Category: Canada

Spin Master Reaches Agreement With Canada Revenue Agency to Resolve Previously Disclosed Transfer Pricing Matter

Liability below the mid-point of the range in IPO prospectus TORONTO, Dec. 18, 2015 /CNW/ – Spin Master Corp. (“Spin Master” or the “Company”) (TSX: TOY) announced today that it has reached a settlement agreement with the Canada Revenue Agency (“CRA”), which resolves a previously disclosed transfer pricing matter arising… – Continue reading

Out of Bangladesh

According to a research report titled “Illegal Financial Flows from Developing Countries: 2004-2013”, recently published by the Washington based research institute Global Financial Integrity (GFI), Bangladesh stands 26th in the list of 149 developing nations, in terms of flight of capital including money laundering (The Daily Star, December 10, 2015)…. – Continue reading

Spain and Finland sign new treaty to avoid double taxation and to fight tax fraud

Given that the latest treaty was signed on 15 November 1967, the two countries felt it was appropriate to revise it in full. The new treaty, signed on Tuesday by the Spanish Ambassador to Finland, María Jesús Figa, and the Finnish Minister for Finance, Alexander Stubb, seeks to enable tax… – Continue reading

The end of financial privacy?

Over 90 jurisdictions have committed to the OECD’s Common Reporting Standard (CRS), creating comprehensive global automatic information exchange for financial assets and the entities through which such assets may be held. Over 70 jurisdictions have signed the OECD’s Multilateral Competent Authority Agreement, which implements the CRS. The CRS is scheduled… – Continue reading

Uber’s Double Dutch tax dodge undermining local economies

Why would anyone object to Uber, the user-friendly online drive-share service? Uber’s many riders obviously love it, but it seems civic officials are having conniptions. Their main complaint is that Uber drivers are unlicensed to carry passengers and might not have adequate insurance. In addition, officials are genuinely concerned that… – Continue reading

Coca-Cola Fights $9.4 Billion Transfer Pricing Adjustment

Dec. 14 — The Coca-Cola Co. filed a petition in U.S. Tax Court challenging a proposed $9.4 billion income adjustment related to the company’s transfer pricing for tax years 2007-09 (Coca-Cola Co. v. Commissioner, T.C., petition filed, 12/14/15). If the adjustment is sustained, the company could face a tax bill… – Continue reading

Update to Canada’s FATCA litigation

The grassroots group responsible for launching the FATCA-based litigation in Canada has issued a public call for witnesses. They are looking for “a Canadian who has been somehow harmed by this FATCA legislation, are interested in helping out by becoming a Witness in our lawsuit, and are willing to have… – Continue reading

Canada: Temporary Assignment Of An Employee From Canada To The United States – December 8, 2015

This article is the fourth and final part in a series examining the Canadian and U.S. income tax implications of the temporary assignment of an employee from Canada to the U.S. Specifically, these articles address the situation of an employee remaining employed by a Canadian entity, but temporarily assigned to… – Continue reading

Canada: Canadian Tax Amnesty – Time May Be Running Out For Canadians With Swiss Bank Accounts To File A Voluntary Disclosure With CRA

Swiss Banks Sending Letters to Canadian Account Holders For resident Canadian taxpayers that hold Swiss bank accounts which have not been reported to the Canada Revenue Agency (“CRA”), the window to come clean with Revenue Canada by filing a Voluntary Disclosure, and thereby avoid financial penalties and the possibility of… – Continue reading

Urgent advisory: Commence voluntary disclosures before the end of 2015

Data from the Canada Revenue Agency (“CRA”) confirms that voluntary disclosures (“VDs”) of offshore assets, gains and income hit record levels in 2015. This proliferation of VDs is attributable to various factors, including increased public awareness of: international tax compliance issues through media reports; the CRA’s Offshore Tax Informant Program;… – Continue reading

Canada: Canada-Swiss Information Exchange For Unreported Offshore Income

Canada and Switzerland have entered into an agreement which will commence in 2018 for the automatic exchange of information. Swiss banks are already requiring Canadian clients to provide evidence that their Swiss offshore bank accounts have been reported in Canada on form T1135 and offshore income reported on a T1… – Continue reading

Orica profits hit after losing battle with Australian Tax Office

Explosives maker Orica will take a $36 million hit to its bottom line after the Federal Court found it had avoided tax by using “round robin” financing arrangement it put in place a decade ago to boost its profit and ward off takeover bids. BusinessDay revealed Orica’s battle with the… – Continue reading

Why are Tax Inversion” Relocations Accelerating?

Tax inversions — the process of U.S. firms, merging with or buying foreign companies to shift their taxpaying headquarters abroad — have deprived the U.S. Treasury of ever-increasing billions of dollars. Although President Barack Obama promised to take punitive action against companies deliberately engaging in mergers and/or acquisitions for tax… – Continue reading

Canadians with Swiss bank accounts have until December 31, 2015 to file a voluntary disclosure

The United States came down hard on Swiss banks after receiving, from various whistleblowers, Swiss bank data evidencing U.S. citizens had hidden fortunes in Swiss accounts. Swiss banks were fined billions for assisting U.S. citizens in evading taxes and now want to avoid repetition of this scenario when the exchange… – Continue reading

What CFOs Need to Know About BEPS

The Base Erosion and Profit Shifting (BEPS) project is an initiative being pursued by the Organization of Economic Cooperation and Development (OECD) to curtail perceived exploitation of international tax rules and loopholes by multinational enterprises (MNEs). The OECD’s BEPS project was initiated in 2013 at the request of the Group… – Continue reading

Canada: BEPS Final Reports: An Update On Treaty Shopping

The Organisation for Economic Co-operation and Development (OECD) sees treaty shopping as an important source of Base Erosion and Profit Shifting (BEPS). In this context, it identified the prevention of treaty abuse as one of fifteen issues or “actions” in respect of which recommendations were to be formulated as part… – Continue reading

The foreign investment tax advisers should pay attention to

Taxes levied on foreign stock dividends can be recouped, but it makes most sense for high-net-worth clients with multimillion-dollar positions Advisers could be missing out on a way to maximize returns on their clients’ foreign investments. Americans investing in non-U.S. stocks could be earning less of a return than they’d… – Continue reading

The foreign investment tax advisers should pay attention to

Taxes levied on foreign stock dividends can be recouped, but it makes most sense for high-net-worth clients with multimillion-dollar positions Advisers could be missing out on a way to maximize returns on their clients’ foreign investments. Americans investing in non-U.S. stocks could be earning less of a return than they’d… – Continue reading

Transfer Pricing Documentation in a Post-BEPS World

“It is not the strongest or the most intelligent who will survive but those who can best manage change”-Charles Darwin The Organization for Economic Co-operation and Development (OECD) released its final recommendations on the Base Erosion and Profit Shifting (BEPS) Project on October 5, 2015. The BEPS project consist of… – Continue reading

‘Edward Snowden Of Tax Evasion’ Gets Five Year Prison Sentence

Edward Snowden is not in jail, but his namesake soon could be. Switzerland has sentenced Hervé Falciani, a former HSBC Swiss bank employee, to five years in prison. He is the whistleblower and leaker often called the “Edward Snowden of tax evasion.” Leaks bank records and tax documents has helped… – Continue reading

Clampdown on tax evasion

As Common Reporting Standard (CRS) comes into operation. OHANNESBURG – South Africans with undeclared offshore funds may only have a few months to get their affairs in order or risk facing significant penalties and even criminal prosecution as revenue authorities start the automatic exchange of information. The Common Reporting Standard… – Continue reading

Kenya and South Africa tax deal takes effect in January

The Kenya-South Africa double taxation agreement comes into force from January 1. An announcement in the November 19, South African government gazette says the agreement applies for taxes withheld at source. “A resident of Kenya will not be taxed on any South African business profits, unless it carries on business… – Continue reading

Hillary Doesn’t Understand High U.S. Taxes Cause Corporate Inversions

In response to the announcement that pharmaceutical firms Pfizer and Allergan would merge, Hillary Clinton released a statement that completely missed the real issue behind these inversions – they are a symptom of the greedy, complex, and inefficient U.S. tax code. “Inversion is a symptom, not a disease,” said Grover… – Continue reading

European Union: The End Of Financial Privacy?

Over 90 jurisdictions have committed to the OECD’s Common Reporting Standard (CRS), creating comprehensive global automatic information exchange for financial assets and the entities through which such assets may be held. Over 70 jurisdictions have signed the OECD’s Multilateral Competent Authority Agreement, which implements the CRS. The CRS is scheduled… – Continue reading

Previewing US Tax Reform

The latest Tax Reform Business Barometer survey, issued by The Tax Council and Ernst & Young, found that tax professionals expect Congress to approve tax reform legislation no earlier than 2017, with most congressional leaders having all but given up hope that tax reform is achievable in the remainder of… – Continue reading

Ethiopia: Unmet Demands of the G20

The creation of the Group of Twenty (G20) was believed to serve as a remedy to the harsh realities of the world today. The initial formation of the Group of Seven G7 could do little to avert pertinent challenges both the developing and the developed nations face frequently. So a… – Continue reading

A Delicate Balance: Tax Competition Versus Cooperation

Tax administrators want to maximise the amount of revenue collected without stifling the county’s competitiveness as a business destination. How should ASEAN countries navigate changing international conditions to meet this goal? By Rebecca Tan – As Benjamin Franklin once famously said, “In this world, nothing can be said to be… – Continue reading

Canada: Navigating BEPS: What The Tax Function Of Today Needs To Know For Tomorrow

The Organisation for Economic Co-operation and Development (OECD) has described its newly unveiled Base Erosion and Profit Shifting (BEPS) Action Plan as a “change of paradigm.”1 A few very large global groups aside, a more apt description may be a minefield for the unwary. BEPS has received considerable air time… – Continue reading

Inversions Are a Symptom of a Failing Tax Code

Once again, a possible corporate inversion is making headlines and once again, the Obama administration has proven it does not understand the real reason inversions occur. In response to news that pharmaceutical firms Pfizer and Allergan are in merger discussions, the Obama Treasury department has suggested it would do its… – Continue reading

180 Participants From 47 Countries Attend CATA Confab In Melaka From Tomorrow

MELAKA: Some 180 participants from 47 countries will attend the five-day 36th annual Technical Conference of the Commonwealth Association of Tax Administrators (CATA) here from tomorrow. The Inland Revenue Board (IRB) said among the countries taking part in the conference are Australia, South Africa, Brunei, India, New Zealand, Canada, Pakistan,… – Continue reading

Canada to join G20 effort to limit ‘profit shifting’ by multinationals

Canada is expected to join other G20 countries to sign off on an international deal in Turkey aimed at cracking down on “profit shifting” by large multinational companies seeking to reduce their tax bills. The changes, which are also aimed at exposing the corrupt use of tax havens to launder… – Continue reading

Report: Canada among biggest G20 losers in tax evasion

Ahead of a G20 meeting in Turkey this weekend that will tackle, among other issues, the GDP lost to global tax havens, the anti-poverty organization Oxfam is warning that it’s not just poor countries that suffer when corporations evade taxes. Julie Delahanty, Oxfam Canada’s executive director, says the only people… – Continue reading

MULTINATIONALS HIDING BILLIONS, SAYS REPORT

Tax: Luxembourg among countries helping US firms cut their tax bills by more than a quarter, campaigners say. The abuse of holding company structures in the Grand Duchy, and fiscal regimes in several other countries, allows American firms to avoid paying billions of dollars in corporate profit taxes, two NGOs… – Continue reading

Transfer pricing — the global phenomenon

THE world appears to be getting much smaller. Rapid technological advances, increased people mobility, and changes in the international political climate have all helped to break down many of the traditional barriers to global and regional trade. For dynamic, fast-growing businesses, this increased globalisation represents an excellent opportunity for businesses… – Continue reading

St Kitts & Nevis pursuing quiet diplomacy to recalibrate international relationships – PM Harris

The nine-month old Team Unity administration has been pursuing quiet diplomacy to recalibrate international relationships for the benefit of the people of St. Kitts and Nevis, reports SKN Vibes. So said St. Kitts and Nevis Prime Minister Dr. the Hon. Timothy Harris at last week’s press conference at government headquarters…. – Continue reading

Barbados, An “Ethical” Tax Haven?

The Caribbean island says its financial system is all aboveboard, yet it remains a gateway to less scrupulous offshore havens like the Cayman Islands. BRIDGETOWN — Is there “dirty” money strewn across the pristine sands of Barbados? Does something sinister hide beneath the glistening coral reefs of this former pirate… – Continue reading

Fair’s Fair: Balancing The Interests of the State and of Wealthy Migrants

Clare Maurice, Arabella Murphy and Sophie Mazzier, Maurice Turnor Gardner LLP For better or worse, the concept of “fairness” is here to stay in relation to taxation, whether domestic or international. Politicians of all persuasions like to insist that their respective policies will ensure that everyone pays his or her… – Continue reading

EY: Broadening the taxable basis across the GCC and MENA

To increase the scope of income tax laws, GCC countries are pursuing tax determinations with significantly broader interpretations of activities or actions that constitute doing business in-country. New concepts like Virtual Service Permanent Establishment and dependent agents are being used in Saudi Arabia and Kuwait to determine taxable presence or… – Continue reading

Australia: The transfer pricing Chevron decision – funding, parental support, currency… and the experts

Key Points: The rejection of the Commissioner’s position on the relevance of credit rating agencies and the relevance of implicit support will give rise to uncertainty going forward, as it is unclear how an arm’s length interest rate can be practically determined. The Federal Court’s recent decision in Chevron Australia… – Continue reading

3 Stocks to Buy if Chris Christie Becomes President

A Chris Christie administration would likely make shareholders at some major U.S. companies very happy. The two-term New Jersey Governor has called for an array of pro-growth, business-friendly reforms as he bids for the Republican nomination. Christie is in favor of lowering corporate taxes so companies earn more profits, raising… – Continue reading

G20 among biggest losers in large-scale tax abuse – but poor countries relatively hardest hit

Headline: G20 among biggest losers in large-scale tax abuse – but poor countries relatively hardest hit G20 countries are the biggest losers when US multinationals avoid paying taxes where they do business. This is the main finding of a new report on the global tax system, ‘Still Broken,’ released by… – Continue reading

U.S. missing out to corporate tax havens

U.S. companies moved $500 billion to $700 billion in profits to countries with low or no corporate tax rates in 2012 alone, according to new research published by tax reform campaigners Tuesday. Tax avoidance on such a large scale means the U.S. accounts for about 71% of profits worldwide that… – Continue reading

Bermuda: Day Of The Deed

Article by Patrick W Martin and Ashley Fife With a net worth of USD77.1 billion, Mexican telecoms businessman Carlos Slim Helú was ranked the second richest person in the world in a 2015 survey.1 At the end of 2014, 16 of Mexico’s citizens were on Forbes’ billionaires list.2 As for… – Continue reading