Category: Dividends

GUEST COLUMN: Protect your investments

Many business owners have substantial personal assets invested in their business. This can have significant implications, not only for you and your business, but also for your family’s financial security. To protect your investment, both business and personal, your business strategy should include carefully structured tax-planning components to ensure you… – Continue reading

BBC star Jeremy Vine made his ten-year-old daughter a company shareholder to help lower his tax bill by channelling funds through private firm

BBC’s Jeremy Vine appears to have used daughter to avoid tax payments Daughter Martha, aged 10, is shareholder in Jelly Vine Productions The presenter has been funnelling cash through the limited company Controversial move highlights BBC practice of paying some presenters off the books using money from millions in earns… – 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

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

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

Taxing times: does the UAE remain unaffected?

Al Tamimi & Company – Advocates and Legal Consultants Surabhi Singhi Kataria Tax planning has always been a topic of international debate and adjudication. The borderlines between permitted tax planning/avoidance and unlawful tax evasion have occupied the centre stage across the globe with several modern economies emphasizing the need for… – Continue reading

Cyprus: Cyprus IP Company: The Breathless Conundrum Solved

The breathless conundrum for IP companies is four-fold: not only should royalties be taxed at a low rate in order to maximise profits; but also research and development (R&D) or acquisition costs should be considered as allowable expenses to the maximum possible effect, whilst also the jurisdiction where the IP… – 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

The Common Reporting Standard: CRS brings the walls tumbling down

A country known for its clocks, chocolate and most importantly banks, the agreement by Switzerland’s government to share details of those super-secret bank accounts is one that will change the world at large. Gone are the days of the elusive Swiss bank account. The arrival of Common Reporting is upon… – 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

US Report Criticizes Repatriation Tax Proposals

A repatriation holiday would have a minimal economic impact and would be the wrong way to pay for the Highway Trust Fund or any other project, according to a new report by the Heritage Foundation. There have been differing congressional proposals recently to change the tax treatment of the USD2… – 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

For Bigger Bank Dividends, It Could Pay to Go International

Following the financial crisis, dividend yields from American banks have remained below the level many income investors are looking for. While all four major American banks yield less than 3%, U.S. investors can still get fat bank dividends by looking abroad. The United Kingdom London has long been a financial… – Continue reading

Singapore, France sign pact for Avoidance of Double Taxation

PARIS: Singapore and France signed an amended Agreement for the Avoidance of Double Taxation (DTA) to lower withholding tax rates for dividends and new anti-abuse provisions. The most notable changes are the following: Withholding tax rate for dividends is reduced to 5 percent (from 10 percent previously) if the beneficial… – 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

Vern Krishna: Corporate barons vote with their feet

The abolition of unfair taxes was one of the foundational principles of Magna Carta, a document that King John assented to on June 15, 1215 at Runnymede, England. Taxation must be fair, and requires the consent of the people. There is no more unfair aspect of fiscal law than retroactive… – Continue reading

Treaty shopping and BEPS considerations in the M&A context

Every acquisition requires careful tax planning early on in the process, especially when dealing with cross border acquisitions. One important consideration when a foreign company plans to acquire a Canadian company is the impact of any tax treaties that currently exist between the two jurisdictions. Tax treaties effectively reduce tax… – Continue reading

Singapore and France revise their tax convention

Singapore and France signed a revised Agreement for the Avoidance of Double Taxation (DTA) on 15 January 2015, which is not yet in force. The new DTA provides for lower withholding tax rates for dividends and new anti-abuse provisions. The most notable changes are the following: 1. Withholding Tax Withholding… – Continue reading

Private banking: shrinking margins, stagnating client base

The following article is from the February 13-26 print edition of the Budapest Business Journal. While the 2008 financial crisis questioned the justification for structured products globally, the recent decision of the Swiss National Bank to scrap the euro peg has revealed risks – not previously perceived by domestic investors… – Continue reading

Tax haven explosion puts hole in corporate tax

Confidential documents obtained from the Tax Office under the Freedom of Information Act show Australia’s corporate tax base is in crisis because of the explosion in tax haven dealings by multinational companies. The alarming data in these internal documents is at odds with the public position of the Australian Tax… – Continue reading

Lord Fink: tax avoidance is normal in British society

Lord Fink, the former Conservative treasurer who threatened to sue Ed Miliband over his comments on tax avoidance, has conceded that the practice is normal in British society. The peer – a multimillionaire former hedge fund manager turned Conservative donor and philanthropist – also said he did take “vanilla” tax… – Continue reading

Singapore inks tax agreements with France and Uruguay

SINGAPORE: Singapore has signed agreements with France and Uruguay for avoidance of double taxation (DTA). In the agreement with France, the revised DTA offers improved terms for businesses, such as lower withholding tax rates for dividends and includes anti-abuse provisions. The signing took place in Singapore between Singapore Deputy Prime… – Continue reading

ATO digs for dirt on miners

The Australian Taxation Office has identified at least 36 Australian companies with related entities in Switzerland that may have engaged in tax evasion costing billions in possible tax revenue. According to internal communications between the ATO and the Department of Treasury the bulk of companies under investigation are based in… – Continue reading

FactCheck: is Australia’s corporate tax rate not competitive with the rest of the region?

“Well, Jon, the Government’s about to bring in a 1.5% corporate, or company, tax cut from the 1st of July. That’s something that obviously we support, because (the) corporate tax rate at 30% is not competitive with the rest of the region and we need to drive that down.” –… – Continue reading

The rise of pass-throughs

Call it the pass-through revolution. The U.S. has been losing about 60,000 conventional corporations a year, according to the Tax Foundation. It’s lost 1 million since 1986, the foundation said. Meanwhile, the number of pass-through entities has exploded. “More than 60 percent of U.S. business profits are now taxed under… – Continue reading

Switzerland, Liechtenstein Conclude DTA Talks

Switzerland and Liechtenstein have concluded negotiations toward a new double tax agreement (DTA), which should enter into force from January 2017. Switzerland’s Federal Department of Finance (FDF) announced on February 5, 2015, that talks concluded on February 2. The FDF expects the deal to be signed this summer and, pending… – Continue reading

Tax row engulfs Rexam predator Ball Corporation as a third of the US giant’s subsidiaries are based in tax havens

The US giant trying to take over Britain’s biggest drinks can maker in a £4.3billion deal is a serial user of tax havens. Ball Corporation is in talks to buy FTSE 250-listed Rexam that would create an industry goliath. The deal could be finalised as early as this week, and… – Continue reading

As Middle Class Flees, Puerto Rico Tries Luring Rich People

Bond trader Ben Eiler swapped life in suburban Georgia for an island in the Caribbean, and he didn’t even have to apply for a visa. The towering 38-year-old native of Arkansas is one of at least 250 people who’ve accepted Puerto Rico’s invitation to well-heeled U.S. citizens to move to… – Continue reading

New tax incentives draw investors to Puerto Rico as middle class continues flight from island

As middle class flees, Puerto Rico tries luring rich people The towering 38-year-old native of Arkansas is one of at least 250 people who’ve accepted Puerto Rico’s invitation to well-heeled U.S. citizens to move to the island and enjoy life without taxes on capital gains, an enticing offer for those… – Continue reading

Croatia: UK And Croatia Signed Double Taxation Avoidance Agreement

Croatia and the UK have signed an Agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital gains. The Agreement was duly signed on January 15th, 2015 and it shall enter into force when both countries complete their… – Continue reading

China Stepping Up Scrutiny of Tax Evaders

Beijing is going after base erosion and profit shifting, and multinationals could get caught in the crosshairs. China is continuing to step up its efforts to curb what it sees as cross-border tax evasion by foreign-owned companies, announcing it will review how companies move money and allocate costs among their… – Continue reading

FY 2016 Budget Tax Proposals Target Insurance Companies

On February 2, the Obama Administration released its fiscal year 2016 budget (FY 2016 Budget). The hallmarks of the FY 2016 Budget are proposals that would impose (i) a minimum tax on the current foreign earnings of U.S. corporations and their controlled foreign corporations (CFCs) and (ii) a one-time 14%… – Continue reading

China to Crack Down on Tax Collection From Multinational Companies

HONG KONG — China’s tax officials plan to step up efforts to collect taxes from multinational corporations in the latest of a series of moves in the last year, mostly against Western companies. The activities have included police raids on the headquarters of companies’ China operations and heavy fines under… – Continue reading

Legal flash Shanghai – 2014 special edition – Update on tax regulations 2014

In 2014, China continued to develop its taxation system affecting domestic and crossborder transactions. This “Legal Flash – Special Edition 2014” highlights the most significant tax updates of the year. Please see our monthly legal flashes for more information and analysis here. Taking a step-forward on anti-avoidance provisions, the State… – Continue reading

President Obama’s fiscal year 2016 revenue proposals

SUMMARY On February 2, 2015, the Obama Administration (the “Administration”) released the General Explanations of the Administration’s Fiscal Year 2016 Revenue Proposals (commonly known as the “Green Book”), which contains significant detail about the fiscal year 2016 revenue proposals. This memorandum discusses certain aspects of the Green Book relating to… – Continue reading