Category: Activity

Canada-U.S. tax agreement raises some concerns

CALGARY – A Calgary-based United States tax expert has recommended to the federal government that Canada follow the lead of other countries and include certain Canadian trusts within the definition of organizations subject to reporting under the recent Intergovernmental Agreement between the Canada and the U.S. “This would eliminate the… – Continue reading

Amazon Facing Fresh UK Tax Avoidance Row

The internet retail giant Amazon is facing fresh claims of tax avoidance after its latest accounts showed it routed more than £11 billion through its Luxembourg-based subsidiary in 2013 – yet paid only £4 million in UK corporation tax last year. Amazon trades through the Luxembourg subsidiary, Amazon EU SARL,… – Continue reading

Cyprus: Cyprus Signs Model 1 IGA With US Treasury

The Inland Revenue Department of Cyprus (“IRD”) will proceed with the signing of Model 1 IGA (Inter Governmental Agreement) with the US Treasury, following the Foreign Account Tax Compliance Act (FATCA). The Model 1 IGA requires Foreign Financial Institutions (FFIs) to report all FATCA-related information to their own governmental agencies,… – Continue reading

What Happens When FATCA Kicks In

There’s a bill that will go into effect on July 1. It’s known as H.R. 2847 which contains FATCA (the Foreign Account Tax Compliance Act of 2010). H.R. 2847 also known as HIRE (the Hiring Incentives to Restore Employment Act) was a law passed in March 2010 which will go into… – Continue reading

FOREIGN WITHHOLDING TAXES: HOW TO ESTIMATE THE HIDDEN TAX DRAG ON U.S. AND INTERNATIONAL EQUITY INDEX FUNDS AND ETFS

Course summary: Justin Bender of PWL Capital and Dan Bortolotti of PWL Advisors explain the ins and outs of foreign withholding tax on U.S. and international equity index funds and ETFs. INTRODUCTION Canadian investors get an enormous benefit from diversifying their portfolios with US and international stocks. But this benefit… – Continue reading

Transfer Pricing: BEPS And New Documentation Requirements

Introduction Successive surveys of tax executives and senior finance professionals at multinational companies show that risks associated with transfer pricing have become the number one tax-related concern for businesses operating across several jurisdictions. Ernst and Young’s (EY’s) latest Global Transfer Pricing Survey shows that businesses are taking increasing heed of… – Continue reading

B2B: Russian International Business Faces Its Biggest Shake Up in Decades

Russian business is certainly facing a challenging time. The Russian Government has sights set on the offshore business of Russian entities and individuals, and when they get their way it may have wide-reaching implications not only for Russian business, but for anyone doing business with Russian partners across the globe…. – Continue reading

Foreign Financial Industry Retaliation Will Be Coming Soon

The United States is targeting so-called offshore tax havens by claiming that billions of dollars of taxes are being evaded. The Foreign Account Tax Compliance Act was passed in 2010 as a revenue raiser, with the simple expectation that the United States can force the world’s financial industry to disclose otherwise… – Continue reading

SIT to probe all cases of black money

Cases like alleged involvement of 500 Indians in parking money in HSBC‘s Geneva Branch, 26 Indian account holders of LGT Bank may all be probed by SITThe special investigation team (SIT), announced on Tuesday by the Cabinet, will probe all cases of black money – be it related to the money allegedly stashed away by Indians abroad… – Continue reading

Azerbaijan, U.S. reach compromise on exchanging information on U.S. citizens’ accounts

Azerbaijan and the U.S. Internal Revenue Service (IRS) agreed to conclude an intergovernmental agreement on implementation of the Foreign Account Tax Compliance Act (FATCA) by Azerbaijani banks, the Ministry of Taxes of Azerbaijan said on May 21. Starting from July 1, 2014 the banks in all countries should join the… – Continue reading

Singapore Is Expected To Overtake Switzerland as the World’s Epicentre of Wealth Management

AsiaOne Business News released an article on the expectation of Singapore to dislodge Switzerland as the world’s wealth management capital (Business AsiaOne, 5/12/14) last week. AsiaBiz Services, Singapore’s leading company formation consultancy, affirmed that the main reasons for the country’s acquisition of its enormous share of global offshore wealth are attributed to… – Continue reading

Russia Mulls ‘Limitations’ On Information Exchange With U.S. Under FATCA

The Russian government may place “limitations” on the amount of information that Russian banks can render to U.S. tax authorities under FATCA, a U.S. federal law intended to crack down on tax avoidance by U.S. citizens, Deputy Finance Minister Alexei Moiseyev said Thursday. Moiseyev told journalists in St. Petersburg that Russia will not become “tax agents for the Americans, that… – Continue reading

Foreign Account Tax Compliance Act will result in heightened tax scrutiny of NRIsForeign Account Tax Compliance Act will result in heightened tax scrutiny of NRIs

In recent years, the US Congress and the US Department of Treasury have come to believe that many US taxpayers (including US citizens and green card holders in India) have not been complying with the tax law that requires reporting of worldwide income, including income held in non-US financial institutions…. – Continue reading

Top 12 tax havens for US companies

US corporations are making record profits in tax havens like Bermuda, the Cayman Islands, and the British Virgin Islands (BVI). Some of the profits exceed the GDP of the host country, with Bermuda’s offshore profits 1643% of total economic output. As a share of Gross Domestic Product (GDP), profits from… – Continue reading

Transparency ‘cop’ can help trace black money

The Special Investigation Team (SIT) constituted by the government to “bring back black money” is likely to help India plug its wealth draining to offshore tax havens with Swiss global tax activists saying that the government can put pressure on Switzerland by blacklisting it as a non-cooperative jurisdiction and complaining… – Continue reading

Tax Chauvinism: Who Cares Where a Firm is Incorporated?

Following the recent offer by U.S drugmaker Pfizer to acquire British pharmaceutical firm AstraZeneca, congressional Democrats are proposing new limits on the ability of U.S.-based firms to establish foreign residence and thus cut their U.S. corporate tax bill. Even before this latest flap, the Obama Administration proposed curbs on this… – Continue reading

Stop bashing Ireland as a tax dodge: Ryanair CEO

Ireland has been “unfairly singled out” as a tax haven for corporations, Dublin-based Ryanair CEO Michael O’Leary said Monday on CNBC. “I wish we were, but we’re not,” he said. As one of Ireland’s wealthiest businessmen, O’Leary also described as “egregious” personal tax rates there. “The top tax rate … is about… – Continue reading

SA startups catch a tax break as Reserve Bank allows for offshore IP transfer

The South African Reserve Bank (SARB) has relaxed regulations for private companies in the country, which now makes it possible to transfer intellectual property (IP) offshore, reports TechCentral. According to ENS Africa IP director Chris Bull, restrictions on intellectual property assets has been one of the key obstacles for local businesses… – Continue reading

Tax Havens (Other than Switzerland) Feeling the Heat From Tax Collectors

Switzerland isn’t the only tax haven feeling the heat from countries that are trying to scrape more revenue by raking in taxes from citizens with undeclared offshore assets. According to the U.K.-based Ethical Consumer, mini-states, like Andorra and the Cayman Islands, and financial centers, like Hong Kong and Singapore, all offer banking… – Continue reading

Swiss banking giant pleads guilty to aiding tax evasion

WASHINGTON — European bank Credit Suisse AG pleaded guilty Monday to helping wealthy Amer­icans avoid paying taxes through secret offshore accounts and agreed to pay about $2.6 billion. The Justice Department said it was the largest penalty imposed in any criminal tax case. It is also the largest bank to… – Continue reading

Convey responds to FATCA transitional relief for 2014 and 2015

MINNEAPOLIS, May 19, 2014 /PRNewswire/ — The IRS recently announced in Notice 2014-33 that it would regard 2014 and 2015 as a period of transitional relief for financial institutions complying with the Foreign Account Tax Compliance Act (FATCA). However, the IRS will continue to enforce the law and only grant penalty… – Continue reading

US pivotal to OECD tax plan

IT’S BECOMING increasingly apparent that the OECD’s plan to reduce tax base erosion and profit-shifting, as laudable as it is, is hugely reliant on the US making significant and drastic alterations to its corporate regime if it is to be successful. The cases of Starbucks and Google have shown us… – Continue reading

Grow FATCA, Grow!

A decision from the U.S. to recognize those with agreements “in substance” changes the number of countries with IGAs from 22 to 48. Jeffrey S. Freeman, J.D., LL.M If you notice money missing from your bank account you start asking questions and find a way to get that money back…. – Continue reading