Earlier this week the State Department released its latest statistics for people who have renounced their US citizenship. 2015 was another record year, with 4,279 people divorcing themselves from the US government and heading to greener pastures elsewhere. This was the third year in a row that broke the previous… – Continue reading
Non-competition agreements can be a valuable tool for purchasers who want to protect their investments in new businesses. However, non-competition agreements can have unintended and unexpected tax consequences, particularly to sellers who grant non-competition agreements to purchasers. The Income Tax Act (Canada) (the Act) contains specific provisions regarding the taxation… – Continue reading
As if the mental harassment of delayed delivery of a house is not bad enough, you could also be losing 85% of the tax benefit on your home loan, for no fault of yours. A tax deduction of Rs 2 lakh per year is allowed against payment of interest on… – Continue reading
In tax law, the concept of residency is used to determine tax liability based on whether there is a sufficient connection between an individual or legally recognized entity and a jurisdiction such that the jurisdiction is justified in taxing such individual or legally recognized entity on their worldwide income. Generally,… – Continue reading
Taxing decisions With highly efficient labour markets, a solid institutional environment and a strong banking system, Canada has long been considered one of the most competitive nations in the world. In fact, in its most recent rankings in 2014, Bloomberg declared Canada the second best country in the world for… – Continue reading
Voluntary Disclosure & CRA Annual Report to Parliament – General Information CRA has provided the latest statistics about the tax amnesty or voluntary disclosure program (VDP) for the previous fiscal year. CRA provides an annual report to parliament that provides a wealth of information about its activities over the past… – Continue reading
To search for a tax haven to free yourself from tax burden, you need not have to go to Bermuda, Isle of Man, Cayman Islands, Dubai, Switzerland, Mauritius or any other country. It is just right here in India where we are living, hidden in various sections of our Income… – Continue reading
As part of what it describes as a ‘relentless’ effort to crack down on tax avoidance, HMRC has put out two publications highlighting problems with contractor loan schemes and misleading claims from scheme promoters, in a bid to deter taxpayers from any involvement In its Spotlight 29 document, HMRC says… – Continue reading
In the first part of this article, we talked about provisions of the Organisation for Economic Co-operation and Development’s (OECD’s) final report on Base Erosion and Profit Shifting (BEPS) Action Plan 14, which reflects the commitment of participating countries to implement substantial changes in their approach to dispute resolution in… – Continue reading
The OECD’s final reports on the Base Erosion and Profit Shifting (BEPS) Project aim to target aggressive tax planning strategies which have the effect of shifting profits from high tax jurisdictions to low tax jurisdictions. The BEPS Project has been divided into 15 Actions, of which one of the most… – Continue reading
At least this is the goal – member states safeguarding their social models by preventing trans-border operating multinational companies from avoiding “their fair share” of the tax burden. According to the European Commission, small and medium-sized enterprises in the EU pay 30% higher tax burden than large multinational companies. With… – Continue reading
The present French Tax Update will focus on an overview of several noteworthy publications, including decisions issued during the past few months by the French Administrative Supreme Court (Conseil d’Etat) and French Constitutional Court (Conseil Constitutionnel), as well as the European Commission decision in respect of the Belgian Excess Profit… – Continue reading
The announcement of another tax and exchange control amnesty in this year’s budget is keenly awaited by some South African taxpayers. The looming implementation of the Common Reporting Standard for the automatic exchange of financial information between more than a hundred countries seems to be fueling the desire for another… – Continue reading
Democrats are balking at tying up $19 million to fund tax credits in 2016, fearing the money might be needed for more urgent needs. MAINERS ALREADY HAVE BEGUN FILING THEIR TAX RETURNS, BUT THE LEGISLATURE HAS YET TO DECIDE WHETHER IT WILL ADOPT AT THE STATE LEVEL A GROUP OF… – Continue reading
The British Virgin Islands (BVI) Court tightens up on creditors raising spurious disputes and relying on arbitration clauses to avoid insolvency. There has been a recent trend in the BVI whereby debtor companies have sought to identify what appear to be spurious disputes and then rely upon arbitration clauses in… – Continue reading
Finance minister will commission an impact assessment on on how a proposed package by the European Commission to clamp down on aggressive tax planning will impact Malta’s economy Malta will resist any attempt by the European Commission to reduce sovereignty over its own fiscal affairs, finance minister Edward Scicluna pledged…. – Continue reading
On December 8, 2015, law No. 13,202 was published, as a result of the conversion of Provisional Measure No. 685/2015 into law. In addition to providing for the Program for Reduction of Tax Litigation (PRORELIT, for its acronym in Portuguese), said law addressed issues such as the scope of double… – Continue reading
BEIJING: China is planning a pilot programme to allow selected commercial banks to set up equity investment arms to take direct stakes in technology firms, people familiar with the matter said, a move aimed at giving lenders a chance to buy into a high-growth industry while stoking competition with private… – Continue reading
Those who have been hiding their income or wealth overseas had better think again, as Korea will soon be exchanging financial information with multiple countries, including tax havens. They are advised to voluntarily report it to the government before the end of March to be given a grace period, said… – Continue reading
On January 15, 2016, Canada and Taiwan entered into an “Arrangement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income” (the “Arrangement“). The Arrangement will apply to amounts paid or taxation years beginning after January 1 of the year following the… – Continue reading
Let’s take a moment to compare the world today to before the Global Financial Crisis struck roughly eight years ago. In this short period of time, US federal government debt has DOUBLED. The Federal Reserve now holds $2.4 trillion of that debt, up from $479 billion. Interest rates, which were… – Continue reading
The People’s Bank of China supports the country’s currency and fends off short sellers in the world’s largest overseas yuan market (Beijing) – The offshore yuan market in Hong Kong has been shaken to the core by weeks of volatility that analysts blame on strong intervention by China’s central bank…. – Continue reading
Ireland will be forced to ban many of the tax advantages it offers multinationals under proposals to be published by the European Commission tomorrow. This is the first step in an effort to have all EU countries introduce similar tax rules to prevent companies in the 28 member states avoiding… – Continue reading
Facebook founder Mark Zuckerberg has been defending his decision to build a new data centre in Ireland against claims the move is a tax dodge. The social media mogul announced the start of construction of the €200m facility at Clonee on the Meath-Dublin border on his own Facebook page, quickly… – Continue reading
Once the thrill of deciding to retire overseas has subsided, you normally start to think of all the things you need to do before you go. Picking the right removal firm, a lawyer to help you buy a new home are a couple, but the tax & financial implications of… – Continue reading
GE division makes millions in sales to health service, and is net beneficiary from UK Exchequer One of the biggest suppliers of equipment and testing services to the NHS pays barely any corporate tax in the UK, despite receiving hundreds of millions of pounds a year from medical sales to… – Continue reading
India to change laws in Union Budget to make country-by-country reporting mandatory for Indian multinationals New Delhi: India will change laws in the upcoming budget to make country-by-country reporting mandatory for Indian multinationals to ensure they follow so-called base erosion and profit shifting (BEPS) guidelines. The norms were announced in… – Continue reading
Multinational companies are facing severe constraints on their ability to avoid taxes on their activities in Europe as regulators seek to close loopholes laid bare by the LuxLeaks scandal Pierre Moscovici, the EU’s tax policy chief, will set out plans next week to curb practices such as using debt interest… – Continue reading
One of the biggest financial benefits of owning a home is qualifying for the tax breaks that homeowners are eligible to receive. Many of the tax deductions for home-related expenses are well-known, but others often slip under the radar. Below, we’ll run through the list of deductions for homeowners that… – Continue reading
Ireland’s insistence that it is not a tax haven and that in fact other EU countries have tax regimes that facilitate tax dodging by multinationals will be borne out by a study to be released next week. But while this will be good news to Finance Minister Michael Noonan a… – Continue reading
FOCUS: Major infrastructure projects and other purely commercial transactions could suffer collateral damage from proposals to reform the international tax system and prevent avoidance by multinationals. Rising tax costs could put additional strain on the viability of key projects. Infrastructure projects are capital intensive and often have a high level… – Continue reading
In an effort to facilitate non-resident enterprises in applying for tax benefits, China’s tax bureau recently released the SAT Announcement [2015] No.60, which replaced the previous “Administrative Measures on Tax Treatment under Double Taxation Agreement to Non-resident Enterprises (Guoshuifa [2009] No.124)” and simplified the application procedures for a non-resident enterprise… – Continue reading
Banking and IT contractors forced to stump up tens of thousands of pounds to settle contested tax debts last year are now in line to be repaid, after the UK tax authority accepted it should not have issued payment demands. HM Revenue & Customs has withdrawn so-called accelerated payment notices… – Continue reading
Banking and IT contractors forced to stump up tens of thousands of pounds to settle contested tax debts last year are now in line to be repaid, after the UK tax authority accepted it should not have issued payment demands. HM Revenue & Customs has withdrawn so-called accelerated payment notices… – Continue reading
Plans to restrict the generous tax treatment of interest costs — a key aspect of Britain’s business-friendly taxation regime — are unnecessary and potentially damaging, companies have told the Treasury. Professional bodies and business groups are voicing fears about the restrictions that are set to be introduced as part of… – Continue reading
NEW DELHI: Indian businesses are anticipating a “more aggressive” stance by tax authorities as their tax arrangements come under greater scrutiny, says a survey. The findings are part of leading consultancy Deloitte India’s BEPS (Base Erosion and Profit Shifting) survey titled ‘Anticipating BEPS India impact’. Indian businesses are anticipating a… – Continue reading
Things just keep getting worse for Gene the Taxi King. A federal judge ruled Tuesday that New York taxi mogul Evgeny “Gene” Freidman illegally transferred more than $60 million in real estate assets into offshore trusts as a means of evading ex-lender Citibank. The ruling, which cited “numerous and glaring”… – Continue reading
UK property companies are seeking changes to the proposed implementation of a global agreement to fight tax avoidance that is set to add £660m to their annual tax bill. Private equity and infrastructure companies are also among those groups facing additional payments under OECD rules on base erosion and profit… – Continue reading
Following a number of questions and concerns raised with the Governor’s Office in recent days, I thought it would be helpful to clarify the situation with respect to seven pieces of legislation passed by the House of Assembly during December 2015. Four of these Acts, which give the Government of… – Continue reading
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
Several ‘brief-case’ professionals, well accomplished sole proprietors and very important personalities all go around earning millions of Naira in income but paying no tax Tax gap is used here to refer to the difference between taxes collected by government and what could ideally be collectible. Without a doubt, the gap… – Continue reading
United States Vice President Joe Biden has never been one to hold his tongue. He certainly didn’t in his recent trip to Kiev. In a speech before Ukraine’s Parliament, Biden told legislators that corruption was eating Ukraine “like a cancer,” and warned Ukrainian President Petro Poroshenko that Ukraine had “one… – Continue reading
MUMBAI: The Reserve Bank of India has tightened norms for banks lending to overseas subsidiary of Indian companies by raising the provisions substantially against these loans. On Thursday, RBI said that banks can extend loan to overseas subsidiaries of Indian corporates but they have to make 2% of the loan… – Continue reading
The Finance Act 2015 introduced an exemption from a borrower’s obligation to withhold tax from interest payments arising on qualifying private placements. It was introduced to stimulate and grow the private placements market in the UK in order to unlock a new source of financing for mid-sized borrowers. Following a… – Continue reading
It was Kerry Packer who famously told the nation’s politicians “if anybody in this country doesn’t minimise their tax they want their head read” because “as a government I can tell you you’re not spending it that well that we should be paying extra”. The words have gone down in… – Continue reading
IP regime To comply with the OECD’s BEPS reports and more specifically its action plan n° 5 regarding harmful tax practices, the Luxembourg intellectual property (“IP“) regime under article 50bis of the Luxembourg income tax law (“ITL“) will be repealed as from 1 July 2016. As such, the Luxembourg 80%… – Continue reading
RIGA – The Latvian Financial and Capital Markets Commission (FCMC) on Dec. 11 imposed a record 2-million-euro fine on Ukrainian-owned A/S Privatbank and ordered the dismissal of its CEO and managing board for violations of money laundering and other banking regulatory laws in connection with the alleged plundering and collapse… – Continue reading
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
There are two things that offshore fund managers and their advisors should remember about income that is effectively connected with a United States trade or business (ECI): It is easy to have ECI; and, It is bad to have ECI. By way of background – U.S. non-residents that are not… – Continue reading
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
