Category: Activity

The BEPS Initiative: Redefining International Tax Planning?

Technology companies frequently possess an international tax footprint before expanding their domestic tax footprint.  That may soon change as the Organisation for Economic Cooperation and Development (OECD) and its G20 member countries undertake an ambitious agenda to fundamentally alter the international taxation system.  The OECD released its Action Plan Addressing… – Continue reading

Fake reception prompts probe

A political candidate has sparked the Reserve Bank and the Financial Markets Authority to visit a foreign-owned company offering “secret” offshore accounts. Grace Haden, an independent standing for election in Epsom, raised concerns with the regulators about Breder Suasso, which is referred to on overseas websites as a New Zealand… – Continue reading

Bosses flee Vietnam, ignoring debts and taxes

VietNamNet Bridge – The bad news about tax evasion and debt repudiation cases by foreign invested companies has darkened Vietnam’s foreign direct investment (FDI) landscape. Tuoi Tre newspaper has reported that Austrian Harald Biebl, director of the HCM City-based Bach Hop Company, operational in Vietnam since 2005, has fled the… – Continue reading

FATCA Alert: IRS Issues Final Version of the Form W-8BEN-E and Accompanying Instructions

On June 25, 2014, the IRS finally issued the instructions to the new version of Form W-8BEN-E, an 8-page withholding certificate to be completed by foreign entities. Previously, foreign individuals and most foreign entities would provide a one-page Form W-8BEN to withholding agents to certify the foreign entity’s entity classification… – Continue reading

Review of patent tax regimes in EU has Irish support

Ireland can adopt ‘wait-and-see’ approach on tax breaks, says Department of Finance Ireland supports the EU review of all patent box regimes – under which certain member states offer tax breaks for intellectual property – and has decided to take a “wait-and-see approach” on the issue until guidance is provided… – Continue reading

Microsoft Admits Keeping $92 Billion Offshore to Avoid Paying $29 Billion in U.S. Taxes

Microsoft Corp. is currently sitting on almost $29.6 billion it would owe in U.S. taxes if it repatriated the $92.9 billion of earnings it is keeping offshore, according to disclosures in the company’s most recent annual filings with the Securities and Exchange Commission. The amount of money that Microsoft is… – Continue reading

5 Year Prison Sentence for Former LR Attorney for Mail Fraud, Tax Evasion

LITTLE ROCK, AR –Former Little Rock attorney David Patrick Henry, Sr., 71, has been sentenced to five years in prison followed by two years of  supervised released, according U.S. Attorney Christopher Thyer.  Henry, Sr. is also ordered to pay over a million dollars. On March 21, a federal jury found… – Continue reading

Billionaire Eugene Melnyk: I’m a ‘whistleblower’ on tax allegations against Valeant

MONTREAL • Eugene Melnyk, the billionaire owner of the Ottawa Senators and founder of drug maker Biovail Corp., is waging war against the company that now controls his one-time business. Mr. Melnyk alleges that Valeant Pharmaceuticals International Inc. is masquerading as a Canadian company to make use of this country’s… – Continue reading

First landmark ruling on Indian indirect transfer taxes! Delhi High Court restricts their applicability

The Delhi High Court upholds the non-taxability of gains from sale of shares of overseas entities by the Copal Group to the Moody’s Group. Interpretation of the indirect transfer tax provisions in a restrictive manner. 50% threshold for substantiality based on guidance by OECD/ UN material and Shome Committee Report… – Continue reading

Richard Kaplan: Additional Rauner tax-return disclosures probably won’t reveal much

Various reporters, editorialists and politicians are clamoring for Bruce Rauner, the Republican candidate for governor of Illinois, to release more of his tax returns — specifically, the detailed schedules that accompany the “top sheets” that he already has released. They probably will be disappointed, even if Mr. Rauner complies with… – Continue reading

Gibbons: New companies trend show Bermuda ‘moving in right direction’

Education and Economic Development Minister Grant Gibbons said yesterday the Registrar of Companies’ data on new company incorporations for the second quarter of 2014 continues to show a strong positive trend in the number of new company registrations. Results following the close of the quarter in June showed that the… – Continue reading

Must Have Been A MASH Fan: Hot Lips Was Code Name For Man’s Hidden Offshore Account

Using the code name Hot Lips with Swiss banking representatives, an 83-year-old Delray Beach man conspired to hide more than $1 million from the Internal Revenue Service in foreign bank accounts. Bernard Kramer pleaded guilty Tuesday in New York federal court before U.S. District Judge Alvin K. Hellerstein, admitting he… – Continue reading

Glencore report: European Investment Bank must drag its secrets into the light

Reasons given by the bank for refusing to publish findings of an investigation into alleged tax evasion remain unconvincing When commodities giant Glencore publishes its half-yearly report on Wednesday, it is unlikely to mention what may be a significant victory for the firm. This relates to an investigation into allegations… – Continue reading

Russell-linked tax avoidance case in High Court

Companies with links to John George Russell are accused of entering into “tax avoidance” arrangements and are in a $3.5 million fight with the IRD. Russell – who developed a template that the Court of Appeal called a “blatant tax-avoidance scheme” – is a 79-year-old accountant being chased by the… – Continue reading

The implications of FATCA in South Africa

The Foreign Account Tax Compliance Act (FATCA) was enacted in 2010 by the US to target non-compliance by US taxpayers using foreign accounts. FATCA essentially requires foreign financial institutions to report information about financial accounts held by US taxpayers, or by foreign entities in which such taxpayers hold a substantial… – Continue reading

New UK measures to counter avoidance schemes involving transfer of corporate profits

A new section 1305A of the UK Corporation Tax Act 2009 (CTA 2009) has been introduced by the UK Finance Act 2014 that applies to payments made from March 19, 2014 under avoidance schemes involving the transfer of corporate profits within a group. This new measure applies if: two companies… – Continue reading

Is offshore equity attractive?

JOHANNESBURG – While numerous asset managers have indicated that global equities currently offer better longer-term investment opportunities than local stocks, some investors are concerned that the rand could strengthen and dilute their offshore gains. Last year, investors with exposure to specific offshore unit trust funds benefited from gains in international… – Continue reading

Offshore incorporations up in Cayman and worldwide

Despite the political and media pressure on offshore financial centers, new incorporations of offshore companies worldwide continue to grow. A new report on offshore company incorporations by law and fiduciary firm Appleby shows that new company registrations increased in most offshore jurisdictions in the second half of 2013. “As the… – Continue reading

Serbia To Protect Taxpayers’ Rights Under FATCA

Serbia’s Information Commissioner has warned that banks must have the full consent of customers before information is passed to US tax authorities under the terms of FATCA, and that it would be illegal for customers to be declined services if they refuse to give consent. The comments were made by… – Continue reading

10 Facts About FATCA, America’s Manifest Destiny Law Changing Banking Worldwide

Never heard of FATCA? You will. FATCA—the Foreign Account Tax Compliance Act—is America’s global tax law. It was quietly enacted in 2010, and after a four-year ramp up, it’s finally in effect. What is most amazing is not its impact on Americans—although that is considerable—but its impact on the world…. – Continue reading

EBT scheme’s defeat will protect £2.4m, says HMRC

A tax avoidance scheme that routed a film financing venture’s profits via Employee Benefit Trusts at the behest of the venture’s owner, an ex-accountant, has been blocked by a tribunal. Operated by John Dryburgh, a former partner with Deloitte & Touche, the scheme  involved extracting profits from a series of companies named… – Continue reading

US has long tried to block tax inversions – with success

US has long tried to block tax inversions – with success – See more at: http://www.independent.ie/business/world/us-has-long-tried-to-block-tax-inversions-with-success-30520958.html#sthash.cT9EIpv4.dpuf US authorities have grappled for more than 30 years with corporate deals known as inversions by which American companies shift their tax 
domiciles abroad to avoid US taxes. Fifty-two substantial deals like this have occurred… – Continue reading

Wolters Kluwer Financial Services Identifies Data Collection and Reporting Requirements to Assist with FATCA Compliance

U.S.-China Agreement Requires Financial Institutions to  Increase Transparency and Enhance Reporting  Wolters Kluwer Financial Services recommends that financial institutions in China should take steps toward enhancing their data and reporting capabilities on financial accounts held by U.S. taxpayers in China as part of the Foreign Account Tax Compliance Act. This recommendation… – Continue reading

Corporate foreign tax moves have bedeviled U.S. for decades

(Reuters) – The U.S. government has grappled for more than 30 years with corporate deals known as inversions in which U.S. companies shift their tax domiciles abroad to avoid U.S. taxes. Fifty-two substantial deals like this have occurred since 1983, about half of them since the 2008-2009 credit crisis, according… – Continue reading

Corporation tax: Rate cut likely as Prime Minister David Cameron set to let Northern Ireland go it alone

Northern Ireland looks set to be handed the power to slash corporation tax in a move with the potential to significantly boost our stuttering economy. In a development which could transform international investment, senior sources in London and Belfast predict that an announcement will be made no later than October… – Continue reading

Global Tax Topical Focus – Corporate Inversions FAQ

To some, US companies switching their tax residency to gain a tax advantage are economic “traitors.” To others, they are victims of a United States tax code that effectively punishes them for investing at home and encourages them to look for opportunities overseas. In this Tax-News Topical Focus, we try… – Continue reading

Rauner’s old firm set up Cayman Island funds when he was boss

SRINGFIELD — Republican Bruce Rauner not only has personal investments in the Cayman Islands, but he presided over his former private equity firm as it set up other investment vehicles in the Caribbean tax haven known for its secrecy. The Chicago Sun-Times verified through the Cayman Islands’ government-run online business… – Continue reading