The Hong Kong bourse has launched a special segregated accounts system for Stock Connect in an attempt to address investors’ concerns over the much-criticised pre-trade checking rules. A reformed trade settlement system was rolled out to Stock Connect investors yesterday in a bid to address concerns over the pre-trade checking… – Continue reading
NEW YORK The former chairman of an LED lighting provider was charged by U.S. officials with scheming to boost the company’s share price in part by making secret payments to conspirators through a firm based in Belize. ForceField Energy Inc.’s Richard St-Julien, who stepped down from his position after his… – Continue reading
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
The former chairman of an LED lighting provider was charged by U.S. officials with scheming to boost the company’s share price in part by making secret payments to conspirators through a firm based in Belize. ForceField Energy Inc.’s Richard St-Julien, who stepped down from his position after his arrest Friday,… – Continue reading
India and China developing frameworks for Reits but while their sheer sizes impress, both face tax and high interest rate hurdles, reports the Business Times. India and China are both developing frameworks for real estate investment trusts (Reits), but the threat to Singapore’s position as a major regional Reit centre… – Continue reading
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
The outlook for uranium, moribund for some time, is looking up. And that means shares of Cameco Corp., the Saskatoon-based miner one analyst calls “the only real blue-chip stock in the sector,” are up, too – about 20 per cent from their 52-week lows. The stock has received a host… – Continue reading
Starwood Hotels & Resorts Worldwide Inc. may need to accommodate activist shareholders with a merger or buyout. Starwood, which owns high-end hotel chains such as W and Westin, has one of the worst stock-return and growth outlooks in the industry. It’s also entering the second month of searching for a… – Continue reading
New Delhi: The government has set the record straight on tax disputes, maintaining they are not covered by the Bilateral Investment Promotion and Protection Agreement (BIPA) and need to be judicially and legally settled. “…But again on the BIPA issue, let me mention, it has been our consistent view that… – Continue reading
Sydney Airport is refusing to display a billboard that denounces tax evasion by multinational companies. The airport, which was last year forced to pay a $69 million settlement to the Australian Tax Office to end an audit of suspect tax deductions, claimed the proposed Labor billboard would contravene its policy… – Continue reading
As foreign portfolio investors balk at India’s claim of $6.4 billion in back taxes, the finance ministry’s latest demand isn’t damping interest in the nation’s stocks and bonds. Foreigners were net buyers of local equities every day barring one since the finance ministry said April 6 it is well within… – Continue reading
Cross border transactions involving German entities investing in French real estate may need to be restructured as a result of proposed changes to the France/Germany double tax treaty, according to two experts. French tax expert Franck Lagorce and German tax expert Werner Geisselmeier, both of Pinsent Masons, the law firm… – Continue reading
Increased mergers and acquisitions in the pharmaceuticals space has been a boon for healthcare-heavy Israel exchange traded funds. Year-to-date, the Market Vectors Israel ETF (NYSEArca: ISRA) and the iShares MSCI Israel Capped ETF (NYSEArca: EIS) are up an average of 11.6%, an advantage of 260 basis points over the MSCI… – Continue reading
Increased mergers and acquisitions in the pharmaceuticals space has been a boon for healthcare-heavy Israel exchange traded funds. Year-to-date, the Market Vectors Israel ETF (NYSEArca: ISRA) and the iShares MSCI Israel Capped ETF (NYSEArca: EIS) are up an average of 11.6%, an advantage of 260 basis points over the MSCI… – 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
Research by the Guardian and the Tax Justice Network reveals 28 English clubs with substantial shareholdings overseas, opening up the football leagues to criticism for allowing ownership structures that could be used for tax avoidance Almost one in three of the 92 Premier and Football League clubs are now substantially… – Continue reading
Analysts upbeat on the company’s standalone prospects The recent share price performance of Shire Plc (LON:SHP), the London-listed drugmaker left at the altar by US pharma giant AbbVie (NYSE:ABBV) last year, suggests that the company will continue to thrive on its own, a view supported by recent analyst comments on… – Continue reading
The Panama Government on its continuous interest of complying with the requirements of international organizations and global standards of highly reputable financial centers has decided to take measures to accelerate the entry into force of Act 47 of 2013, which establishes a regime for the immobilization of Bearer Shares, and… – Continue reading
His softball sentence of two years probation ended five years ago. But billionaire real estate developer Igor Olenicoff still can’t put behind him his December 2007 guilty plea to lying on his federal tax return about some $200 million he kept offshore. For that, he can blame his own litigiousness… – 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
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
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
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
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
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
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
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
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
Shenzhen authorities have started to lift the sales ban against projects by Kaisa Group Holdings, but troubles are far from over for the developer. The city restricted Kaisa from selling thousands of flats four months ago, which quickly pushed the developer to the brink of bankruptcy as its cash flow… – Continue reading
MANY retirees could be forced on to age pensions if they lose tax credits on dividends, Australia’s biggest listed investment company has warned. Australian Foundation Investment Company general manager Geoff Driver says retirees would have less income if the dividend imputation system were scrapped. Higher demand for age pensions would… – Continue reading
Argues tax proceedings initiated after more than six years Vedanta group company Cairn India on Monday filed a petition in the Delhi High Court here against a Rs 20,494-crore tax demand, seeking quashing of the order. The company argued the tax proceedings were initiated more than six years from the… – Continue reading
Allegations that News Corp engaged in an aggressive tax avoidance scheme have been strongly rejected by the company. News Corp Australia chief executive Julian Clarke said in a statement: “This claim is based on a fundamental misunderstanding of the nature of these transactions, US and Australian tax treaties and applicable… – Continue reading
Rupert Murdoch’s media empire in the US has siphoned off $4.5 billion of cash and shares from his Australian media businesses in the past two years, virtually tax free. According to calculations by University of NSW accounting academic, Jeffrey Knapp, over the past 10 years, Mr Murdoch’s companies here have… – Continue reading
After much of a clout about who will acquire Salix Pharmaceuticals (SLXP), Canadian Drug maker Valeant Pharmaceuticals International Ltd (VRX) completed the purchase for $11 billion last Wednesday. Salix Pharmaceuticals works in gastro instrumental drugs and it will provide Valeant with new therapeutic business. This is Valeant’s biggest buy so… – Continue reading
On April 3, 2015, as part of its Action Plan on Base Erosion and Profit Shifting (BEPS), the OECD released a discussion draft entitled “BEPS Action 3: Strengthening CFC Rules” (the Draft) for comments. The Draft stresses the importance of CFC rules in countering base erosion and profit shifting, and… – Continue reading
The Luxembourg supervisory authority, the Commission de Surveillance du Secteur Financier (CSSF), has recently issued FAQs regarding the immobilisation of bearer shares and units, as well as a press release to remind Luxembourg alternative investment fund managers (AIFMs) and non-EU AIFMs that market alternative investment funds (AIFs) in Luxembourg under… – Continue reading
New Delhi/Mumbai: In the biggest-ever tax demand slapped on them, nearly 100 foreign funds have been asked to cough up an estimated USD 5-6 billion for ‘untaxed gains’ made by them in the Indian markets over the past years. The number of affected investors can rise substantially as assessments are… – Continue reading
Interview with Partner and National Leader, Human Capital Services, EY India The Undisclosed Foreign Income and Assets (Imposition of Tax) Bill, 2015, popularly called the “anti-black money bill” has been in the news for its stringent and sweeping provisions. Sonu Iyer, partner and national leader, human capital services, EY India,… – Continue reading
Law360, New York (April 03, 2015, 10:12 AM ET) –One of the tougher issues buyers face when engaging in preliminary discussions regarding a potential going-private transaction is whether and when an amendment to required U.S. Securities and Exchange Commission stock ownership disclosures needs to be filed as steps are taken… – Continue reading
A BRITISH philanthropist at the centre of a national tax avoidance storm has donated £2,000 towards a Worcestershire MP’s bid for re-election, it has emerged. Lord Fink, a multi-millionaire former hedge fund manager embroiled in a row Ed Miliband, has handed the cash to West Worcestershire Conservative Harriett Baldwin. The… – Continue reading
The Shanghai-Hong Kong Stock Exchange Connected is working out its kinks and investors are taking notice. Hong Kong and Beijing signed a tax treaty on Thursday that ends double taxation for equity traders, which was one of the sticking points for local brokers hoping to buy into China’s massive mainland… – Continue reading
Hong Kong (HKSAR) – The Secretary for Financial Services and the Treasury, Professor K C Chan, signed the Fourth Protocol to the Arrangement for the Avoidance of Double Taxation and Prevention of Fiscal Evasion with respect to Taxes on Income with the Mainland (the Fourth Protocol) with the Deputy Commissioner… – Continue reading
United Kingdom In Tower Radio Limited and another v HMRC5, the taxpayers successfully utilised a scheme which was designed to take advantage of Part 7 of the Income Tax (Earnings and Pensions) Act 2003 (ITEPA). Background During the periods relevant to this case, no liability to income tax arose under… – Continue reading
