FATCA—the Foreign Account Tax Compliance Act—is America’s global tax law, called an American tax nightmare by the New York Times. That is an apt description. It was quietly enacted in 2010, and after a four-year ramp up, it’s finally in effect. Never before has an American tax law attempted such… – Continue reading
Even as the action plan to address Base Erosion and Profit Sharing (BEPS) is being worked out, multinationals are bracing for some turbulent times in India. For some time now, transfer pricing – the price of goods and services determined by a company when two of its subsidiaries transact –… – Continue reading
In 2014, Canadian corporations sent nearly $200 billion offshore, costing us nearly $8 billion in tax revenue. Ottawa (12 May 2015) — Figures released by Canadians for Tax Fairness (CTF) (link is external) show that the amount of money Canadian corporations are keeping in tax havens has jumped to record… – Continue reading
Two roadshow events in Canada to promote Bermuda as the jurisdiction of choice for captive insurance companies and e-commerce business have been hailed a success. The Bermuda Business Development Agency (BDA) hosted the sessions in Toronto and Calgary this week. It was standing-room only at the first event, in Toronto… – Continue reading
Top-level executives turned out for information sessions in Toronto and Calgary this week to hear a BDA-hosted delegation spell out the benefits of establishing captive insurance companies and e-commerce entities in Bermuda. The BDA said, “A 20-strong delegation from the Island delivered a compelling Bermuda message to well-attended sessions in… – Continue reading
OTTAWA —The Liberal plan for the middle class, two planks of which were unveiled this week, could risk another brain drain in Canada, stalling the national economy, says one public policy and economics expert. “It’s a real possibility,” said Charles Lammam, director of fiscal studies at the right-leaning think tank… – Continue reading
As part of its 2015 Federal Budget announcements, Canada committed to implementing the “Common Reporting Standard” (CRS) promulgated by the Organization for Economic Co-operation and Development (OECD). While the OECD’s efforts to facilitate information reporting via the CRS and Canada’s corresponding implementation of such a regime will certainly have lasting… – Continue reading
Taipei, May 2 (CNA) Taiwan has reached an agreement with Canada on the avoidance of double taxation at an annual bilateral economic consultation, the Ministry of Economic Affairs (MOEA) said Saturday. The double taxation avoidance pact, which will be signed very soon, will be favorable to Taiwan businesses because it… – Continue reading
The Supreme Court of Canada has dismissed Conrad Black’s bid to have his multi-million-dollar battle with the Canada Revenue Agency over back taxes heard by the country’s highest court. The Supreme Court of Canada has dismissed Conrad Black’s bid to have his multi-million-dollar battle with the Canada Revenue Agency over… – Continue reading
Ontario’s 2015 Budget, delivered on April 23, overhauled a number of the province’s tax credits and set out plans for a further crackdown on tax avoidance. The Budget made numerous changes to creative tax breaks, effective from April 23, 2015. The Ontario Production Services Tax Credit was reduced from 25… – Continue reading
As compared to past federal Budgets, Budget 2015 contained fewer (and arguably less controversial) international tax measures. Nevertheless, Budget 2015 did announce the Government’s intention to address taxpayer concerns relating to (i) the withholding obligations borne by non-resident employers that have non-resident employees that work in Canada, and (ii) the… – Continue reading
According to the most recent estimates, the quantity of goods carried by containers has risen from around 100 million metric tons in 1980 to about 1.5 billion metric tons in 2012. Out of these numbers, one container in every 11 that is engaged in global trade is either bound for… – Continue reading
The April 21, 2015 Federal budget released by the Conservative Government includes updates on Canada’s involvement in the BEPS project and how Canada intends to fulfill its obligations to implement an automatic exchange of tax information with the G-20. Notably (with the exception of the common reporting standard discussed below),… – Continue reading
Section 55 of the Income Tax Act (Canada) (the “Tax Act”) contains an anti-avoidance rule that prevents a corporation from converting what would otherwise be a taxable capital gain into a tax-free intercorporate dividend. Section 55 deems a dividend not to be a dividend, but rather a capital gain, where… – Continue reading
A 15-strong delegation of Bermuda industry, government and regulator representatives will take part in a Canada roadshow next week, targeting top-level executives and touting the corporate benefits of setting up a captive insurance company in Bermuda, reports the Bermuda Business Development Agency. Led by Bermuda’s Economic Development Minister Dr. Grant… – Continue reading
One million American citizens in Canada face double tax troubles. Max Reed explores these challenges in a spring series. The United States has two tools with which to collect information on accounts held by its citizens, FATCA and FBAR. Lots of attention has been paid to FATCA, less so to… – Continue reading
Yesterday afternoon, the Canadian government tabled the 2015 Canadian Federal Budget. Two measures are particularly relevant to certain employers. Withholding Relief for Non-Resident Employers and Employees To take effect next year (if the measure is enacted), Budget 2015 proposes an exemption from certain withholding requirements on payments from “qualifying non-resident… – Continue reading
Island Delegation to Tout Jurisdiction as Risk Capital and Potential e-Commerce Hub HAMILTON, Bermuda, April 27, 2015 (GLOBE NEWSWIRE) — A 15-strong delegation of Bermuda industry, government and regulator representatives will take part in a Canada roadshow next week, targeting top-level executives and touting the corporate benefits of setting up… – Continue reading
When Burger King’s owners first announced last summer’s mega-deal to gobble up Tim Hortons, the fast-food firm’s executives downplayed a key reason why they were acquiring the Canadian coffee chain and relocating corporate HQ to Canada: to cut its taxes. “Tax wasn’t really the driver of this,” Daniel Schwartz, the… – Continue reading
NUMBER OF THE WEEK: 6.5 percent The tax rate at which companies could voluntarily repatriate their foreign earnings under the Invest in Transportation Act of 2015 ( S. 981). Senators Barbara Boxer (D-CA) and Rand Paul (R-KY) introduced the bipartisan proposal, offering ways to save the Highway Trust Fund. Funding… – Continue reading
FPIs are battling it out with the income-tax department, which has issued notices demanding that they pay MAT to the tune of Rs40,000 crore New Delhi/Mumbai: Despite the government affirming that foreign portfolio investors (FPIs) can use tax treaties to fight tax demands on past capital gains, a majority of… – Continue reading
Documents exposed secret deals to slash global tax bills of multinational companies A French journalist has been criminally charged in Luxembourg for his role in exposing how hundreds of multinational companies used secret deals with the European duchy’s government to slash their global tax bills — a scheme that CBC… – Continue reading
The Minister of Finance (Canada), the Honourable Joe Oliver, presented the Government of Canada’s 2015 Federal Budget (“Budget 2015”) on April 21, 2015 (“Budget Day”). Budget 2015 contains several significant proposals to amend the Income Tax Act (Canada) (the “ITA”) while also providing updates on previously announced tax measures and… – Continue reading
Minister of Finance Joe Oliver today tabled the 2015 Federal Budget (the “Budget”), his first budget as Minister of Finance, entitled “Strong Leadership: A Balanced-Budget, Low-Tax Plan for Jobs, Growth and Security”. We are pleased to provide our summary of tax measures contained in the Budget. The Budget proposed no… – Continue reading
As has been widely predicted, today’s federal budget (Budget 2015) delivered a handful of tax “goodies” in the lead-up to the coming election. It also includes a number of important proposed changes to the corporate tax rules. They are noteworthy, although not as extensive as the corporate tax changes proposed… – Continue reading
The arrival of Netflix in Australia has brought into sharp relief the GST base erosion problem caused by global digital commerce. Along with the non-taxation of low-value imported goods, the absence of GST on services and digital products imported by consumers represents an omission from the tax base that is… – Continue reading
Finance Minister Joe Oliver faced formidable challenges, both economic and political, in delivering his first Budget. In a time of depressed oil prices, and mere months ahead of the next federal election, it appears he felt it was imperative to follow through with prior commitments to balance the budget, provide… – Continue reading
In the end, Dale travelled most of the way across his adopted country to cut his last ties to his old one. Originally from Kansas, the Strathroy, Ont. man had become a Canadian citizen in 2004, which he thought of as marking the loss of his U.S. citizenship. Global News… – Continue reading
(Reuters) – Australia needs to tighten safeguards against money laundering in its booming property market, which has attracted Chinese funds with likely links to corruption, an international anti-money laundering body said in a report released late on Tuesday. The intergovernmental Financial Action Task Force said real estate agents and lawyers… – Continue reading
The number of suspicious activity reports of potential money laundering have increased by 42 per cent to 558 cases over 2012/2013, reports the Cayman Compass. The Financial Reporting Authority, the national agency which receives the reports of suspected money laundering and other financial crime, believes the record number was prompted… – Continue reading
The OECD Mutual Agreement Procedure Statistics for 20131 (MAP Statistics), released on November 25, 2014, show a dramatic surge in the inventory of mutual agreement procedure (MAP) cases among OECD member countries. The MAP Statistics confirm that the potential for double taxation is increasing. This is reflected most starkly in… – Continue reading
U.S. guards at Canada’s rail hubs? April 20 If years from now, we discover that Prime Minister Stephen Harper turned out to be working for the U.S. government, who could be surprised? He almost had Peter MacKay indenture us to Lockheed Martin for 65 ruinously expensive F-35s. When he isn’t… – Continue reading
UBS whistleblower Stéphanie Gibaud talks to the Herald before travelling to Argentina With tax evasion allegations against HSBC under the spotlight in Congress, a whistleblower from another banking giant famous for its secrecy, Switzerland’s UBS, says she is coming to the country to testify soon, and warns that emerging economies… – Continue reading
The outlook for uranium, moribund for some time, is looking up. And that means shares of Cameco Corp., the Saskatoon-based miner one analyst calls “the only real blue-chip stock in the sector,” are up, too – about 20 per cent from their 52-week lows. The stock has received a host… – Continue reading
KATHMANDU, APR 16 – With the selected consultant for the Tanahu Hydropower Project demanding income tax exemption during ongoing negotiations before signing a contract, the Nepal Electricity Authority (NEA) has said that the government cannot provide the facility as the current tax law does not allow it. The NEA clarified… – Continue reading
This week, the Royal Bank of Canada became the first bank to complete cross-border Renminbi (RMB) payment using Canada’s new RMB Trading Hub through the hub’s designated clearing bank, Industrial & Commercial Bank of China (Canada). On 23 March, Royal Bank of Canada (RBC), other Canadian banks and government delegates… – Continue reading
Introduction Soft commodity prices, divergent monetary policies across major economies, high unemployment rates and weak world trade have all conspired to slow down global economic recovery over the past seven years. Consequently, governments have had to cut spending as future revenues remain uncertain. This has led governments to look for… – Continue reading
Beijing enlists seven firms, including PwC, to investigate projects and holdings this year Beijing has appointed seven audit companies, including international firm PwC, to look into the overseas assets of major state-owned enterprises as it tightens the reins on the business giants. The State-owned Assets Supervision and Administration Commission (Sasac)… – Continue reading
Everyone’s “favorite” day of the year is less than 24 hours away – Tax Day. And the big question is: Have you filed your return yet? (If you haven’t, stop reading this and go take care of that. This will still be here when you’re done.) By now, most people… – Continue reading
Duncan Card believes that his new law firm will be instrumental in attracting foreign investment to the Island. Bennett Jones (Bermuda) Ltd, which practises in association with the Canadian law firm of the same name, will be led by managing principal Mr Card, a Bermudian who has returned with his… – Continue reading
Swiss banks, for decades the bastions of secrecy, are preaching the virtue of transparency to their U.S. clients as they try to head off billions of dollars in potential fines for helping Americans evade taxes. Faced with the threat of penalties that could bankrupt some of them, almost 100 of… – 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
Swiss banks, for decades the bastions of secrecy, are preaching the virtue of transparency to their U.S. clients as they try to head off billions of dollars in potential fines for helping Americans evade taxes. Faced with the threat of penalties that could bankrupt some of them, almost 100 of… – Continue reading
The Minister of Finance for Luxembourg says his country – labelled by critics as a tax haven for multinational corporations – is committed to sweeping international tax reforms being pushed by the G20 and the Organization for Economic Co-operation and Development, as long as they create a “level playing field.”… – Continue reading
Listed companies in developed market could be avoiding as much as $82b annually London: Listed companies in developed markets are avoiding at least $82 billion (Dh301 billion) of tax a year by using tax havens and other minimisation strategies, according to detailed analysis of more than 1,000 businesses. The revelation… – Continue reading
New York, NY, April 08, 2015 –(PR.com)– The Knowledge Group/The Knowledge Congress Live Webcast Series, the leading producer of regulatory focused webcasts, has announced today that Conor Crowley, Managing Director, Vizor Software will speak at a 2-hour webcast entitled “FATCA for Government Agencies: What You Need to Know in 2015… – Continue reading
As tax filing season approaches, Canadians should watch their back in light of the new whistleblower initiatives of the Canada Revenue Agency (CRA), which will reward those who snoop into other people’s affairs and invade their privacy. Frustrated by cutbacks in staffing levels, the CRA has instead set up an… – Continue reading
Many Canadian Snowbirds who have become fed up with Canada’s long, hard winters (and there are bound to be many more this year, especially from the Eastern provinces) have purchased winter homes in Southern U.S. states. This has been an especially popular move over the past few years, with U.S…. – Continue reading
By now, most of us know that the ruling Conservatives announced they will release the Federal Budget (calling it Economic Action Plan 2015 – the “Budget”) on April 21, 2015. Once again, I will be in attendance in Ottawa representing CPA Canada and our firm. What do I predict will… – Continue reading
Suspicions rising that ‘hot money’ is being washed through Vancouver real estate As affluent Chinese buyers – spurred by relaxed regulations and a lower Canadian dollar – flood into British Columbia’s real estate market, warnings are rising that some cash deals may contravene federal money laundering rules. A 2015 report… – Continue reading
