Category: Loans

HSBC files: Swiss bank hid money for suspected criminals

Documents detail customers who faced allegations including drug-running, corruption, doping and money laundering This article is the subject of a legal complaint made on behalf of Anura Perera. HSBC’s Swiss bank concealed large sums of money for people facing allegations of serious wrongdoing, including drug-running, corruption and money laundering, leaked… – Continue reading

U.S. companies may not be fleeing due to high tax rate, Reuters analysis shows

(Reuters) – When a series of big U.S. companies last year moved to reincorporate abroad in inversion deals, some Republican lawmakers and tax policy critics blamed the high U.S. corporate tax rate. Lowering it, they said, would keep companies from fleeing the country. But a Reuters analysis of the taxes… – Continue reading

U.K. rails against Shire’s tax tricks that suitors extol

Report skewers PwC for creation of Shire tax shelter it calls ‘tax avoidance on an industrial scale’ Shire’s Ireland address has made the specialty drugmaker a prime takeover target. AbbVie was attracted but dumped the $55 billion buyout when the U.S. Treasury Department threw cold water on the deal with… – Continue reading

Emirates Investment Bank assets under management jump 81% to Dh7.7 billion

Emirates Investment Bank yesterday said its total assets under management jumped 81 per cent last year as the economy boomed and the UAE’s safe haven status continued to attract funds from politically troubled countries in the Middle East and other parts of the world. Total assets under management increased to… – Continue reading

Upmarket leather goods firm employing Prime Minister’s wife Samantha Cameron based in tax haven

The upmarket leather goods firm employing the Prime Minister’s wife is based in a tax haven. Smythson is owned through a holding company in Luxembourg and linked to a secretive trust in the Channel Island of Guernsey, another well-known tax haven. The store in Central London’s New Bond Street, which… – Continue reading

Year in Review: Legislation and Guidance for Financial Institutions in 2014

2014 was a year replete with new legislative and regulatory initiatives impacting federally regulated financial institutions. The key initiatives introduced or implemented in 2014 are outlined in our annual year in review. PRUDENTIAL REGULATION: GUIDANCE FROM OSFI Proposed New Bail-in Regime for Large Banks On August 1, 2014, the Government… – Continue reading

Finance Ministry proposes amendments to Anti-Money Laundering Act 2010

ISLAMABAD: The Finance Ministry has proposed amendments to the Anti-Money Laundering (AML) Act 2010, in order to further improve it in lines with suggestions of the stakeholders regarding the anti-money laundering efforts and the Combating the Financing of Terrorism (CFT) regime. A well-placed source at the Finance Ministry told Customs… – Continue reading

TRANSFER PRICING IN SINGAPORE: PENALTIES, THRESHOLDS AND OTHER NEW REQUIREMENTS

Earlier this month, the Inland Revenue Authority of Singapore (IRAS) released revised transfer pricing guidelines, providing a better defined view of how the IRAS will handle transfer pricing matters. IRAS has explicitly noted that the arm’s length principle should be applied on a transaction-by-transaction basis, which suggests that each transaction… – Continue reading

COMPANY COMMENT: Offshore property funds; Shaft Sinkers

OFFSHORE property funds should outpace most local property funds in terms of capital growth this year. Many developed countries’ property markets are offering developers low interest rates amid increasing economic growth, while SA is expected to struggle to grow and a number of property funds here will be beset with… – Continue reading

How an Obscure Tax Loophole Brought Down Obama’s Treasury Nominee

(Bloomberg) -– So how did the previously obscure term tax inversions become part of Washington parlance, fodder for the next presidential campaign and the issue that helped derail a U.S. Treasury nominee? Thank, or blame, depending on your perspective, cutting-edge tax lawyers, populist Democrats, a banana seller, a drugmaker, a… – Continue reading

Revenu Québec keeps Bombardier findings secret

Quebec Finance Minister Carlos Leitão said in December he would ask Revenu Québec to look into whether Bombardier Inc. used Luxembourg as a way to avoid paying provincial taxes. What he didn’t say was that the results of those inquiries would remain secret. Washington-based International Consortium of Investigative Journalists discovered… – Continue reading

UPDATE 1-China developer Kaisa’s bonds jump but battle ahead for offshore creditors

* Bonds up around seven points * Kaisa missed bond coupon payment last week * Case could be test of China’s bankruptcy law (Adds comments, updates price) By Umesh Desai HONG KONG, Jan 13 (Reuters) – Bonds issued by Kaisa Group rose sharply on Tuesday after the embattled Chinese property… – Continue reading

Kaisa’s bonds rise but offshore creditors face waiting game ahead

Bonds issued by Kaisa Group rose sharply on Tuesday after the embattled Chinese property developer said it had received a waiver from HSBC Holdings on a loan it failed to repay in late December 2014. Kaisa, which is struggling with the sudden departure of senior executives, government officials blocking sales… – Continue reading

A two-minute nutshell on the UK’s proposed “Google Tax” – the “diverted profits tax” or “DPT”

The UK is proposing to introduce a unilateral, non-OECD co-ordinated anti-BEPS provision, referred to in the media as the “Google Tax”, with effect from 1 April 2015. The draft provision is very complex, and it will be time consuming to assess its potential impact on many common cross-border business structures…. – Continue reading

Bank of America warns of ‘lethal’ damage to China’s financial system as deflation deepens

‘Deflation, Devaluation, and Default’ loom in China this year. The denouement for Shanghai’s bourse will not be pretty, says the US bank. China is at mounting risk of a financial crisis this year as growth sputters and deflationary pressures trigger a wave of defaults, Bank of America has warned. The… – Continue reading

A taxing tale of two peak bodies

Four days out from Christmas, Blind Citizens Australia (BCA), Deaf Australia, Homelessness Australia and Down Syndrome Australia learned they were to be subject to federal government funding cuts. New Social Services Minister Scott Morrison assured concerned parties that frontline services to the disabled would not be cut, just grants to… – Continue reading

The Outlook for Taxes in 2015

The new year could bring important changes to the tax landscape. Here are several issues that will affect how much taxpayers owe for 2015 and beyond: Federal tax policy There is serious talk of overhauling the federal tax code. “There appears to be a consensus” on making changes, says Stephen… – Continue reading

Internal Revenue Service Getting Tough on Production of Evidence From Current and Former Microsoft Executives In Connection With Its Transfer Pricing Audit

In recent court filings made in various federal district courts in Washington and California, the Internal Revenue Service is seeking to enforce testimonial summonses issued to current or former Microsoft employees, including former CEO Steven A. Ballmer. The summons had been issued earlier this fall. Microsoft’s outside tax counsel responded… – Continue reading

South Africa urged to finalise renegotation of Mauritius tax treaty

CAPE TOWN — South Africa needs to finalise the renegotiation of its tax treaty with Mauritius as soon as possible to prevent the loss of large sums of money through “treaty shopping” the Davis tax committee has urged. The committee released its interim report on ways to prevent base erosion… – Continue reading

Move to stop multinationals artificially loading debt overseas to dodge tax

The OECD is urging governments to tackle interest payments made by multinationals and their subsidiaries as part of a global crackdown on profit shifting. The aim is to also stop companies artificially loading debt in no-tax or low-tax jurisdictions to reduce their tax bills. It comes as the government backs… – Continue reading

Scorecard of Offshore Tax Crimes: Advisers, Bankers and Lawyers

A mixed success record has been notched up by the US Justice Department when it comes to prosecuting offshore bankers, advisers and lawyers accused of assisting American taxpayers cheat their taxes. The United States Government, from 2008, has charged 38 individuals, including Swiss bankers like the top three managers of… – Continue reading

Bank Leumi to Pay $400 Million in U.S., N.Y. Tax Probes

Bank Leumi Le-Israel Ltd. (LUMI) agreed to pay $400 million and admit it helped American clients evade taxes for a decade, in a case showing that U.S. prosecutors and New York regulators are extending their probes of offshore tax evasion beyond Switzerland. The Justice Department filed a conspiracy charge today… – Continue reading

OECD sets out options for restricting tax deductions for interest

Tax deductions for interest payments could be restricted on a group wide basis, by reference to a fixed ratio, or by a combination of these two solutions, in order to counteract international tax avoidance the Organisation for Economic Co-operation and Development (OECD) has suggested. 19 Dec 2014 Tax Corporate tax… – Continue reading

Cayman begins to see a rise in hybrid funds

UBS Fund Services has had one of its strongest years in terms of winning new clients according to Monette Windsor (pictured), who heads up the Cayman Islands business.   “We’ve invested heavily in our business development team this year and we’ve had to beef up our client onboarding team. We have 165… – Continue reading

Germany’s increasingly tough TP audit environment presents challenges for taxpayers

Transfer pricing has been an area of high importance for years. We are seeing that multinational companies operating in Germany are being increasingly examined by tax auditors. The level of transfer pricing expertise of the tax auditors is also increasing. Therefore, the transfer pricing environment in Germany is getting more… – Continue reading

The trouble with Hockey’s tough talk on tax avoidance

Where do things stand with the government’s efforts to combat corporate tax avoidance and evasion, one of its priorities as G20 chair in 2014? The headlines suggest a contradictory stance. The latest headline is that Treasurer Hockey ‘backflips on tax laws to target multinational profit-shifters’. This refers to the announcement… – Continue reading

Credit-Rating Firms Fall Short on ABS, European Regulator Says

Credit ratings of asset-backed securities fall short of quality standards, according to the European regulator for Standard & Poor’s, Moody’s Investors Service (MCO) and Fitch Ratings. Debt-rating companies lack “quality controls over information used and received from data providers,” have delayed annual rating reviews, and must strengthen “the review of… – Continue reading

Financial Group Wants More Limits on Corporate Inversions

The FACT (Financial Accountability and Corporate Transparency) Coalition today submitted comments to the Treasury Department praising their previous actions to limit inversions while also calling for additional measures. The proposals come as a part of the open comment period for Notice 2014-52, Rules Regarding Inversions and Related Transactions, originally issued… – Continue reading

ATO chief identified tax ‘abuse’ by multinationals before Joe Hockey backed away from reform pledge

The head of the Australian Tax Office, Chris Jordan, has described a tax lurk for multinational companies that is being retained by the Abbott government as having been “abused” by foreign corporations at a cost of “hundreds of millions of dollars” a year to the Commonwealth. As revealed by Fairfax… – Continue reading

The inversion backlash

Something strange happened in 2014 — Americans became very interested in corporate tax policy. It started in the spring, when U.S.-based pharmaceutical giant Pfizer, which produces blockbuster drugs like Lipitor and Viagra, floated a possible merger with its British-based rival AstraZeneca. Normally a merger of that size would make a… – Continue reading

Packer’s PBL in latest tax leak: report

Publishing and Broadcasting Limited (PBL) allegedly negotiated a secret deal with the Swiss government when James Packer was chief executive officer, which set a tax rate of less than 2.15 per cent for the media group’s intra-company loans, The Australian Financial Review reports. According to correspondence obtained by the newspaper,… – Continue reading

Inversions Are Often Last Stop for Avoiding U.S. Taxes

The surge in U.S. companies avoiding taxes by taking a foreign address has been condemned by President Barack Obama and stirred a policy debate in Congress. What’s often overlooked is that these “inversions” are typically a final step in a hopscotch of multinational tax dodging. Many companies invert after years… – Continue reading

BEPS Transfer Pricing Update

Background On 15 December, 2014, the OECD hosted a webcast to update the global tax community on progress under the Base Erosion and Profit Shifting (“BEPS”) Plan.  This year, the OECD produced 10 different reports (“BEPS Reports”) covering several actions specific to transfer pricing. This latest OECD webcast summarised efforts… – Continue reading

Jersey: The Shifting Position Between Lawful Tax Avoidance & Unlawful Tax Evasion

1. The traditional attitude to tax avoidance is encapsulated in the judgment of Lord Tomlin in the English case of IRC v Duke of Westminster (1936): “Every man is entitled if he can to arrange his affairs so that the tax attaching under the appropriate Acts is less than it… – Continue reading

Foreign Holders of Mexican Debt Securities Should Hold a Little Longer

Gains derived from the sale of Mexican public debt instruments listed abroad between two foreign tax residents will soon be exempt from Mexican tax. Currently, for Mexican income tax purposes, any gains derived from the transfer of publicly-traded bonds, securities and other credit instruments are treated as interest. If the… – Continue reading

New Luxembourg leaks reveal James Packer’s PBL in secret Swiss tax deal

A secret deal with the Swiss government negotiated by media group Publishing and Broadcasting Ltd when James Packer was chief executive set a tax rate of less than 2.15 per cent on PBL’s intra-company loans. “We do have good news for you!” Ernst & Young Swiss partner Markus Huber wrote… – Continue reading

S&P: Bahrain outlook revised to negative on weakening fiscal position; ‘BBB/A-2’ ratings affirmed

On Dec. 12, 2014, Standard & Poor’s Ratings Services revised its outlook on the Kingdom of Bahrain to negative from stable and affirmed its ‘BBB/A-2’ long- and short-term foreign and local currency sovereign credit ratings. “At the same time, we revised our outlook on the Central Bank of Bahrain to… – Continue reading

American lawmakers will put their rubber stamp on global profit-shifting

All those Dutch sandwiches, double Irishes and Luxembourg, uh, lunchboxes that US multinational companies use to defer taxes and shift profits abroad are expected to be re-empowered today when the Senate votes to enact a one-year tax extension package. Included in the package is a renewal of two breaks, one… – Continue reading