Category: North America

Offshore jurisdictions asked to embrace transparency

In a world of data breaches and political unrest, the concept of confidentiality faces a certain death, warned British Virgin Islands lawyer Tim Prudhoe on Tuesday. Rather than fear the future, the Kobre & Kim partner advised offshore tax jurisdictions to embrace transparency and find benefit in a turbulent world…. – Continue reading

Trump’s tax plan could have rich New Yorkers fleeing for Florida

President Trump has signed three executive orders to spark reviews of tax and financial regulations so taxes on businesses and individuals can be cut. The approach would be different from Trump’s earlier plan, which was criticized as an approach that would mostly benefit higher earners. Michael Zezas, a strategist at… – Continue reading

Deal that sends Canadian bank records to IRS is ‘illegal,’ lawyer tells U.S. committee

Witnesses call for repeal of Foreign Account Tax Compliance Act An agreement that has resulted in hundreds of thousands of Canadian banking records being sent to the U.S. Internal Revenue Service could violate the U.S. constitution, a congressional subcommittee heard Wednesday. Testifying before a subcommittee of the House Committee on… – Continue reading

Trump Plans to Seek 10% Tax on Offshore Earnings, Official Says

President said to call for taxing pass-throughs at 15% Pass-throughs are currently taxed at higher individual rates President Donald Trump plans to propose a 10 percent tax on more than $2.6 trillion in earnings that U.S. companies have stockpiled offshore, said a White House official familiar with the president’s tax… – Continue reading

Survey: Citizens in G-20 countries favor gov’t cooperation over tax competition

The overwhelming majority of people in G-20 countries believe that cooperation between governments on tax policy is more important than competition to increase national tax revenue. According to a survey by the Association of Chartered Certified Accountants, the preference for cooperation over competition is strongest in Argentina, Australia, Brazil, France,… – Continue reading

Chevron: a game-changer for multinational tax avoiders

The Australian Tax Office had a superb win against Chevron in the Federal Court last week, but there is something everyone is missing, something that will turn the art of tax avoidance on its head; a game-changer for multinationals. Put simply, Chevron borrowed US$2.5 billion in the US at less… – Continue reading

Ontario Introduces the new Non-Resident Speculation Tax

Overview of the Tax As expected, the Government of Ontario has introduced a new non-resident speculation tax (“NRST”) that takes effect on April 21, 2017. The NRST is a 15% tax payable on the purchase of an interest in residential property located in the “Greater Golden Horseshoe” area (which includes… – Continue reading

US tax cuts could lead to financial instability: IMF

Report warns that Trump’s proposed corporate tax reforms could spark risk-taking WASHINGTON • The International Monetary Fund (IMF) warned yesterday that United States President Donald Trump’s proposed tax cuts and reduction of financial regulations could spark a new round of financial risk-taking of the type that preceded the last crisis… – Continue reading

St Kitts-Nevis joins Antigua-Barbuda in rejecting Illinois tax haven label

BASSETERRE, St Kitts (WINN) — Efforts by one American state to officially label St Kitts and Nevis a foreign tax haven are being strongly objected to by the federation’s foreign affairs minister, Mark Brantley, thus joining Antigua and Barbuda in a similar protest. A proposed House Bill 3419 in the… – Continue reading

Understanding the taxation of international and expatriate assignments

(Second of two parts) In last week’s article, we discussed how or why taxpayers working on international assignments have to consider the impact of different tax jurisdictions on their individual tax obligations. We also explained how most companies implement a tax equalization (TEQ) arrangement for the employees so that they… – Continue reading

Germany Provides Update On 10-Point Tax Evasion Plan

The German Ministry of Finance has published a progress report on its 10-point plan to combat tax evasion, which was first announced in the wake of last year’s Panama Papers leak. The plan, launched on April 12, 2016, outlines the measures that Germany wants to put in place at domestic… – Continue reading

Campaigners demonstrate ‘In Praise of Whistleblowers’

Members of the Methodist Tax Justice Network (MTJN) and the Tax Justice Network (TJN) gathered outside the Embankment headquarters of PricewaterhouseCoopers on Wednesday 5 April 2017 to demonstrate in support of whistleblowers and against the actions of PwC, who have facilitated global tax avoidance, tried to prevent the release of… – Continue reading

Sao Paulo Property Secrecy Exposes Continuing Role of UK Tax Havens

A new report from Transparency International has revealed that more than US$2.7 billion worth of property in Sao Paulo, Brazil’s biggest city, is hidden behind shell companies, many of which have close links to the United Kingdom, which has many offshore tax havens in its overseas dependencies. Using newly released… – Continue reading

Sao Paulo Property Secrecy Exposes Continuing Role of UK Tax Havens

A new report from Transparency International has revealed that more than US$2.7 billion worth of property in Sao Paulo, Brazil’s biggest city, is hidden behind shell companies, many of which have close links to the United Kingdom, which has many offshore tax havens in its overseas dependencies. Using newly released… – Continue reading

How to Shut Down Offshore Corporate Tax Avoidance, Full Stop

A new bill introduced this week by Rep. Mark Pocan (D-WI), the Tax Fairness and Transparency Act, would rip out the offshore corporate tax avoidance system by its roots. This legislation combines into a single, comprehensive bill elements of three pieces of legislation that Rep. Pocan has proposed in previous… – Continue reading

More objections to A&B being listed as tax haven

Antigua & Barbuda, on Wednesday, launched what government said was a strong objection with the US State of Illinois, which has introduced legislation, listing the twin island state and 10 Caricom countries as tax havens. In letters to the Speaker of the House of Represen-tatives of the Illinois General Assembly,… – Continue reading

G20 Citizens Favor BEPS Crackdown Over Tax Competition

Citizens in G20 countries would prefer their government engage in international efforts to improve the functioning of international tax rules than compete for tax receipts, says a new survey. G20 public trust in tax, a report compiled by the ACCA (the Association of Chartered Certified Accountants), IFAC (the International Federation… – Continue reading

OECD recommends introduction of US-style deferred prosecution agreements in Scotland

ANALYSIS: US-style deferred prosecution agreements (DPAs) should be introduced in Scotland to deal with corporate offending, according to a recent report by the global Organisation for Economic Cooperation and Development (OECD). Foreign bribery should attract significant penalties, and Scotland’s civil settlement regime is potentially too lenient, according to the report,… – Continue reading

Tax haven label haunts Barbados

There is a worrying perception of Barbados on as a tax haven, a view that is hampering the island’s status as a jurisdiction in which to do business, says President of the Barbados International Business Association (BIBA) Gregory McConnie. Equally troubling, McConnie says, is that Barbados’ primary investing jurisdiction, Canada,… – Continue reading

1099 Pro Offers Common Reporting Standard Software for CRS Reporting

1099 Pro now offers Common Reporting Standard software for CRS reporting as part of the OECD’s Automatic Exchange of Information for Tax Matters (AEoI) program. 1099 Pro, Inc., https://www.1099pro.com, known for over 25 years of Windows based product development for 1042-S, 1099, & FATCA reporting recently confirmed the upcoming release… – Continue reading

Germany: Legislative proposal in reaction to Panama Papers

As a reaction to the so-called “Panama Papers” the German legislator proposed, on 30 December 2016, a draft bill to combat tax avoidance (so-called Steuerumgehungsbekämpfungsgesetz – StUmgBG). The aim of the draft bill is to enhance the German tax authorities’ means to determine and reveal EU-foreign domicile company structures which… – Continue reading

Art of the deal: Trump, Dems look for common ground to close tax loopholes

Venture capitalists, investors left unfazed Both President Trump and Capitol Hill Democrats head into negotiations over tax reform vowing to put the squeeze on hedge fund managers by closing the carried interest tax loophole — a point of agreement that held out promise for becoming a foundation for a once-in-a-generation… – Continue reading

€8 billion annual risk of money laundering

Malta’s threat places it 20th out of 27 states, Pana Committee told Malta faces an annual €8 billion money laundering risk, according to figures quoted in a study presented to the European Parliament’s Pana committee. The committee, which visited Malta in February for a fact-finding mission on the island’s involvement… – Continue reading

Panama Must Continue To Improve Transparency: IMF

Panama must continue to improve tax transparency and how it exchanges information relevant in tax matters to sustain growth in its economy, the International Monetary Fund has said. In the concluding statement for its Article IV visit, warned that the countries shift toward “increasing trade restrictions could lead to a… – Continue reading

House bills to fund infrastructure reward big multinationals

U.S. Rep. John Delaney has introduced two infrastructure funding bills — H.R. 1669 and H.R. 1670 — that good government groups say would further incentivize corporate tax dodging, reward the biggest multinational corporations for stashing their profits in offshore tax havens and replace one system riddled with tax loopholes with… – Continue reading

Amazon not liable for $1.5bn tax bill, judge rules

Online giant wins transfer pricing case against US Internal Revenue Service Amazon. com has won a tax dispute with the US Internal Revenue Service (IRS), involving more than $1.5 billion (€1.39 billion), in relation to the transactions of a Luxembourg unit more than a decade ago. Judge Albert Lauber of… – Continue reading

Law Society reaches understanding with IRD on FATCA

The New Zealand Law Society says that following discussions with Inland Revenue and the New Zealand Bankers’ Association it has now reached an understanding with Inland Revenue about application of FATCA to lawyers’ trusts accounts. FATCA is the United States’ Foreign Account Tax Compliance Act. Its objective is to reduce… – Continue reading

Ottawa to spend $500M on pursuit of tax cheats, budget reveals

Money will be used to hire more auditors and develop computer systems to “target high-risk international tax” evasion. Tax auditors and fraud investigators have been given more than half a billion dollars to pursue tax cheats, and the government expects them to collect five times that much in additional taxes…. – Continue reading

EU Lawmakers Visit IRS, Delaware as Tax Haven Concerns Mount

The European Parliament’s Panama Papers investigative committee is preparing for a “fact-finding” visit with counterparts in the U.S. Congress, as well as officials from the Treasury Department and Internal Revenue Service. The European Union lawmakers’ four-day U.S. trip, which begins March 21, will include a visit to Delaware for meetings… – Continue reading

CARICOM seeks FATCA delay, but law may prove irrelevant

The Caribbean Community is looking at spending nearly quarter of a million dollars on a Washington-based consultant to lobby the Trump administration about the Foreign Accounts Tax Compliance Act. Cayman appears unlikely, however, to be affected by any lobbying – or even FATCA repeal – in the wake of last… – Continue reading

FATCA repeal on agenda of US Republicans

Washington’s Foreign Accounts Tax Compliance Act, known as FATCA, will be assailed afresh as lawyers and lobbyists renew efforts to repeal the law as part of President Donald Trump’s tax reform. Washington-based Jim Jatras, a Republican and co-leader of the Campaign to Repeal FATCA, says “lots is happening,” and his… – Continue reading

Combatting Foreign Tax Evasion With New Filing Requirements for Foreign-Owned Disregarded Entities: Tax Update, Volume 2017, Issue 2

The new regulations expand the filing requirements for Form 5472 to include disregarded entities with foreign owners when there are certain reportable transactions. If a non-U.S. person (individual or corporation) owns 100 percent of the stock of a U.S. corporate subsidiary, the subsidiary needs to obtain an employer identification number… – Continue reading

Tax executives anticipate Trump reforms

Tax reform is widely expected under the Trump administration by the corporate tax executives polled by BDO USA in a new survey. BDO’s 2017 Tax Outlook Survey polled 100 tax executives at public companies across the U.S., and found that 100 percent of the surveyed tax executives believe tax reform… – Continue reading

Anti-money laundering rule looms for advisers

WASHINGTON — In the current deregulatory environment, investment advisers might expect a reprieve from new federal compliance rules. But one exception is the proposal for an anti-money-laundering regulation, which experts believe is likely to become the law of the land, bringing with it a significant new compliance responsibility. A year… – Continue reading

Wolf proposal to eliminate Delaware loophole

Creating a fairer tax system is on the state budget agenda again with a proposal from Democratic Gov. Tom Wolf to eliminate a business tax loophole. Wolf wants to close the Delaware loophole — a mechanism that allows businesses headquartered in other states to avoid paying taxes on their operations… – Continue reading

Irish Citizen Denied US Tax Refund On Gambling Winnings

The United States Court of Federal Claims has turned down a claim from an Irish citizen that more than USD5m in US tax withheld on gambling winnings should be refunded under the US-Ireland double tax avoidance treaty. The claim was filed by the plaintiff, John P McManus, after USD5.22m in… – Continue reading