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
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
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
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
Major accounting firms say they are not doing anything illegal in helping corporations to minimise tax liabilities. KPMG’s managing partner Rosheen Garnon faced the second day of the Senate inquiry into tax avoidance, which has so far heard Australia is missing out on billions of dollars in tax every year… – Continue reading
The Federal Government has floated the idea of lowering the corporate tax rate – arguing the current rate of 30% is not internationally competitive. The rationale is that globalisation makes capital perfectly mobile and the marginal non-resident investor in Australian companies will go where corporate tax rates are lowest. At… – 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
No member of Congress has been more active in the cause of protecting tax cheaters and tax avoidance by our nation’s wealthiest individuals and corporations than Sen.(now presidential candidate) Rand Paul. While Paul is a standard bearer of anti-tax conservatives through his advocacy of radical policies such as the flat… – 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
It’s been five years since the Foreign Account Tax Compliance Act (FATCA) became law and while the intentions were good – to crack down on those hiding money offshore and avoiding taxes, compliance comes at a price for individuals and corporations. “The upside of FATCA is that it is forcing… – Continue reading
Law360, New York (April 06, 2015, 3:10 PM ET) — A draft report released Friday by the Organization for Economic Cooperation and Development on strengthening controlled foreign-company rules to crack down on tax evasion said there are substantial disagreements among member states about how to best define CFC income. The… – 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
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
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
New rules mean that almost 100 governments around the world will exchange information about bank accounts Expat tax dodgers are running out of places to hide, as information about their bank accounts and assets will soon be exchanged between 93 governments globally. At present, if tax authorities suspect people of… – Continue reading
We asked Vincenzo Villamena, a New York-based international tax adviser and certified public accountant with Online Taxman, and his British-expat client Ed Zitron of San Francisco, to share personal finance tips for expats, particularly those hailing from the U.K. Here are their top tips: 1. Mind your pensions & QROPS!… – Continue reading
I. Introduction In an effort to crack down on individuals obtaining U.S. citizenship illegally, the U.S. Department of Justice recently raided several “maternity tourism” operations in Southern California.1 These companies cater to wealthy foreigners seeking to give the gift of U.S. citizenship to their children. Since at least 1868, the… – Continue reading
Like a savvy bargainer on a used car lot, big multinational corporations have mastered the art of feigning indifference and walking away. What they walk away with is their profits, stockpiling them abroad where they legally remain untaxed until returned to the United States. Then these corporations threaten to keep… – Continue reading
New EU plans to force governments to send quarterly reports on tax rulings are a “revolutionary” step towards overcoming corporate secrecy, the bloc’s tax commissioner has said. The blueprint published two weeks ago by the Commission would establish a system of automatic exchange of information on tax rulings and require… – Continue reading
U.S. multinationals represent the healthiest segment of the economy, with higher profits and more than $1 trillion of cash on hand. This has kept corporate tax reform alive as a political issue. ON Semiconductor had a solid 2014, boosting net income by 36 percent to $196 million on revenue of… – Continue reading
In order to guide the implementation of the Tax Law on amending key tax laws which was effective from January 20151, the following guidance regulations have been issued: Decree 12/2015/ND-CP dated 12 February 2015 of the Government (“Decree 12”); and Circular 26/2015/TT-BTC dated 27 February 2015 of the Ministry of… – Continue reading
Australians working in Hong Kong should be aware of the various complexities that affect their residency, super and tax status. Going overseas to work is a grand adventure for many professionals. But the way income earned outside your home country is taxed is a complex area, and it’s worth seeking… – Continue reading
Government questions dividend imputation and company tax rate Australian investors appear to have dodged a bullet, with the government’s first paper on tax reform discussing the dividend imputation system but falling short of attacking it outright as an idea that has outlived its usefulness. David Murray’s inquiry into the Australian… – Continue reading
Ted Cruz has developed a reputation as the most conservative of the major 2016 Republican presidential candidates, but he hasn’t taken many specific policy positions to earn that moniker. One exception? His longtime support for a flat tax. The flat tax dramatically lowers the top tax rate and exempts capital… – Continue reading
Dividend payment by an overseas company with related assets in India will not be taxable in India, the govt says New Delhi: The income tax department on Thursday clarified that dividend payment by an overseas company with related assets in India will not be taxable in India, as part of… – Continue reading
(Bloomberg) — Japan is stepping up pressure on companies to use their near-record cash stockpiles to help drive growth, with Finance Minister Taro Aso saying Thursday the government should consider a tax to prod businesses into action. “Japan should carefully consider issues like this,” Aso said in Parliament in response… – Continue reading
SINGAPORE, March 27 (IFR) – China’s Bank of Communications said it would raise up to Rmb60bn (US$9.7bn) in Additional Tier 1 capital through onshore and offshore offerings. It will sell preference shares of up to Rmb45bn onshore to not more than 200 investors and up to Rmb15bn offshore. The bank… – Continue reading
Five years after paying $413.7 million to settle a huge tax avoidance claim, ANZ bank is under fire for a $1 billion deal that appears to “double dip” on trans-Tasman tax benefits. The criticism follows the Australian bank’s issue this month of A$970 million ($995 million) of hybrid securities to… – Continue reading
Ghana and the Netherlands have signed a Memorandum of Understanding (MoU) for the Automatic Exchange of Information to help in efforts to fight tax evasion. The agreement would allow the tax authorities of the two countries to automatically provide each other with information about income from immovable property earned by… – Continue reading
The recent release of Ireland’s major strategy paper, ‘IFS2020 – A strategy for Ireland’s financial services sector 2015-2020’ addresses Ireland’s five year strategy in further developing the country as a global leader in the financial services sector. Over the past 25 years, Ireland’s international financial services sector has grown dramatically,… – Continue reading
Attorney-at–Law and Compliance Specialist We are living in a time where the tax landscape facing the Bahamian financial services industry is changing and evolving rapidly. On November 3, 2014, the Government executed a Model 1 Intergovernmental Agreement (IGA) with the US government to implement the latter’s Foreign Account Tax Compliance… – Continue reading
America’s tax code is riddled with problems. It imposes high rates on families, businesses, investors, and entrepreneurs. Its double taxation of capital gains and dividends creates a bias against savings and investment—activities essential for economic growth. Its convoluted system of deductions, credits, and exemptions distorts incentives and inefficiently allocates resources,… – Continue reading
U.S. Court of Appeals Rejects IRS Attempt to Apply Closing Agreement Retroactively to Support an Unrelated Proposed Adjustment to Tax SUMMARY From 2003 to 2006, U.S. corporations were entitled, in certain circumstances, to elect a one-time dividends-received deduction for dividends from controlled foreign corporations. BMC Software, Inc. made this election… – Continue reading
1.GENERAL QUESTIONS 1.1 Why is the Commission presenting a Tax Transparency Package? The Commission has made the fight against tax evasion and corporate tax avoidance a political priority, with a view to creating a socially and economically more efficient Single Market. While much has been done to advance this agenda… – Continue reading
Towards the end of last December, the cabinet passed resolutions representing the latest attempt to turn Thailand into an attractive location in which to establish an international headquarters (IHQ). This is the third attempt in a little over a decade to lure multinational companies to Thailand. The first regional operating… – Continue reading
Transactional work varies from jurisdiction-to-jurisdiction with the ebb and flow of various economic cycles, but a prevailing theme across the EMEA region has been that more and more advisory firms are urging taxpayers to prepare for the impact of the OECD’s base erosion and profit shifting (BEPS) action plan. Joe… – Continue reading
In 2013, STHL and its subsidiaries generated $38.6 billion in sales of crude oil, after purchasing $38.5 billion in crude and fuel products from third party and other companies from the SOCAR group. Malta has been hosting Azerbaijan’s state oil company (SOCAR) since 2007 thanks to its favourable tax regime… – Continue reading
New Zealand has a broad-based tax system consisting principally of: income tax fringe benefit tax resident and non-resident withholding tax (RWT and NRWT) goods and services tax (GST) Accident Compensation levies import tariffs and miscellaneous excise duties, and local authority rates on property. Stamp duty, gift duty and death duties… – Continue reading
The present French Tax Update will focus on (i) certain noteworthy tax courts decisions issued in the last months of 2014 and in the first months of 2015, and (ii) the so-called projet de loi Macron (Draft Macron Law) adopted by the Assemblée Nationale in February 2015 and now discussed… – Continue reading
I hold some U.S. stocks in a non-registered account and pay U.S. withholding tax of 15 per cent on the dividends. My tax slips provide the dividend and tax information in U.S. dollars. Given the currency fluctuations we’ve seen recently, how do I report these amounts on my Canadian income… – Continue reading
Republican Senators Marco Rubio and Mike Lee recently released a tax reform proposal that is a curious mix of principled pro-growth measures and populist middle-class relief. Where it sticks to principle, it is great. But where it veers into populism, the plan collapses into incoherence. The senators’ plan is a… – Continue reading
Your Isa investments don’t have to be limited to the UK. It’s also possible to hold shares in foreign firms in one. However, the rules for this are a little more complicated, and you need to be aware of an extra cost that can outweigh the tax benefits if you’re… – Continue reading
This article is the first in a series of four parts that will examine the Canadian and U.S. income tax implications when an employee employed by a Canadian entity is assigned temporarily to work in the U.S. This first article focuses on the importance of the determination of “residency” for… – Continue reading
AMERICANS in France are being asked to take urgent action in a bid to change harsh banking rules which an expats’ body says are “wrecking people’s lives”. AARO (Association of Americans Resident Overseas) says intrusive rules in America’s ‘FATCA’ law place such heavy reporting obligations on French banks with American… – Continue reading
ISLAMABAD: Signing of a Trade and Investment Framework Agreement (TIFA) between Pakistan and the United States has been put on the back-burner since America has become the largest export market for Pakistan with a volume of $3.7 billion, said US Secretary of Commerce, Penny Pritzker on Tuesday. A key member… – Continue reading
The regional operating headquarters (ROH) provisions that Thai tax authorities introduced in 2002 have never been popular, as they are difficult to understand and comply with. As a result, many businesses have bypassed Thailand and chosen Kuala Lumpur for their regional offices. Even a major revamp of ROH regulations in… – Continue reading
The long-awaited double tax agreements entered into by Kenya with South Africa and Mauritius respectively did not come into force on 1 January 2015 as expected. The treaty between Kenya and South Africa that was signed in November 2010 was ratified by Kenya in October 2014, following earlier ratification by… – Continue reading
For dividend investors, the allure of attractive and steady income streams is always a number one priority. In recent years, however, a new type of investment vehicle has emerged on Wall Street, promising to be the “next big thing” for dividend investors. A few years ago, many alternative energy companies… – Continue reading
