Category: Activity

How to Avoid Foreign Dividend Withholding Tax

Using foreign stocks to diversify your portfolio can be a good move for investors looking to collect dividends and protect capital. But owners of dividend paying foreign stocks can find themselves being hit by another type of tax: foreign dividend withholding tax. Keeping as much of your dividends as possible… – Continue reading

Canada: Appeal Filed With The Federal Court Of Canada Seeking A Declaration That FATCA Is Unconstitutional And Should Not Be Enforced In Canada

On Monday the 11th of August, an appeal was filed with the Federal Court of Canada in Vancouver seeking a declaration that the enforcement by the Canadian Government of the United States’ Foreign Account Tax Compliance Act (“FATCA”) on Canadian soil is unconstitutional. Under FATCA financial institutions enter into an… – Continue reading

Weighing tax benefits of S corporations

Factors to consider in deciding which type of incorporation is best for you AS TAX LAWS continue to evolve, so do choices of entity. Being mindful of the alternatives is critical to achieving tax benefits. Both S corporations and Limited Liability Companies (LLC’s) are flow-throughs, which have long been a… – Continue reading

Heat on Joe Hockey over tax avoidance deal as government prepares to host G20

Labor has accused the government of procrastinating on a key measure to stop multinational companies shifting profits offshore. It comes as the government prepares to chair the G20 finance ministers meeting in Cairns next week. The information-sharing deal, part of the global push to tackle tax avoidance, has been signed… – Continue reading

How tax inspectors could prevent the next Ebola outbreak

Much has been written about the poor public health and clinical capacity to respond to the Ebola outbreak in West Africa. Inadequate medical and nursing staff resources, inadequate isolation wards, inadequate intensive care resources, insufficient ambulances. An international emergency response is being mounted in an attempt to fill this huge resource gap…. – Continue reading

Transfer-pricing in the world of BEPS

The past few years have seen a quantum leap in globalisation, resulting in free movement of capital and labour, shifting of manufacturing bases from high-cost to low-cost locations, gradual removal of trade barriers, technological and telecommunication developments, etc. These developments have, on one hand, led to increasing sophistication in tax… – Continue reading

Foreign Account Tax Compliance Act (FATCA) for Private Funds: Key Considerations

Although the Foreign Account Tax Compliance Act (FATCA) went “live” July 1, 2014, guidance continues to fall into place. On July 16, the IRS issued instructions for the requester of various Forms W-8 and continues to update its FAQ website. The Cayman Islands Tax Information Authorityissued regulations effective July 4, 2014 addressing the… – Continue reading

FATCA in Europe: understanding grandfathering

Withholding on US source income under FATCA started on 1 July 2014.  The withholding will apply to gross “proceeds of sale” of securities bearing US source income (which includes repayment of principal on a loan to a US borrower) and, potentially, to “foreign passthru payments” from January 2017. Now that… – Continue reading

BNY Mellon backs London to lead European race for offshore RMB

London and Singapore are fast closing the gap on Hong Kong in the race to become centres for offshore renminbi business and capitalise on Beijing’s ambition to make the RMB a global currency. Fred DiCocco, Asia-Pacific head of sales & relationship management for BNY Mellon’s Treasury Services business, says London… – Continue reading

Corporate Tax Cuts Would Help Treasury And Investors

Countries worldwide have cut their corporate tax rates in the past two decades. Germany lowered its top rate to 29.6% from 59.7% in 1993. Canada went from 44.3% to 26%, Ireland from 40% to 12.5%. The average top rate for 34 non-U.S. countries went from 36.9% in 1993 to 25.1%… – Continue reading

Congressman Introduces Legislation to Stop Tax Inversions

Rep. Mark Pocan, D-Wis., has introduced three pieces of legislation to close tax breaks that enable U.S. multinational corporations to use so-called “inversions” in which they merge with a foreign company and move their tax domicile abroad to a low-tax country to reduce corporate taxes. Corporate inversions are used by… – Continue reading

U.S. tax evasion and money-laundering sting nabs Canadians

A contingent of so-called “corrupt clients” from Canada have been caught in the net of a massive fraud investigation by the FBI and the U.S. Attorney, a source close to the investigation told CBC. CBC News reported Wednesday that two Canadians, along with four others, were indicted in the U.S…. – Continue reading

Minister’s offshore business to be re-investigated

The offshore tax affairs of a company previously headed by the economics minister are to be re-examined by the finance department of canton Bern. The move comes after Swiss Public Television, SRF, published a memo written by the Federal Tax Authorities (FTA) which raised questions about the previous investigation. The… – Continue reading

FATCA responsible officer function obsolete for Cayman funds

Outsourcing the responsible officer (RO) function under the Foreign Account Tax Compliance Act (FATCA) offers limited value to Cayman-Islands’ domiciled fund managers.The Model one Intergovernmental Agreement (IGA) between the Cayman Islands and the US does not stipulate that a responsible officer is required. The responsible officer title is a feature… – Continue reading

Firms issuing offshore bonds hit a company law hurdle

NEW DELHI, SEPTEMBER 11:   Indian companies looking to raise money abroad through offshore bond issuances to overseas investors are in a bind, thanks to the new company law requirement around private placement of securities. They are now looking up to the Corporate Affairs Ministry (MCA) to provide clarity on whether… – Continue reading

More firms signing up with IRS

EVEN MORE Philippine companies have complied with a US tax law since a July 1 deadline, after which foreign financial institutions (FFIs) not yet registered with the US Internal Revenue Service (IRS) faced penalties. A list published by the IRS earlier this month showed that a total of 197 Philippine-based… – Continue reading

Caribbean-Based Investment Advisor Sentenced for Using Offshore Accounts to Launder and Conceal Funds

Washington, DC—(ENEWSPF)—September 5, 2014. Joshua Vandyk, an investment advisor, was sentenced today to serve 30 months in prison for conspiring to launder monetary instruments, the Justice Department and Internal Revenue Service (IRS) announced. Vandyk, a U.S. citizen, and Eric St-Cyr and Patrick Poulin, Canadian citizens, were indicted by a grand… – Continue reading

Vadnais Heights Investment Advisor Pleads Guilty To Tax Evasion

MINNEAPOLIS (WCCO) — A 43-year-old Vadnais Heights investment advisor pleaded guilty to accusations that he spent clients’ money on personal items instead of investing their funds, the United States Attorney’s Office announced Wednesday. Joel William Carlson, who was charged on Aug. 4, pleaded guilty Wednesday to two counts of tax evasion… – Continue reading

Canada, UK Tax Authorities To Deepen Cooperation

The tax authorities of the United Kingdom and Canada are to deepen cooperation to establish a stronger mutually beneficial relationship, senior officials from both Government have said. Canada’s Revenue Minister, Kerry-Lynne D. Findlay, met with David Gauke, the UK’s Financial Secretary to the Treasury, in London on September 8. Findlay… – Continue reading

Schumer to release offshore tax bill

Sen. Charles Schumer (D-N.Y.) released legislation Wednesday seeking to roll back the tax benefits for companies that reincorporate abroad. Schumer’s bill takes aim at a maneuver known as earnings stripping, a process by which U.S. subsidiaries can take tax deductions on interest stemming from loans from a foreign parent. The… – Continue reading

Jack M. Mintz: Ending corporate tax inversions is ill-advised. The answer is tax reform

Retroactive legislation curtails tax-avoidance schemes but undermines faith in a government that changes the rules of game after an investment is made The temperature is rising in the United States over corporate inversions. U.S. Treasurer Jacob Lew is looking to pass retroactive law to undo recent corporate restructurings and, with… – Continue reading

Developing Countries Losing Billions To Corporate Tax Avoidance

BANGKOK, Sept 10 (Bernama) — Developing countries may be losing over US$160 billion annually due to corporate tax avoidance – money that could fund greater policy ambitions to get the global economy out of the doldrums and moving towards a more inclusive and sustainable future. Greater policy ambition in both… – Continue reading

Small island nations Mauritius and Seychelles considered good prospects for foreign direct investment

(Seychelles News Agency) – According to a new report by the United Nations Conference on Trade and Development (UNCTAD), Seychelles and Mauritius are two of the most attractive small island developing states for foreign direct investment (FDI) due to the competitive advantages they offer to foreign capital. SIDS which are… – Continue reading

Federal Court hands down software tax decision

The Federal Court has handed down its decision in the case of Task Technology v Commissioner of Taxation in relation to the tax treatment of specific software payments. The case related to payments made by Task to CaseWare International Inc (CWI) for the right to market and distribute CWI software to end users… – Continue reading

Banking without borders

This article was first published in the 2nd quarter 2014 edition of Personal Finance magazine. You might need a bank account in a foreign country for all sorts of reasons. As Gerrit Viljoen, financial planner at Ultima Financial Planners, says: “More and more South Africans have business interests and property… – Continue reading

Can inheritance tax work?

Now that we have new cabinet ministers to drive the economy forward, the next expectation is for martial law to be lifted so that foreign investors and tourists can feel more comfortable about returning to Thailand. Meanwhile, the junta is determined to quickly show the people some signs of genuine… – Continue reading

‘Vaccine’ tax avoidance scheme loses in court

A cynical tax avoidance scheme which “abused the reliefs” offered for research into life-saving vaccines to claim back £77m, has been rejected at a second tribunal. HMRC said investors in the scheme used a Jersey registered limited partnership which claimed to be involved in creating and exploiting intellectual property from… – Continue reading

Revered Catalan Leader Tarnished by Tax Investigation

Scandal Is an Embarrassment to Separatists Planning Independence Referendum BARCELONA— Jordi Pujol often said he discovered his mission for Catalonia while climbing a mountain as a boy and seeing the destruction wrought by the Spanish Civil War of the 1930s. Decades later, as Catalonia’s long-serving leader, Mr. Pujol presided over… – Continue reading

Airbnb pays tax on Australian profit offshore

Airbnb has joined other multinational tech companies by booking its Australian profits offshore through an Irish subsidiary. The move raises questions about how much local tax it pays and whether its rent-sharing model will run into trouble with regulators here. The private company, estimated to be worth $10 billion, has sought immunity from corporate… – Continue reading

UBS Appeals $1.4 Billion Bail in French Tax Evasion Probe

UBS AG (UBSN) asked a Paris appeals court to overturn a $1.4 billion bail looming over the Swiss bank as France steps up a two-year-old tax evasion probe. The hearing dragged on for nearly three hours as the parties argued the case. The court said it would decide on the… – Continue reading

Retired Co Fermanagh businessman pays up in £10.8 million tax deal

A retired businessman from Northern Ireland has made a 13.5 million euro (£10.8m) settlement with the tax man in the Republic – one of the largest ever. Anthony Cafferkey, from Lisnarick Road, Irvinestown, Co Fermanagh has been named and shamed on the latest defaulters’ list over his tax affairs. Listed… – Continue reading

Six Corporate Executives and Six Corporate Entities Indicted for Orchestrating a $500 Million Offshore Asset Protection, Securities Fraud, and Money Laundering Scheme Defendants Created Three Brokerage Firms in Belize to Assist U.S. Citizens in Fraudulent Manipulation Schemes of Publicly Traded Companies, Including Cannabis-Rx Inc. (CANA)]

A multi-count indictment was unsealed this morning in federal court in Brooklyn, New York, against six individual defendants: Robert Bandfield, a U.S. citizen; Andrew Godfrey, a citizen of Belize; Kelvin Leach, a citizen of the Bahamas; Rohn Knowles, a citizen of the Bahamas; Brian De Wit, a citizen of Canada;… – Continue reading

Medtronic Has Biggest Stash Of Offshore Cash Among Inverters

Medical device giant Medtronic Inc. leads all corporate inverters in the amount of offshore cash waiting to be tapped if their tax inversion deals are consummated. Medtronic is buying Covidien and moving to Dublin, and it has $13 billion of cash outside the United States, according to a report from the Financial Times,… – Continue reading

SEC charges Belize ‘neighbors’ of summer market sensation Cynk

On Tuesday, the SEC and the Justice Department charged several companies claiming to be located on the same floor of an office building in Belize City with fraud and conspiracy. We may not have heard the last from Cynk Technology. On Tuesday, the Securities and Exchange Commission and the Department… – Continue reading