Every year, corporations and wealthy individuals use complicated gimmicks to shift U.S. earnings to subsidiaries in offshore tax havens – countries with minimal or no taxes – in order to reduce their federal and state income tax liabilities by billions of dollars. While tax haven abusers benefit from America’s markets,… – Continue reading
Swiss banks, for decades the bastions of secrecy, are preaching the virtue of transparency to their U.S. clients as they try to head off billions of dollars in potential fines for helping Americans evade taxes. Faced with the threat of penalties that could bankrupt some of them, almost 100 of… – Continue reading
New Delhi: With overseas investors pumping in over Rs 2,000 crore in the Indian capital markets so far this month, total foreign fund inflows have crossed the Rs 81,000 crore mark since the beginning of the year. Analysts expect the inflows to accelerate further going ahead, helped by clearance of… – Continue reading
New Jersey is known for many things. As a burial ground for New York mobsters. Home to an impressive array of environmentally toxic factories. Atlantic City is the established gambling capital of the Eastern United States. Newark, New Jersey: one of the United States’s most criminal-minded cities. And a catchy… – Continue reading
A crackdown on alleged tax abuses by private equity managers has been drawn up by Labour as part of a £7.5bn plan to “come down hard on tax avoidance and evasion”, reports the Financial Times. The party said it would “re-write the rules that allow private equity managers to get… – Continue reading
The Ministry of Finance (MoF) recently signed a memorandum of understanding (MoU) with Umm Al Quwain Free Trade Zone Authority (UAQ FTZ). This agreement has been signed to ensure international standards of transparency in the exchange of information for tax purposes, as per Organisation for Economic Cooperation and Development (OECD)… – Continue reading
This is relevant mainly for (1) Hong Kong companies or investment funds selling securities in Chinese listed companies and (2) ship or aircraft leasing companies resident in Hong Kong who (finance) lease vessels and aircraft to lessees in mainland China. On 1 April 2015, Hong Kong and mainland China signed… – Continue reading
In recent years, the State Administration of Taxes (“SAT”) has paid closer attention to fees resident enterprises pay their overseas related parties, concerned that multinational groups have shifted profits away from China through aggressive tax planning and by paying unreasonable service fees and royalties overseas. Following PRC’s active participation in… – Continue reading
Labour has claimed it will reduce tax avoidance and evasion by £7.5bn a year by the middle of the next parliament. The party has also pledged to reduce pensions tax relief for higher earners, alongside similar plans by the Conservatives. Shadow Chancellor Ed Balls laid out the target this weekend… – Continue reading
Historically taxpayers have faced difficulty overcoming a presumption against a change in domicile to a foreign jurisdiction. Intellectual property generally will be the most valuable asset held by technology companies and, in fact, many other business entities across all sectors of the economy. A recent analysis of S&P 500 companies… – Continue reading
On 26 March 2015, the United Kingdom Parliament passed into law the Small Business, Enterprise and Employment Act 2015 (the “Act”). The Act will bring about a number of fundamental changes to UK company law including, amongst others, the abolition of bearer shares and corporations acting as directors and, perhaps… – Continue reading
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
Who Will Be Next? How To Respond To A Tax Investigation The international political community continues to make the most threatening noises about those who they believe do not pay enough tax. Long gone it seems are the days where it was accepted that a person could properly organise his… – Continue reading
The Texas Windstorm Insurance Association (TWIA) is returning to the catastrophe bond market, as expected, with its largest transaction to date, a proposed $450m two tranche Alamo Re Ltd. (Series 2015-1) offering. TWIA had always been planning to include a catastrophe bond within its 2015 reinsurance renewal, as long as… – Continue reading
One of the most financially damaging taxes facing wealthier British families is UK inheritance tax. Living in Malta does not automatically protect you since liability does not rest on residence but on domicile. Domicile is a complex UK common law concept. If claiming a change of domicile, the onus is… – Continue reading
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
The key is to arrive at a Goldilocks mean — rolling out tax-friendly policies while being firm with incorrigible offenders A phrase first used by Prime Minister Narendra Modi while addressing a group of businessmen in the run-up to the elections last year has now come back to haunt his… – Continue reading
A veteran lawyer of 35 years, Mr Pascal Netto, has been struck off the rolls for professional misconduct. The 68-year-old had been a nominee director in a client’s firm but issued company shares to himself and borrowed some US$158,000 (S$215,000) from the firm without authorisation. In disbarring Mr Netto on… – Continue reading
BERLIN: The Governments of France and Germany signed an amendment to the France-German treaty dated (the “Treaty”), which will have an impact in the future for certain investments in real estate. For France, this amendment follows the amendment to France-Luxembourg signed on 5 September 2014 which also impacts foreign investments… – Continue reading
All eyes will be on former Secretary of State, and now presidential candidate, Hillary Clinton as she sets out a policy agenda during the opening months of her campaign. While in recent years Clinton has not gotten into the nitty-gritty of tax policy, she does have a long voting record… – Continue reading
On 18th March 2015, George Osborne delivered his sixth budget as Chancellor and the last of the current Parliament. Amongst the announcements were a number of developments relevant to tax planning, the key points of which are summarized below: Capital Gains Tax – Entrepreneurs’ Relief Entrepreneurs’ Relief (ER) reduces the… – Continue reading
On 31 March 2015, the Governments of France and Germany signed an amendment to the France-German treaty dated (the “Treaty”), which will have an impact in the future for certain investments in real estate. For France, this amendment follows the amendment to France-Luxembourg signed on 5 September 2014 which also… – Continue reading
The present French Tax Update will focus on (i) several noteworthy French and European Union court decisions issued in the last months of 2014 and in the first months of 2015, and (ii) the recent presentation by the European Commission of a package of tax transparency measures. VALIDITY OF TAX… – Continue reading
[SHANGHAI] A sudden surge in mainland money chasing after Hong Kong’s share rally has prompted a dozen Chinese overseas mutual funds to suspend subscriptions on certain products, citing quota limits and the interests of existing fund investors. Chinese funds that invested overseas under the Qualified Domestic Investor (QDII) pilot scheme… – Continue reading
Australia is one of a handful of countries that offers franking credits, making the nation’s investors the envy of their counterparts elsewhere in the world. A franking credit is an income tax credit that companies can pass on to their shareholders. It is the result of dividend imputation, or attribution…. – Continue reading
Scottish Government must work closely with councils to ensure devolution of taxation powers to Scotland brings tax and welfare systems together, according to experts. The Chartered Institute of Taxation (CIOT) also warned draft legislation could have ‘unintended complexities’, leading to double taxation on foreign income and forcing more Scottish taxpayers… – Continue reading
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
NEW DELHI — An Indian court on Thursday sentenced the former head of Satyam Computer Services, a software outsourcing company, and nine others to seven years in prison after a trial centered on one of the largest corporate accounting frauds in India’s history. The former chairman of the Hyderabad-based company,… – Continue reading
Bachelet and Piñera Governments Linked to Latest Corruption Scandal High profile corruption scandals in Chile continue to pile up, implicating both the governing and opposition coalitions parties, and even reaching as high as the office of President Michelle Bachelet. On Thursday, April 2, the Chilean Internal Tax Service (SII) filed… – Continue reading
Hong Kong Exchanges and Clearing Limited’s securities market turnover has risen to a record high, and the recent signing of the fourth Protocol to the China-Hong Kong double taxation agreement (DTA) will further boost trading activity through the Shanghai-Hong Kong Stock Connect (SHKSC) program. Hong Kong Exchanges and Clearing Limited’s… – Continue reading
Recently, State Administration of Tax issued Annual Corporate Income Tax (“CIT”) Return Package of People’s Republic of China (Type A, 2014). The new return package will come into force on Jan 1st, 2015 and first to be adopted by resident CIT taxpayers in the 2014 annual CIT filing. This issue… – Continue reading
The Australian Taxation Office has cut 4400 jobs in the past 19 months with one staff member telling a Senate hearing many of them were “our go-to” people. On Thursday, the Community and Public Sector Union told the hearing into corporate tax avoidance Australia’s tax collection would be hurt by… – Continue reading
The state Division of Taxation is taking steps to recoup $1.6 million in rebates it overpaid nearly 3,800 taxpayers, following an investigation by the Office of the State Comptroller. The comptroller’s office released the findings of its investigation into property tax relief programs for multi-unit properties Thursday along with steps… – Continue reading
Tax and business consultants KPMG are warning the government to be cautious in reforming corporate tax law in its moves to target offshoring of corporate profits. In its submission to the Senate inquiry examining corporate tax avoidance, KPMG said while governments need to ensure they are receiving appropriate amounts of… – Continue reading
SINGAPORE – An enhanced regulatory framework for corporate service providers (CSPs) to combat money laundering and terrorism financing will take effect from May 15. The strengthened regime for CSPs will help to further boost Singapore’s reputation as a trusted international financial and business centre with robust regulatory frameworks against money… – Continue reading
China has introduced measures to deny income tax deductions for certain service fees and royalties paid by Chinese companies to their overseas affiliates. They appear to stem from China’s initiatives to implement rules it sees as related to the OECD’s Base Erosion and Profit Shifting project (BEPS) They will likely… – Continue reading
Changes are in the pipeline which will have a dramatic impact on the way that auditing firms handle public-interest entities (PIEs) as from December 2016 – but Deloitte CEO Malcolm Booker is very wary about how this could work in practice. According to the legislation, auditors would have to enter… – Continue reading
Draft plans to remove tax benefits for cross-border funds to eradicate Base Erosion and Profit Sharing could significantly impact investment into Ucits, the Alfi conferences hears. New draft OECD rules designed to combat Base Erosion and Profit Sharing (Beps) could have dire unintended consequences for cross-border funds, warned Roger Exwood,… – Continue reading
Labour Party leader Ed Miliband’s vow to close a tax loophole sparked fresh scrutiny on wealthy residents and drew warnings the plan could threaten London as one of the world’s major financial centers. Miliband pledged on Wednesday to abolish the non-domicile status if he’s elected on May 7, allowing some… – Continue reading
Corporations like Apple shouldn’t get a sweetheart deal to “onshore” profits, tax expert Scott Klinger tells Salon One of the more consequential paradoxes of American politics concerns the myth and the reality of bipartisan legislation. The myth is that American voters want it, and they want it bad. In fact,… – Continue reading
Introduction In a recent chief counsel memorandum (AM 2015-01), the IRS addressed a long uncertain tax question: when a US corporate shareholder includes an amount in income under subpart F, does the subpart F inclusion increase the corporate shareholder’s “earnings and profits” immediately or only when the earnings are actually… – Continue reading
Since entering the Illinois Senate race last week, Democratic Rep. Tammy Duckworth has been running a protectionist campaign, railing against her Republican opponent’s alleged support for outsourcing jobs and overseas tax havens. But financial records obtained by The Daily Caller show that Duckworth has investments in companies that use offshore… – Continue reading
Many Canadian Snowbirds who have become fed up with Canada’s long, hard winters (and there are bound to be many more this year, especially from the Eastern provinces) have purchased winter homes in Southern U.S. states. This has been an especially popular move over the past few years, with U.S…. – Continue reading
By now, most of us know that the ruling Conservatives announced they will release the Federal Budget (calling it Economic Action Plan 2015 – the “Budget”) on April 21, 2015. Once again, I will be in attendance in Ottawa representing CPA Canada and our firm. What do I predict will… – Continue reading
Malta has become the only jurisdiction to offer full UK-style pension freedoms for British ex-pat savers in qualifying registered overseas schemes, after a deal forged last week between the country’s financial regulator, reports the FT Adviser. One provider, TMF Group, has announced it has reached agreement with the Malta Financial… – Continue reading
In my practice, I have found that a majority of my clients who create significant wealth do so through ownership of a private business or a concentrated stock position in a publicly traded company. What that means for you is that if you haven’t yet started a business or taken… – Continue reading
Tax breaks for research and development should be targeted to smaller technology start-ups, rather than big companies that will most likely make the investments regardless of incentives, Google Australia will tell the senate inquiry into corporate tax avoidance. Google Australia’s managing director, Maile Carnegie, will be appearing before the inquiry… – Continue reading
Mylan-Perrigo deal would combine two generic drugmakers that recently left the U.S. for Europe. NEW YORK — In a deal that would combine two generic drugmakers that recently left the U.S. for Europe, Mylan says it wants to buy Perrigo for $205 per share, or $28.86 billion. Shares of both… – Continue reading
For British pension holders in the US, transferring into a Qualifying Recognised Overseas Pension Scheme (QROPS) is now commonplace. These pension solutions are widely accessible to all US residents or nationals who have accrued pensions from their time working in the UK, and are an invaluable aspect of financial planning… – Continue reading
Says India not a tax haven, dues have to be paid if demands are right Finance Minister Arun Jaitley on Monday said India’s tax regime wasn’t confrontational, but added legitimate demands by the Income Tax Department had to be paid. He said there were challenges on the road towards reforms… – Continue reading
