BEIRUT: Lebanon’s commitment to fighting money laundering does not hurt banking secrecy but, to the contrary, is in the interests of the banking sector, said Joseph Torbey, president of the Association of Banks in Lebanon. “Lebanon’s serious commitment to fighting money laundering will prevent the escape of investments from Lebanon… – Continue reading
The Protocol amending the Multilateral Convention on Mutual Administrative Assistance in Tax Matters will lead to substantially more transnational identity theft, crime, industrial espionage, financial fraud, and the suppression of political opponents and religious or ethnic minorities by authoritarian and corrupt governments. It puts Americans’ private financial information at risk…. – Continue reading
The Markets Supervision Directorate of the Central Bank published its programme of themed-inspections for 2016. These inspections reflect a number of supervisory priorities for 2016 and anticipate areas of emerging risk. This programme builds on the successful supervisory work undertaken in 2015 in the areas of Cyber Security, Operational Risk… – Continue reading
The provisions commonly known as the Foreign Account Tax Compliance Act (FATCA) became law in March 2010. •FATCA targets tax non-compliance by U.S. taxpayers with foreign accounts •FATCA focuses on reporting: •By U.S. taxpayers about certain foreign financial accounts and offshore assets •By foreign financial institutions about financial accounts held… – Continue reading
MUMBAI: As many as 380 market entities, most of them stock brokers, faced action for failing to prevent possible money laundering and terror financing activities during the last fiscal. Discrepancies related to Anti-Money Laundering and Combating Financing of Terrorism (AML and CFT) regulations were observed against brokers and depository participants… – Continue reading
An Easy Checkoff for Global Competitiveness: The Case for a U.S. Innovation Box – Robert D. Atkinson – November 30, 2015. “Taxing corporate revenues from innovation-based activities less will not only boost U.S. global competitiveness it will help bring back IP-based corporate profits now overseas. “Within the last decade a… – Continue reading
Legal experts say court order for restaurant’s parent company based in British Virgin Islands could lead to resolution of more disputes in city Hong Kong’s top court recently gave the go-ahead for the parent company of the famous Yung Kee roast goose restaurant in Central to be wound up, despite… – Continue reading
The Australian Taxation Office (ATO) on 17 December 2015 released guidelines that address country-by-country reporting. The ATO release—Law Companion Guideline (LCG) 2015/3—discusses Tax Laws Amendment (Combating Multinational Tax Avoidance) Act 2015 that was enacted earlier this month and discusses, in particular, Schedule 4. Background Schedule 4 created Subdivision 815-E of… – Continue reading
Footwear is one of the industries with high export turnover. However, the profitable industry is being controlled by companies from South Korea and Taiwan. According to the Vietnam Leather & Footwear Association (Lefaso), with 800 enterprises and 1 million workers, FIEs account for one-fourth of total number of footwear makers,… – Continue reading
The organization’s new ambassador in the Brazilian capital Brasília claims trade and mutual investment between Arab countries and Brazil can be worked on. São Paulo – Newly appointed to represent the Middle East and North Africa countries in Brazil, the ambassador of the League of Arab States in the national… – Continue reading
When purchasing a real property overseas, there are situations when it may prove advantageous or even necessary to do so through an offshore corporation, rather than owning the property individually. It is crucial to understand that this can also have significant US tax consequences for US persons. Fortunately, “checking the… – Continue reading
Case law Chevron appeal to the Full Federal Court Chevron Australia Holdings Pty Ltd has appealed the decision of the Federal Court in Chevron Australia Holdings Pty Ltd v Commissioner of Taxation (No 4) [2015] FCA 1092 to the Full Federal Court. For details of the Federal Court decision, please… – Continue reading
The Department of Justice announced today that Edmond de Rothschild (Suisse) SA and Edmond de Rothschild (Lugano) SA (collectively EdR Switzerland) reached a joint resolution under the department’s Swiss Bank Program. EdR Switzerland will pay a penalty of more than $45 million. The Swiss Bank Program, which was announced on… – Continue reading
MUMBAI|NEW DELHI: Many US-based non-resident Indians are considering selling their property in India – even at a discount – amid confusion and fear that a new information-sharing protocol may bring their assets, bank accounts, mutual funds and capital market investments in India under the scanner of US tax authorities. India… – Continue reading
The Australian Government’s efforts to improve tax collections are more urgent amid falling revenue from weak commodity prices, the Wall Street Journal reports Malcolm Turnbull’s government took the rare step of making public the tax affairs of scores of multinationals, highlighting that many big names—including Apple Inc. and Volkswagen AG… – Continue reading
The Indian government has become progressively more strict about what is considered income under tax law and who must file an income tax return. In particular, companies required to withhold taxes, and individuals or companies in receipt of income, have found themselves subject to increasingly stringent withholding rules. The topic… – Continue reading
2016 Compliance Update For the past few years, FATCA has dominated the international tax compliance landscape. As that regime continues to be phased-in, a new regime – the Common Reporting Standard (“CRS”) – will begin to be implemented around the world. CRS, sometimes referred to as “Global FATCA,” will expand… – Continue reading
Where it happens does not matter. Portugal or overseas, whether its rental income, bank interest, bond yields, dividends, or even gains from the sale of a property, such personal financial information will be automatically shared from 1st January 2016. For many who have undergone financial planning, or have been involved… – Continue reading
Where it happens does not matter. Portugal or overseas, whether its rental income, bank interest, bond yields, dividends, or even gains from the sale of a property, such personal financial information will be automatically shared from 1st January 2016. For many who have undergone financial planning, or have been involved… – Continue reading
Why raise the limit for quoting PAN in cash deals? Though the government’s one-time black money compliance window for money stashed overseas garnered a mere Rs 3,770 crore, getting rid of black money remains a focus area. While it is understandable that industry’s protests over the General Anti-Avoidance Rules (GAAR)… – Continue reading
The Cayman Islands (along with the United Kingdom, Ireland, Jersey, Guernsey, the British Virgin Islands and over 70 other countries) has committed to implementing the OECD Common Reporting Standard (“CRS”), which will require investment funds to collect tax identification and tax residency information from all new subscribers and transferees (including… – Continue reading
IP regime To comply with the OECD’s BEPS reports and more specifically its action plan n° 5 regarding harmful tax practices, the Luxembourg intellectual property (“IP“) regime under article 50bis of the Luxembourg income tax law (“ITL“) will be repealed as from 1 July 2016. As such, the Luxembourg 80%… – Continue reading
It has been a tough year for Russian businesses. The latest monthly forecast of the Economist Intelligence Unit (EIU) predicts a contraction in Russian real GDP of 3.8% in 2015 and another 0.5% in 2016. “Structural weaknesses will keep trend GDP growth below 2% a year in the medium term,”… – Continue reading
ISLAMABAD: The World Bank says tax regulations in Pakistan are frequently altered, and unpredictable tax rules worsen the business climate and may deter potential investment. The report “Towards a more friendly tax regime: Key challenges in South Asia,” points out that South Asia’s tax regulations are complex and difficult to… – Continue reading
Over 90 jurisdictions have committed to the OECD’s Common Reporting Standard (CRS), creating comprehensive global automatic information exchange for financial assets and the entities through which such assets may be held. Over 70 jurisdictions have signed the OECD’s Multilateral Competent Authority Agreement, which implements the CRS. The CRS is scheduled… – Continue reading
Draft 2015 Instructions for Form 8966. IRS has published a draft version of the instructions to the 2015 Form 8966 (FATCA Report), which certain foreign financial institutions (FFIs) and others use to report information with respect to U.S. accounts under the Foreign Account Tax Compliance Act (FATCA). The instructions reflect… – Continue reading
Action on tax avoidance could see €600m go from the pharma sector, says report International moves on multinational tax could threaten Ireland, with a potential annual loss of corporate tax revenue of €600 million or more from the pharma sector alone, according to a new report from Chartered Accountants Ireland…. – Continue reading
WHETHER he is being straitjacketed by the International Monetary Fund (IMF) or it’s a case of his own ignorance of how economies work, Dr Peter Phillips is recklessly betraying the cause of Jamaican businesses. The finance minister, with the tacit support of the Cabinet – and his self-serving cabal –… – Continue reading
FOCUS: New UK government plans to penalise those who help others evade tax could punish those who unknowingly enable evasion and could create conflicts of interest and the danger of double jeopardy. The government will introduce a new civil penalty for those who deliberately “enable” offshore tax evasion. It also… – Continue reading
Provide high-net-worth individuals with (further) incentives to relocate to Cyprus. This is one of the objectives of the introduction of the non-domicile rules (voted on the 9th of July 2015, among other tax reforms) that came into force on the 17th of July 2015 (date of the publication in the… – Continue reading
Provisions under new article 76A of Mexico’s tax law reflect certain items of the OECD’s base erosion and profit shifting (BEPS) project—in particular expanded transfer pricing disclosure requirements that will apply for the 2016 tax year. Background The Mexican government’s 2016 federal budget, presented 8 September 2015, included proposals for… – Continue reading
There are a number of ways to structure your offshore fund and the best option for you will depend largely on the location of the manager, your investor base and the type of investments that the fund will make. I have set out a summary of the three most common… – Continue reading
Executive summary On 9 December 2015, the UK released draft clauses for Finance Bill 2016 as well as consultation documents. The key items released include: A new requirement for large businesses to publish their tax strategies as they relate to or affect UK taxation. This sits alongside new ‘special measures’… – Continue reading
According to Baroness Neville-Rolfe, Parliamentary Under Secretary of State at the Department for Business, Innovation and Skills, the United Kingdom “is at the forefront of a dramatic increase in transparency about company ownership” in developed countries. However, it is the UK which is going to provide the testing ground for… – Continue reading
The U.S. Internal Revenue Service (IRS) has released Instructions for Form 1042 for 2015 that provide guidance for withholding agents regarding the filling in of their form. It includes updates for FATCA requirements in accordance with the newly issued regulations under Chapter 3 and 4 of the Internal Revenue Code…. – Continue reading
The Australian Federal Court has ordered five investment schemes managed by Avestra Asset Management to shut down, The Australian reported today, following the fund’s link to the 1Malaysia Development Berhad (1MDB) controversy. It was reported that the judge made the decision after going through a report from liquidators, who unearthed… – Continue reading
On December 15, 2015 the European Commission issued a media release announcing that on that same date it adopted new rules to make it easier for EU Member States’ tax authorities to exchange financial information so that they can ensure full tax transparency and cooperation. According to the media release… – Continue reading
Dividend income from foreign companies is not treated the same as dividend from domestic companies, for tax purposes The two key advantages of investing in equities are the possibility of higher returns and tax efficiency. In the long term, equity has outperformed other asset classes. And, according to Income tax… – Continue reading
Growth and profitability have been at the crux of the corporate agenda and defined the way businesses function. Companies have nevertheless encountered challenges while trying to achieve these goals, which have inevitably required them to sometimes ‘work around the way of the land’. For instance, it is a common concern… – Continue reading
The BVI Business Companies Act 2004 (“BCA“) is shortly due to be amended by the BVI Business Companies (Amendment) Act 2015 (the “Amendment Act”). As well as keeping the British Virgin Islands (“BVI“) corporate regime at the forefront of compliance with international standards, the Amendment Act is intended to provide… – Continue reading
FATCA (the Foreign Account Tax Compliance Act) came into force in July 2014. It is far-reaching and may impose a compliance burden on the trustees of New Zealand family trusts, even if no US persons are involved. IRD has recently issued further draft guidance on the application of FATCA to… – Continue reading
More good news for Hong Kong before the end of 2015: Italy decided to remove Hong Kong from its national blacklist on November 30, 2015. Italy ratified a comprehensive agreement for the avoidance of double taxation (CDTA) signed with Hong Kong on June 18, 2015. Facilitating an early removal of… – Continue reading
Lately, the IRS is warning offshore account holders to disclose before it’s too late. Under FATCA, banks everywhere want to know if you are compliant with the IRS. And the cost of compliance for many people is growing. The IRS updated its list of foreign banks where accounts trigger a… – Continue reading
the company will make a complaint against the decision Nokian Tyres plc (HEX:NRE1V) has received a renewed reassessment decision from the Tax Administration, according to which the Company is obliged to pay EUR 87 million additional taxes with punitive tax increases and interests concerning tax years 2007-2010. Payment must be… – Continue reading
Celebration, FL One of the basic principles of the 3.8% “net investment income tax” (NIIT) under §14111 is that the tax does not apply to individuals who are classified as “nonresident aliens” for U.S. income tax purposes, as defined in §7701(b).2 What was not clarified in the statute, however, was… – Continue reading
In 2002, a corporation could establish a fiscal year end for Quebec tax purposes that differed from its year end for British Columbia and federal tax purposes – referred to as a Quebec year end shuffle. In Veracity Capital Corporation v. Canada, 2015 BCSC 2278 (copy attached), taxpayers transferred shares… – Continue reading
DuPont and Dow are now officially combining and Piper Jaffray analyst, Brett Wong, thinks further consolidation is coming with Monsanto (NYSE: MON) likely to renew the pursuit of Syngenta (NYSE: SYT) towards the beginning of the year. Piper thinks a renewed bid for Syngenta would be viewed negatively by investors… – Continue reading
Hundreds of millions of dollars of revenue could be up for grabs as the Tax Office announces reviews of multinationals using offshore hubs in Singapore to minimise their tax. The ATO has issued a warning to multinationals to come forward immediately to discuss their overseas hub arrangements, if they have… – Continue reading
Something unusual is happening with the Irish corporation tax in 2015 — so unusual that Ireland’s top tax man felt obliged to write to the parliament to explain what is going on. But the explanation left a lot to be desired. According to government data, Ireland received 57.7 percent more… – Continue reading
The European Commission asked the Netherlands on 19 November to amend the limitation on benefits (LOB) provision in the existing Dutch-Japanese tax treaty. The LOB provision may be detrimental to Dutch companies held by residents of certain EU/EEA countries when they receive interest, royalties and dividends from Japan. They may… – Continue reading
