Category: Statutory

Nigeria, Seychelles Seek Closer Ties

Abuja — NIGERIA and Republic of Seychelles relations Wednesday received a boost even as both countries have renewed commitment to further strengthen bilateral relations between them. Speaking during the presentation of his Credence Letter to the Minister of Foreign Affairs, Ambassador Aminu Wali, in Abuja, the Honourary Consul of Seychelles… – Continue reading

BMA’s Cox: Bermuda ‘demonised’ in Europe

Bermuda and other international financial centres are “routinely attacked and demonised” in Europe, according to Bermuda’s top financial regulator, reports the Royal Gazette. Jeremy Cox, chief executive officer of the Bermuda Monetary Authority, said in opening remarks in the BMA’s Business Plan 2015, published today, that it was “time for… – Continue reading

Imagination at Work? GE Once Again Pays Less Than 1% in Federal Taxes

Notorious tax dodger GE recently released its annual financial report and the only thing eye-raising about the company’s paltry 0.9 percent federal income tax rate is that it’s marginally higher than the 0.4 percent average rate it paid over the past decade. Released without fanfare late in the afternoon last… – Continue reading

Swiss Leaks: Malta Investment Registration Scheme attracts 1,469 applications with €455m

An investment registration scheme launched by the government last year attracted a total of 1,469 valid registrations covering an aggregate of €455.8 million worth of eligible assets, The Finance Ministry told The Malta Independent. Of the total amount registered, €69.8 million or 15% of the total was repatriated following registration…. – Continue reading

Tax residency tweak may hit Indian firms with overseas operations

Foreign subsidiaries may now have to pay tax both in India and the country of their operations At present, a company incorporated outside India is considered a tax resident only if the control and management of its affairs is situated wholly in India. Photo: Pradeep Gaur/Mint New Delhi: A budget… – Continue reading

Rwanda: Competing On Corporate Tax

Corporate tax reform has emerged as an area of potential bipartisan action in the United States Congress over the next few months. But fundamental questions about the right approach remain. There is widespread agreement that the US corporate tax system is deeply flawed. The rate is too high; the base… – Continue reading

It’s time to choose what kind of tax system we want

The Conversation Five years ago the Henry Review undertook a detailed examination of Australia’s tax and transfer system. Today, the Tax and Transfer Policy Institute at ANU’s Crawford School has revisited the Henry Review, as the Australian government prepares to release its tax white paper. Tax reform should not be… – Continue reading

Deadline dates for automatic exchange of tax information under FATCA and CRS

In previous updates we have alerted clients to the introduction of Cayman Islands regulations1, which give effect to the automatic exchange of tax information principles established by the US and UK intergovernmental agreements (the “Cayman US Regulations” and the “Cayman UK Regulations”, respectively). While many Cayman Islands entities will be… – Continue reading

No respite for Vodafone as Arun Jaitley maintains status quo on past offshore deals

British mobile giant Vodafone hasn’t been bailed out, with Finance Minister Arun Jaitley maintaining status quo on taxing past offshore deals. However, foreign investors can draw comfort as tax will be charged in India only on certain offshore deals where the underlying asset and the value derived thereon are in… – Continue reading

A new milestone for taxation on Indirect Asset Transfer by Non-Resident Enterprises — a review of the past and present of bulletin 7

After several rounds of revisions and consultations in the past few years, the State Administration of Taxation (“SAT”) has recently promulgated the Bulletin on Several Issues concerning the Enterprise Income Tax (“EIT”) on Indirect Asset Transfer by Non-Resident Enterprises (“Bulletin 7”)[1]. Tax matters occurred but have not been settled before… – Continue reading

Set right the tax climate

As recommended by Tax Administration Reforms Commission (TARC) under Parthasarathi Shome, for taxation, the appellate functions must be housed separately from the field functions, in order to have fair and judicious orders passed. Indian Revenue should be divided into two distinct sets—the operational side and the technical/adjudication side. The quasi-judicial… – Continue reading

Regulators Increase Scrutiny On Banks Over Tax-Avoidance Derivatives

Bank of America and four other banks have been queried by financial regulators about a complex trading maneuver that allows hedge funds to escape certain taxes. Reuters Financial regulators are heightening their focus on banks involved in complex international trades designed to skirt taxes, the Wall Street Journal reports. The… – Continue reading

Leaks on tap

Making tax-transparency standards watertight will be difficult THE optimistic view of the tax-evasion scandals that have bedevilled banks since 2008 is that they can only be seen in the rear-view mirror. The incriminating files in the latest case, regarding tax-dodging personal accounts held at the Swiss arm of HSBC, date… – Continue reading

Leading Offshore Firm: The Inside View on the Cayman Islands Jurisdiction

MCC interviews three attorneys from Mourant Ozannes. Hayden Isbister is a partner and head of the Corporate practice in the Cayman firm. He specializes in investment funds, general corporate and commercial work. James Burch is a partner and leads the Structured Finance/Banks practice in the Cayman Islands, and Tim Dawson… – Continue reading

US citizens in Greece and US taxes: A word to the wise, and a seminar

It is estimated that there are at least 100,000 Greeks with American citizenship living in Greece. In addition, thousands of US citizens live and work in Greece, either on a short-term or permanent basis. According to US law, all of these citizens, with very few exceptions, are required to file… – Continue reading

FATCA: The End of ‘Shadow Boxing’ in the Offshore Trust Industry

Not long after the U.S. Department of Justice’s Tax Division (“DOJ”) made international headlines in 2009 for its bombshell announcement that it had entered into a deferred prosecution agreement with the United Bank of Switzerland (UBS), lawmakers in Washington, D.C. began reviewing the testimony of hundreds of UBS’s U.S. clients… – Continue reading

How to navigate transfer pricing in Brazil; Deloitte advises

São Paulo, Brazil. International transfer pricing is able to take place in Brazil, outside of the OECD While Brazil is not a member of the OECD, many multinational groups there are able to successfully navigate international transfer pricing standards, yielding effective results The economic view of Brazil has always been… – Continue reading

Alberta online bank first in Canada to shun U.S. clients amid tax rules

An Alberta online bank is believed to be the first Canadian financial institution to deny service to Americans, citing the burden of complying with strict new U.S. tax rules. Canadian Direct Financial, a subsidiary of Edmonton-based Canadian Western Bank, is refusing to open new Internet accounts for U.S. citizens, even… – Continue reading

2 Investments to Avoid in Your IRA

IRA plans can be excellent ways to save for retirement, but there are some investments to avoid if you want to take full advantage of IRA tax savings. Two that come immediately to mind are tax-exempt municipal bonds and high-yielding stocks from foreign countries with dividend withholding taxes. Tax-exempt municipal… – Continue reading

Everything U.S. Expats Need to Know About IRS Tax Forms (But Were Afraid to Ask)

This is the time of the year for millions of Americans to begin the annual ritual of gathering information about income, taxes, charitable giving, health insurance, expenses and sundry other items, and prepare to send mountains of information to the IRS –and to those who prepare their tax returns. Overseas… – Continue reading

IRS Issues Tax Scam Warnings

Tax season is under way with Forms 1099 and W-2 already in mailboxes, and the Internal Revenue Service has also issued its annual list of the most common tax-related scams, called the dirty dozen. At the top of the list is identity theft, followed by potential tax swindles pitched by… – Continue reading

Sebi unearths tax evasion case; cracks whip on 33 entities for making Rs 1,800 crore undue gains

MUMBAI: The Securities and Exchange Board of India has banned 33 entities for allegedly misusing the stock exchange system to generate fictitious long-term capital gains of over Rs 1,800 crore and for converting their unaccounted income into legal money. Sebi said Kamalakshi Finance Corp (KFCL) made preferential shares to connected… – Continue reading

Private equity chiefs using “government-sponsored tax avoidance”, to save £700m a year, investigation finds

Research highlights the money pipeline between political parties and private equity houses A tax loophole is being used by the executives at private equity firms to save huge amounts on their personal income tax, according to research published today. An investigation, published by campaign group 38 Degrees, uncovers the private… – Continue reading

Fed up with manually filing forms in the Hong Kong company registry

The Companies Registry, Hong Kong has launched a full scale electronic filing system with effect from 15th February 2015 known as e-Registry. It is a 24 hour portal that allows electronic submission of applications for: Registration of Hong Kong companies Registration of non-Hong Kong companies 84 different specified forms under… – Continue reading

China’s tax administration issues new rules governing taxation of offshore indirect transfers

On February 3, 2015, the PRC State Administration of Taxation (“SAT”) released the Announcement of SAT Concerning Several Matters Relating to Corporate Income Tax on Indirect Transfer of Properties by Non-tax Resident Enterprises, Announcement [2015] No. 7 (国家税务总局关于非居民企业间接转让财产企业所得税若干问题的公告, 国家税务总局公告2015年第7号; “Announcement 7”). Below is a brief summary and discussion of the… – Continue reading

Tax Policy Update

NUMBER OF THE WEEK: 3,415. The number of people who renounced their citizenship in 2014 according to IRS data. This is one of the five highest totals on record since the U.S. Congress passed the Foreign Account Tax Compliance Act in 2010. In the past five years, more than 10,000… – Continue reading

Bull and bear cartels in stock market misuse for black money

Mumbai: As a probe continues into the misuse of stock markets for evading taxes and laundering black money, 4-5 cartels of market operators have been identified for making illicit gains or showing fictional losses of several thousands of crores of rupees over last 2-3 years. According to sources, both ‘bull’… – Continue reading

Worldwide: Asia Tax Bulletin – January 2015

CHINA China Releases GAAR Administrative Measures Courtesy of Mr Glen Wei, an attorney at law, certified tax adviser, and CPA based in China.China’s State Administration of Taxation (SAT) on December 12 issued Decree 32 (dated December 2) introducing administrative measures for applying the domestic general anti-avoidance rule to special tax… – Continue reading

The art of not curbing investment

If the Davis tax committee’s recommendations are followed, tax avoidance could be effectively reined in. Zeroing in on the super-wealthy and tax reluctant remains at the top of the global agenda as budgets across the world grow increasingly hungry for extra revenues. Now a draft report from the Davis tax… – Continue reading

India to boost trade ties with US, commits to adopt FATCA soon

NEW DELHI: Committing to boost trade ties, India and the US today resolved to enhance cooperation, remove obstacles to investment flows and work towards early adoption of FATCA to facilitate automatic flow of tax information. “We are committed to share our experiences in tackling offshore tax evasion and avoidance. We… – Continue reading

Ackman Says Tax Inversion Rules Could Lead to U.S. Drugmakers Selling to Overseas Buyers

(Bloomberg) — The backlash against acquisitions meant to skirt U.S. tax laws could spur more midsize U.S. drugmakers to sell to overseas buyers, Bill Ackman, the billionaire activist hedge fund manager, said Thursday. Takeover activity in 2014 was highlighted by U.S. companies — including Medtronic Inc. and Pfizer Inc. —… – Continue reading

Budget 2015: GAAR may be deferred by two years to boost business sentiment

NEW DELHI: The much-feared general anti avoidance rules (GAAR) could be deferred by about two years so that business sentiment is allowed to improve in India but will need to be rolled out in some form or the other by 2017, in sync with the international framework on preventing treaty… – Continue reading