Category: Offshore Investments

IRS releases final rules on Section 965 repatriation taxes

The Internal Revenue Service and the Treasury Department issued final regulations spelling out how U.S.-based companies will have to pay repatriation taxes on offshore profits under Section 965 of the tax code. The IRS released proposed regulations on Section 965 in August, and the proposed rules went through a public… – Continue reading

FBR probes undeclared offshore assets of resident Pakistanis

KARACHI: The Federal Board of Revenue (FBR) has sought explanations from the resident Pakistanis regarding their undeclared foreign assets, sources said on Tuesday. These assets were identified under the Automatic Exchange of Information (AEoI), they added. Large Taxpayers Unit (LTU) Karachi summoned around 100 people from Sindh Region to appear… – Continue reading

Proportion of HNWIs investing offshore rises

The wealthy are showing a keen interest to invest offshore, as the HNWIs seek to achieve benefits from global diversification and gain tax efficiencies. The proportion of HNWIs who invest offshore has risen from 11.2% in 2014 to 16.9% by December 2018, , according to GlobalData’s HNW Offshore Investment survey…. – Continue reading

Tax havens refuse cooperation with Pakistan

Pakistan has been unable to get much cooperation from 11 countries known as tax havens around the world to share information on offshore wealth amid a global clampdown on tax evasion. Under the Organisation for Economic Cooperation and Development’s (OECD) new automatic exchange of information programme, effective since September 1,… – Continue reading

ASEAN taxation cooperation via automatic information exchange

IN 2015, the ASEAN Economic Community (AEC) Blueprint 2025 was adopted as part of the ASEAN 2025: Forging Ahead Together plan. This collaboration charts the broad trajectories of ASEAN economic integration from 2016 to 2025. It aims to strengthen and reinforce by 2025 these five AEC characteristics: 1. A highly… – Continue reading

Even the CBO Says the GOP Tax Reform Will Incentivize Corporate Offshoring

The Congressional Budget Office’s analysis of the new tax law suggests it could incentivize companies to offshore investments and jobs, which is directly at odds with GOP claims about the tax law. After the release of the GOP’s tax reform plan, several outlets, including the Prospect, noted that new tax… – Continue reading

UK property tax changes affect GCC nationals

  PROPERTY in the UK, particularly London, has always been popular with GCC investors for many years. It has remained a safe haven and an attractive destination for investors and their families from the GCC region perhaps more than any other major city. Depending on the level of investment, well… – Continue reading

Foreign investors oppose tax amnesty scheme for offshore assets

KARACHI: Foreign investors expressed concern over a proposed tax amnesty scheme to bring back offshore investments, terming it as an injustice with compliant taxpayers, officials said on Monday. Overseas Investors’ Chamber of Commerce and Industry (OICCI), representing major foreign companies in Pakistan recently shared its concerns, through a letter, with… – Continue reading

Tax on offshore investments: time to come clean

The South African Revenue Service (SARS) launched the Special Voluntary Disclosure Programme (SVDP) in October 2016, providing taxpayers with the opportunity to make good on any tax and/or exchange control contraventions of which they may be guilty in relation to offshore investments. The nine-month window period opened on October 1,… – Continue reading

FBR initiates scrutiny of offshore transactions

KARACHI: The Federal Board of Revenue (FBR) has initiated audit of all those taxpayers who have made offshore transactions during the last six years, sources said on Tuesday. “All corporate and individual taxpayers, who have made offshore investments, have been selected for audit to check the tax concealment,” an official… – Continue reading

Cayman Islands’ investment in S. Korea tops 9.2 tln won

SEOUL, Feb. 16 (Yonhap) — The Cayman Islands became the largest investor as a tax haven country in the South Korean market last year, data showed Thursday, amid suspicions that some of the money could be owned by South Koreans disguised as foreign investors in an attempt to avoid taxes…. – Continue reading

China’s banking regulator issues guidelines on outbound investment

China’s banking regulator issued guidelines on Wednesday calling for the country’s financial institutions to strengthen their control and management of funding for outbound investment. The guidelines are the latest new rules on overseas investment as Beijing moves to clamp down on cross-border capital outflows and halt questionable investments. The China… – Continue reading

Govt poised to regulate offshore investments

ISLAMABAD: The government has stepped up to check corruption and regulate offshore investments in a bid to promote transparency and good governance, finance minister said on Tuesday. “New measures, such as the companies’ global register of beneficial ownership, will curb corruption, help (government) address challenges related to offshore investments and… – Continue reading

HMRC takes aim at tax dodgers hiding foreign income

The taxman plans to crack down on people who hide earnings from offshore investments, with greater powers to impose tougher penalties. People who do not reveal income from foreign accounts and investments to HM Revenue & Customs (HMRC) could be hit with penalties of three times the amount of tax… – Continue reading

Jakarta Plans Tax Haven Near Singapore

Indonesia has defined two islands near Singapore as its own tax havens to prevent taxpayers from keeping their assets offshore – in Singapore, for example. The two islands identified by Indonesia are Bintan and Rempang, according to a report on Monday in the Singaporean daily «Straits Times» and a story… – Continue reading

Monitor offshore investments, IMF tells Mauritius

The International Monetary Fund (IMF) has askedMauritius to set up a ‘macro-prudential authority’ to monitor the offshore investments from the island. One of the largest destinations of such offshore investments is the Indian stock market. The proposed authority will have a central role for the banking regulator, the Bank of… – Continue reading

Canada Revenue offered amnesty to wealthy KPMG clients in offshore tax ‘sham’

Federal authorities demanded secrecy in no-penalty, no-prosecution deal to high net worth Canadians The Canada Revenue Agency offered amnesty to multi-millionaire clients caught using what’s been called an offshore tax “sham” on the Isle of Man — a reprieve that was supposed to remain secret and out of the public… – Continue reading

Zimbabwe’s Central Bank Blames Offshore Accounts for Economic Decline

WASHINGTON — Zimbabwe’s central bank governor, John Mangudya, on Thursday blamed the sustained decline of the country’s economy on illicit cash flows, saying more than a billion dollars was externalized last year. Presenting his 2016 Monetary Policy, Mangudya said some $684 million was exported to foreign accounts by individuals while… – Continue reading

Global Private Equity Newsletter – Winter 2016 Edition: Hong Kong Profits Tax Exemption for Private Equity Funds

The Inland Revenue (Amendment) (No.2) Ordinance 2015 (the “Amendment Ordinance”) came into effect on July 17, 2015, extending Hong Kong profits tax exemption to offshore private equity (“PE”) funds. Profits Tax Exemption prior to the Amendment Ordinance This is a welcome development for the private equity industry since, in the… – Continue reading

IRS goes after Royce Gracie claiming tax underpayment, fraud totaling $1.15 million

Royce Gracie isn’t scheduled to fight at Bellator 149 until February, but he’s in a serious fight with the IRS over his taxes, including whether he rightfully claimed a tax credit for the poor. Remember the scrawny guy in a gi who smoked the field at UFC 1 and had… – Continue reading

B.C. government, with accounts flush from property tax earnings, cool on petition calling for real estate market intervention

Spokesman for B.C. finance minister downplays tax loophole issue A new petition urging B.C. politicians to limit offshore investment and exploitation of tax loopholes in Vancouver real estate is getting a cool reception from Victoria as provincial coffers overflow with property transfer tax revenues in a red-hot housing market. The… – Continue reading

PATH Act Enacts Notable Changes to REIT and FIRPTA Provisions

On Friday, December 18, 2015, President Barack Obama signed the “Protecting Americans from Tax Hikes Act of 2015” (“PATH Act”). Our December 10, 2015 client alert discussed significant proposed changes to the rules governing real estate investment trusts (“REITs”) and the Foreign Investment in Real Property Tax Act of 1980… – Continue reading

New dividend withholding tax of 1.69 per cent for foreign shareholders

Non-Belgian shareholders with a participation in a Belgian company with an acquisition value of at least €2.5m (but not reaching the 10 per cent participation threshold under the Parent–Subsidiary Directive) are now entitled to the Belgian participation exemption regime. In C-384/11 (Tate & Lyle Investments), the European Court of Justice… – Continue reading

Exclusive: More banks pay no UK tax, Labour wants tougher approach

Two more investment banks have reported paying zero tax in Britain in 2014, prompting the opposition Labour party to urge the government to reverse a tax change it made for banks last year. Citigroup and Credit Suisse disclosed in the past fortnight that their main UK subsidiaries paid no corporate… – Continue reading

Cyprus: Latest Tax Updates To Attract International Corporations Investing Through Cyprus

As the year comes to an end, the Cyprus Parliament in its last session before the holidays passed a series of tax updates attempting once again a balancing act between flexibility and tax transparency. Some of the most important provisions passed include the FOREX Neutralisation which targets the significant exchange… – Continue reading

Global dragnet puts pressure on tax evaders as year-end deadlines loom

Tax cheats are facing a series of year-end deadlines to come clean, as an international dragnet affecting both wealthy Canadians with offshore accounts and Americans in Canada who have failed to file U.S. tax returns keeps tightening. Lawyers say some Canadians with Swiss bank accounts have received letters demanding written… – Continue reading

Latin America business potential for Island

The World Captive Forum takes place in Florida next month Bermuda’s business chiefs will be out in force at next month’s World Captive Forum. The event, to be held in Florida, will include several speakers from Bermuda including lawyers, regulators and business leaders. And Bermuda delegates will use the event… – Continue reading

BEPS Action Plan 2: Neutralizing the effects of hybrid mismatch arrangements

Hybrid mismatch arrangements are the focus of the 2-part Action Plan 2 of the Organisation for Economic Co-operation and Development’s (OECD’s) Base Erosion and Profit Shifting (BEPS) initiative. Hybrid Mismatch Arrangements abuse differences in the tax treatment of an instrument (i.e., a hybrid instrument) or an entity (i.e., a hybrid… – Continue reading

UK taxman warns expats that tax evasion penalties will get tougher in 2016

With a new year on the horizon it is often at this time when people start thinking about fulfilling a dream of moving abroad and making plans. Others may be thinking about moving back home. For people paying tax in the UK, the country’s tax man has come up with… – Continue reading

Column: MNEs must start test runs fast

Group companies, irrespective of the jurisdiction, will have to conform to common standards The Organization for Economic Cooperation and Development (OECD) recently released 15 action-plans to address the issue of “Base Erosion & Profit Shifting” or BEPS, which has led to misalignment between where taxes are paid and where value… – Continue reading

Out of Bangladesh

According to a research report titled “Illegal Financial Flows from Developing Countries: 2004-2013”, recently published by the Washington based research institute Global Financial Integrity (GFI), Bangladesh stands 26th in the list of 149 developing nations, in terms of flight of capital including money laundering (The Daily Star, December 10, 2015)…. – Continue reading

Incentives for innovations in Intellectual Property (IP) and State Aid: the current legal framework

A review of the application of EU State Aid rules is crucial for determining if a national tax incentive scheme for IPs is being implemented lawfully. The result of such a compatibility analysis is not certain. In some decisions, the Commission considered ‘Tax Box’ regimes as not being State aid… – Continue reading

Will Sri Lanka follow the dismal road to tax havenry?

An article in today’s edition of Sri Lanka’s Mirror newspaper draws attention to that island’s plans to develop an offshore financial centre in Colombo. According to the article the proposal is modelled on the Dubai International Financial Centre, a notorious centre for moneylaundering and illicit financial flows. Now this doesn’t… – Continue reading

British Virgin Islands: What Structure Should I Use For My Offshore Fund?

There are a number of ways to structure your offshore fund and the best option for you will depend largely on the location of the manager, your investor base and the type of investments that the fund will make. I have set out a summary of the three most common… – Continue reading

UK releases Finance Bill clauses and consultation documents

Executive summary On 9 December 2015, the UK released draft clauses for Finance Bill 2016 as well as consultation documents. The key items released include: A new requirement for large businesses to publish their tax strategies as they relate to or affect UK taxation. This sits alongside new ‘special measures’… – Continue reading

DYK: Dividend from investing in shares of foreign companies is taxable in India

Dividend income from foreign companies is not treated the same as dividend from domestic companies, for tax purposes The two key advantages of investing in equities are the possibility of higher returns and tax efficiency. In the long term, equity has outperformed other asset classes. And, according to Income tax… – Continue reading

Icahn Says Stop Corporate Inversions By Giving Tax Break

Billionaire investor Carl Icahn has a strong opinion on almost every subject, especially politics. He’s also quite happy to share that opinion with anyone who will listen to or read what he has to say. Icahn’s comments this week on how to stop future tax-motivated corporate inversions such as the… – Continue reading

Common Reporting Standard Enters Into Effect for Investment Funds in Early Adopter Jurisdictions

Many jurisdictions have agreed to implement the Organisation for Economic Co-operation and Development’s multilateral system of automatic exchange of information called the “Common Reporting Standard” (CRS).  In furtherance of its objectives, the CRS imposes a variety of diligence and reporting requirements on “financial institutions,” which includes many master funds, offshore… – Continue reading

Hundreds more evaders caught by the taxman: Number of fraudsters prosecuted for fiddling the system up 58% in a year

Hundreds more people who fiddled their tax have been prosecuted in the past year, it was revealed today. HM Revenue & Customs (HMRC) has said its assault on tax evasion has produced a 58 per cent rise in convictions with criminals getting a total of 400 years in jail. HMRC… – Continue reading

Investing in Morocco

Over recent years, Kingdom of Morocco has created a legal and regulatory framework very attractive for foreign investors. In addition to its political stable environment, a recent series of tax treaties with numerous countries and reforms in almost all of its sectors of activities, in conjunction with its creation of… – Continue reading

Tax info sharing kicks in 2017

Come 2017, tax information on all foreign nationals holding bank accounts or other financial holdings in Cayman will be automatically shared with tax authorities in their home countries when the Mutual Administrative Assistance in Tax Matters convention kicks in. Maples, in a Cayman Islands Automatic Exchange of Information update statement… – Continue reading

Senate approves tax treaties with Turkey, Italy & Germany

The Senate concurred, after hearing, the ratification of tax treaties between the Philippines and the governments of Italy, Germany and Turkey that will prevent double taxation. Sen. Juan Edgardo “Sonny” Angara said the approval on third and final reading of Senate resolutions 1540, 1541, 1542 on the double taxation avoidance… – Continue reading