India and China developing frameworks for Reits but while their sheer sizes impress, both face tax and high interest rate hurdles, reports the Business Times. India and China are both developing frameworks for real estate investment trusts (Reits), but the threat to Singapore’s position as a major regional Reit centre… – Continue reading
NEW DELHI: Tax authorities have issued a fresh notice to UK-based telecom giant Vodafone seeking reassessment of tax returns for two years. The notice has been served under Section 148 of the Income Tax Act which seeks to deal with income that has escaped assessment. Sources said the notice seeks… – Continue reading
To balance the books, Australians will have to pay more tax, the only questions being what will be taxed and how high the rate. Boasting glittering skyscrapers and label-clad youth, Singapore is the new jewel in the capitalist world’s crown. The city state is home to the third-highest density of… – Continue reading
MUMBAI: In a fresh crackdown on suspected tax evasion and laundering of black money through stock markets, regulator Sebi today barred Mishka Finance and TradingBSE -1.93 % Ltd and 128 other entities from the securities market. While the total amount involved could not be ascertained, these entities are estimated to… – Continue reading
Finance Minister Arun Jaitley, who had previously stated that India was not a tax haven and legitimate dues from foreign investors will be pursued, had earlier this week said that “the amount involved is Rs 40,000 crore.” Refusing to relent on a Rs 40,000 crore tax demand on foreign portfolio… – Continue reading
CHEYENNE, WY, April 17, 2015 /24-7PressRelease/ — OUTPOST PROVISIONING LLC today announced the launch of its “Wyoming…the Offshore Alternative” campaign alongside release of its Wyoming Paymaster Purpose Trust product. “Wyoming…The Offshore Alternative” touts Wyoming as being the Offshore-equivalent for wealth protection without the inconvenience, scrutiny, compliance costs and risks involved… – Continue reading
Nothing is certain in India except death and tax disputes. Ask foreign portfolio investors: they now face demands for past dues of as much as $6.4 billion. The wrangle stems from the Minimum Alternative Tax, or MAT, which officials say leads to a 20 percent levy on capital gains by… – Continue reading
On 17 March 2015 Cyprus and Bahrain signed a new double taxation agreement. Like all of Cyprus’s recent DTAs it closely follows the 2010 OECD Model Tax Convention. Its main provisions are summarised below. Taxes covered The agreement applies to taxes on income imposed by either country. In Bahrain these… – Continue reading
“Tax policy and administration should incentivise compliance. They should be administered fairly, transparently, with minimum discretion, with no harassment of taxpayers but also ensuring that tax evasion is dealt with firmly.” Promising a ‘modern tax system’ with low and globally competitive rates, Finance Minister Arun Jaitley has assured foreign investors… – Continue reading
When Hillary Clinton recently borrowed Elizabeth Warren’s talking points and claimed “the deck is still stacked in favor of those at the top” (in our economic and political system) against regular working people, did she mention reforming the tax code — and then offer any solutions? The simple answer is… – Continue reading
Foreign owners of UK property assets are being advised to seek property valuations to avoid falling foul of changes to Capital Gains Tax, writes David Westgate – Managing Director, Andrews Letting & Management CHANGES to Capital Gains Tax for UK property investors based overseas were first announced by George Osborne… – Continue reading
The measure probably won’t advance further, at least not this year. The U.S. House voted to repeal the 99-year-old U.S. estate tax amid a partisan clash over whether the government should break up concentrated wealth or make it easier to pass along assets to the next generation. The House passed… – Continue reading
Finance Minister Arun Jaitley on Tuesday said the government will press ahead with Rs 40,000 crore tax demand on foreign institutional investors as FIIs lost a case against levy of tax on capital gains they made. “FIIs went to a tribunal, which is called Authority for Advance Rulings (against levy… – Continue reading
New Delhi: The government has set the record straight on tax disputes, maintaining they are not covered by the Bilateral Investment Promotion and Protection Agreement (BIPA) and need to be judicially and legally settled. “…But again on the BIPA issue, let me mention, it has been our consistent view that… – Continue reading
Wealthy Americans are running out of ways to hide their money. The IRS has been relentless in prying open the secret Swiss bank account—dozens of Swiss banks are cooperating with the agency. Just last month, a settlement with the private bank BSI revealed bankers used coded language and nameless credit… – Continue reading
As foreign portfolio investors balk at India’s claim of $6.4 billion in back taxes, the finance ministry’s latest demand isn’t damping interest in the nation’s stocks and bonds. Foreigners were net buyers of local equities every day barring one since the finance ministry said April 6 it is well within… – Continue reading
Cross border transactions involving German entities investing in French real estate may need to be restructured as a result of proposed changes to the France/Germany double tax treaty, according to two experts. French tax expert Franck Lagorce and German tax expert Werner Geisselmeier, both of Pinsent Masons, the law firm… – Continue reading
In a major relief to Vodafone, the Supreme Court on Wednesday rejected the income tax department’s appeal challenging Vodafone Essar Gujarat’s transfer of certain passive assets to Vodafone Essar Infrastructure. However, it said that the department is free to raise tax demand under relevant tax laws but can’t block the… – Continue reading
One in three wealthy people who may be dodging tax will get a call or personal visit by the Australian Taxation Office as it moves to ensure the richest Australians and private companies pay their fair share of tax. The ATO wants to beat its 2013-14 rate of raising $1.1… – Continue reading
New Delhi, April 15 (IANS): The Supreme Court on Wednesday said that while the tax authorities could move under the law to raise tax claims against Vodafone, in another case involving the de-merger of its towers business, the assets transfer, as such, cannot be blocked. The apex court bench of… – Continue reading
The Labour party call for stripping non-domiciled UK residents of tax privileges has gone down well with people at large April 15, 2015: In January 1799, British Prime Minister William Pitt the Younger brought in a 10 per cent tax on income for Britons for the first time, as part… – Continue reading
Research by the Guardian and the Tax Justice Network reveals 28 English clubs with substantial shareholdings overseas, opening up the football leagues to criticism for allowing ownership structures that could be used for tax avoidance Almost one in three of the 92 Premier and Football League clubs are now substantially… – Continue reading
1. NON-TAX ISSUES 1.1 Domestic law 1.1.1 Briefly describe your legal system and its origins Canada is a federal state, with legislative powers divided between the federal and provincial governments. The federal government has legislative jurisdiction over issues concerning Canada as a whole, including foreign affairs, international trade, banking, telecommunications,… – Continue reading
A crackdown on alleged tax abuses by private equity managers has been drawn up by Labour as part of a £7.5bn plan to “come down hard on tax avoidance and evasion”, reports the Financial Times. The party said it would “re-write the rules that allow private equity managers to get… – Continue reading
This is relevant mainly for (1) Hong Kong companies or investment funds selling securities in Chinese listed companies and (2) ship or aircraft leasing companies resident in Hong Kong who (finance) lease vessels and aircraft to lessees in mainland China. On 1 April 2015, Hong Kong and mainland China signed… – Continue reading
Shift a rock in the garden and the insects underneath will scurry away to cover. Only the foolish or desperate stand their ground, ready to take you on. So when a Senate committee decided to probe the tax arrangements of some multinationals last week, and they fought back, it was… – Continue reading
The key is to arrive at a Goldilocks mean — rolling out tax-friendly policies while being firm with incorrigible offenders A phrase first used by Prime Minister Narendra Modi while addressing a group of businessmen in the run-up to the elections last year has now come back to haunt his… – Continue reading
All eyes will be on former Secretary of State, and now presidential candidate, Hillary Clinton as she sets out a policy agenda during the opening months of her campaign. While in recent years Clinton has not gotten into the nitty-gritty of tax policy, she does have a long voting record… – Continue reading
New Delhi, April 10: The finance ministry is mulling a new tax regime for financial SEZs of the kind inaugurated today in Gujarat so that the taxes paid by financial institutions working out of them are on a par with Dubai and Singapore. The country’s first International Financial Services Centre… – Continue reading
On 18th March 2015, George Osborne delivered his sixth budget as Chancellor and the last of the current Parliament. Amongst the announcements were a number of developments relevant to tax planning, the key points of which are summarized below: Capital Gains Tax – Entrepreneurs’ Relief Entrepreneurs’ Relief (ER) reduces the… – Continue reading
The present French Tax Update will focus on (i) several noteworthy French and European Union court decisions issued in the last months of 2014 and in the first months of 2015, and (ii) the recent presentation by the European Commission of a package of tax transparency measures. VALIDITY OF TAX… – Continue reading
Revenue figures show that just 13 people paid domicile levy of €200,000 in 2013 Ireland is home to more than 3,000 individuals or couples recognised as ‘non-domiciled’ for tax purposes, new figures from the Revenue Commissioners show. So-called “non-doms” can avoid paying tax on their worldwide income in Ireland, thus… – Continue reading
Proposed changes to Australia’s managed investment trust regime have been met with cheers from the investment community as they welcome the boost in certainty and tax treatments. The government revealed the long-awaited changes to Australia’s MIT tax system on Tuesday, and expects to create a new standalone regime that will… – Continue reading
• “Budget deficit calls for combination of cuts, and contributions,” says Seaton This week Republican Representative Paul Seaton, R-Homer, introduced a bill that would impose an income tax on residents and non-residents deriving an income source from within the state of Alaska. Proposed as a diversification strategy, Seaton said that… – Continue reading
The Federal Government has floated the idea of lowering the corporate tax rate – arguing the current rate of 30% is not internationally competitive. The rationale is that globalisation makes capital perfectly mobile and the marginal non-resident investor in Australian companies will go where corporate tax rates are lowest. At… – Continue reading
An arrest over allegations of price fixing has increased calls for tighter regulation of the booming sector On a late February morning, Yves Bouvier arrived at the Monaco home of one of his best clients. He expected Dmitry Rybolovlev, the Russian billionaire owner of AS Monaco football club, to pay… – Continue reading
No member of Congress has been more active in the cause of protecting tax cheaters and tax avoidance by our nation’s wealthiest individuals and corporations than Sen.(now presidential candidate) Rand Paul. While Paul is a standard bearer of anti-tax conservatives through his advocacy of radical policies such as the flat… – Continue reading
Argues tax proceedings initiated after more than six years Vedanta group company Cairn India on Monday filed a petition in the Delhi High Court here against a Rs 20,494-crore tax demand, seeking quashing of the order. The company argued the tax proceedings were initiated more than six years from the… – Continue reading
To reduce the growing urban sprawl most levels of government are allowing higher density housing in the suburbs. This means people with larger residential blocks are presented with an opportunity to subdivide and increase the value of their home. However if the correct steps are not taken when subdividing a… – Continue reading
On April 3, 2015, as part of its Action Plan on Base Erosion and Profit Shifting (BEPS), the OECD released a discussion draft entitled “BEPS Action 3: Strengthening CFC Rules” (the Draft) for comments. The Draft stresses the importance of CFC rules in countering base erosion and profit shifting, and… – Continue reading
Till March 31, close to 100 FIIs got notices from the Tax Department for a controversial Minimum Alternate Tax (MAT) of 20 per cent, while they are now being followed up with Assessment Orders. In the biggest-ever tax demand slapped on them, nearly 100 foreign funds have been asked to… – Continue reading
New Delhi/Mumbai: In the biggest-ever tax demand slapped on them, nearly 100 foreign funds have been asked to cough up an estimated USD 5-6 billion for ‘untaxed gains’ made by them in the Indian markets over the past years. The number of affected investors can rise substantially as assessments are… – Continue reading
On January 2, 2015, the IRS issued annual revenue procedures in the Internal Revenue Bulletin, which included its annual list of “no-rule” areas. Traditionally, the issues on which the IRS refrains from issuing letter rulings or determination letters tend to be inherently factual. In the domestic area, there are a… – Continue reading
The UK’s Upper Tribunal has ruled in HM Revenue and Customs’s (HMRC’s) favor in three tax avoidance cases. The Department said that the judgments protected over GBP260m (USD385m) in tax. All three rulings upheld earlier First-Tier Tribunal judgments in HMRC’s favor. In one case, the Upper Tribunal dismissed an appeal… – Continue reading
The Shanghai-Hong Kong Stock Exchange Connected is working out its kinks and investors are taking notice. Hong Kong and Beijing signed a tax treaty on Thursday that ends double taxation for equity traders, which was one of the sticking points for local brokers hoping to buy into China’s massive mainland… – Continue reading
As Tax Day approaches, homeland Americans scurry to file their annual tax filing obligations. But for an estimated 7.6 million Americans working and living overseas, they have an obligation to not only pay taxes in their respective countries where they live; they need to pay the piper in homeland America… – Continue reading
U.S. multinationals represent the healthiest segment of the economy, with higher profits and more than $1 trillion of cash on hand. This has kept corporate tax reform alive as a political issue. ON Semiconductor had a solid 2014, boosting net income by 36 percent to $196 million on revenue of… – Continue reading
Australians working in Hong Kong should be aware of the various complexities that affect their residency, super and tax status. Going overseas to work is a grand adventure for many professionals. But the way income earned outside your home country is taxed is a complex area, and it’s worth seeking… – Continue reading
The UK’s Finance Bill was published on 24 March 2015. It was subsequently enacted on 26 March 2015 without further amendment and became the Finance Act 2015. The “disguised investment management fee” provisions contained in this Act, summarised below, will be effective from 6 April 2015. These rules apply to… – Continue reading
Government questions dividend imputation and company tax rate Australian investors appear to have dodged a bullet, with the government’s first paper on tax reform discussing the dividend imputation system but falling short of attacking it outright as an idea that has outlived its usefulness. David Murray’s inquiry into the Australian… – Continue reading
