – four of the most advantageous territories for UK ex-pat retirees People aged 55 and over are now entitled to their pension in the form of a lump sum, to be taxed at marginal rates applying in the… – Continue reading

International tax update – UK

Autumn Statement 2014, Budget 2015 and Finance Act 2015 The UK Chancellor delivered his Autumn Statement on 3 December 2014 and his Budget speech on 18 March 2015. For an overview of some of the key announcements, please see our Autumn Statement 2014 briefing and Budget 2015 briefing. The UK’s… – Continue reading

The FBAR tax plight: The maddening implications of when Uncle Sam deems you have signing authority

One million American citizens in Canada face double tax troubles. Max Reed explores these challenges in a spring series. The United States has two tools with which to collect information on accounts held by its citizens, FATCA and FBAR. Lots of attention has been paid to FATCA, less so to… – Continue reading

British Virgin Islands: The BVI: Stepping Stone To Russia

International finance centres (IFCs) are frequently used to structure Russian inward and outward investment and it has been observed that in 2012, 11 of the 40 main recipients of Russian FDI were IFCs1. The BVI is at the forefront of offshore investment into Russia, and the share of outward FDI… – Continue reading

BSI Provides Road Map For Future Swiss Bank Agreements

On March 30, 2015, the U.S. Department of Justice announced that it had entered into a nonprosecution agreement with BSI SA, the first Swiss bank to reach resolution with the U.S. government as to its potential criminal exposure for assisting its U.S. clients in engaging in tax evasion.[1] As part… – Continue reading

Switzerland To Amend Tax Treatment Of PEs

Switzerland is to amend federal tax legislation to prevent the double taxation of certain permanent establishments (PEs) located in the country. The planned reform is the result of a consultation on the application of the flat-rate tax credit. It will affect PEs in Switzerland that have their registered office in… – Continue reading

Parliament takes aim at corporate ‘looting’

MPs say transfer pricing, though legal, presents challenges when determining if firms have evaded taxation and they want the practice criminalised. The portfolio committee on trade and industry has heard calls for the criminalisation of transfer pricing – a practice that, when abused, results in large corporations shifting profits offshore… – Continue reading

Corporate Investigations & White Collar Defense – April 2015

In This Issue: • It’s Stifling in Here! SEC Rules That Companies Can’t Put Restrictive Language in Confidentiality Agreements That Could Potentially Stifle Whistleblowers • An Opinion on Opinions: U.S. Supreme Court Decision in Omnicare • Is OFAC the New Black? Schlumberger and PayPal—The Rise in the Enforcement of Sanctions… – Continue reading

Taxpayer Advocate Urges IRS to Ease FATCA Rules for Americans Abroad

Doing so would get rid of ‘overlapping and duplicative disclosure requirements,’ says advocacy group for Americans abroad The IRS’ taxpayer advocate is urging the tax service to simplify rules for Americans living overseas. Currently, foreign bank accounts must be reported both to the Treasury, in a Report of Foreign Bank… – Continue reading

African leaders advised to focus on tax policies

SOUTH Africa’s Finance Minister Nhlanhla Nene says African leaders need to focus more on tax policies and the diversification of tax resources in order to foster growth. Speaking at an African Tax Administration Forum conference on Tuesday, he said the global focus on international taxation offered a unique opportunity for… – Continue reading

China: Asia Tax Bulletin – Spring 2015

CHINA Tax Free Reorganisations • With circulars 109 and 116 jointly issued in December 2014 by the Ministry of Finance and the State Administration of Taxation, the Chinese authorities have relaxed the conditions for internal reorganisations. • Circular 109 deals with internal reorganisations. Provided the pertinent requirements are met, the… – Continue reading

European Union: European M+A News, Spring 2015

EUROPEAN M&A DOS AND DON’TS FOR NON-EUROPEAN BUYERS Inbound M&A in Europe by non-European buyers increased in 2014 by 68.6% compared to 2013, representing over a third of USD 901.4 billion total European M&A.1 For non-European buyers the basic framework of transactions may be similar, but there are a number… – Continue reading

Tax Directors Anticipate Domestic and Cross-Border Growth Over The Next Three Years, According To The Inaugural BDO Tax Outlook Survey

– Rising Cost of Compliance Within The Tax And Financial Regulatory Environment Creates Opportunities For Increased Efficiency – CHICAGO–(BUSINESS WIRE)–As the economy continues to accelerate, many organizations plan to grow by entering into new markets in the years ahead, reveals the first ever BDO USA, LLP Tax Outlook Survey. Fifty… – Continue reading

Cayman Islands: Don’t Get Snowed In By GATCA

Offshore investment entities in the Cayman Islands and many other international financial centers should now start turning their attention to compliance with the Common Reporting Standard (“CRS”) promulgated by GATCA – Global FATCA. They must document all account holders existing on December 31, 2015, with the exception of entities with… – Continue reading

IRS declares victory on ObamaCare

The IRS is claiming victory as ObamaCare’s first tax filing season appears to be wrapping up with only a few hiccups. John Koskinen, the agency’s commissioner, said recently that the current filing season has gone “swimmingly” despite the extra burdens of the Affordable Care Act (ACA) and cutbacks to the… – Continue reading

Switzerland: Tax Briefing – Switzerland Takes Next Steps Towards Automatic Exchange Of Information In Tax Matters (AIA)

1. Introduction On 14 January 2015, the Swiss Federal Council opened consultations on two draft laws on the international exchange of information in tax matters. One of them deals with the OECD/Council of Europe administrative assistance convention signed by Switzerland on 15 October 2013. The other consultation deals with Switzerland’s… – Continue reading