Category: North America

Google expected to reveal growth of offshore cash funds to $43bn

Tech company’s 2015 earnings will be announced next week as governments aim to crack down on Google’s controversial tax avoidance arrangements Google is poised to confirm next week that controversial tax structures in Ireland, the Netherlands and Bermuda have boosted its offshore cash mountain to more than $43bn (£30bn), figures… – Continue reading

Central Bank Props up Offshore Yuan in Hong Kong

The People’s Bank of China supports the country’s currency and fends off short sellers in the world’s largest overseas yuan market (Beijing) – The offshore yuan market in Hong Kong has been shaken to the core by weeks of volatility that analysts blame on strong intervention by China’s central bank…. – Continue reading

US taxes and FATCA: ‘The time for hiding is over’

FATCA. Since July 2014, the five-letter acronym has instilled dread in the hearts of American expats all around the world. “The Foreign Account Tax Compliance Act (FATCA) requires banks to report information to the IRS regarding all financial accounts held by American clients,” Ines Zemelman, expat tax specialist and founder… – Continue reading

IRS Still Hunts Offshore Accounts As More Foreign Banks Sign Deals With U.S.

With the web of FATCA information exchanges, whistleblowers, cooperating witnesses, and other sources, the IRS and Justice Department have a wealth of information at their disposal. They have warned offshore account holders to disclose before it’s too late. Under FATCA, banks everywhere want to know if you are compliant with… – Continue reading

Submission for Customs Supplement Tax Administration Jamaica

Transfer pricing is the general term for the pricing of cross-border and domestic, intra-group transactions between connected parties. It refers to the setting of prices for transactions between connected persons involving the transfer of property or services. Companies can be connected in various ways, for example, two wholly owned subsidiaries… – Continue reading

Irish Facebook data centre ‘is not tax dodge’, says Mark Zuckerberg

Facebook founder Mark Zuckerberg has been defending his decision to build a new data centre in Ireland against claims the move is a tax dodge. The social media mogul announced the start of construction of the €200m facility at Clonee on the Meath-Dublin border on his own Facebook page, quickly… – Continue reading

IRS Adds More Foreign Banks To Disclosure Blacklist

The US Internal Revenue Service (IRS) has added more banks to the swelling list of financial institutions involved in tax avoidance. Customers of these banks owning up to past financial indiscretions under the Offshore Voluntary Disclosure Program (OVDP) face penalties based on balances over the past eight years. Penalties for… – Continue reading

How Much Revenue The U.S. Is Losing Through Tax Inversions, And How Much Worse It May Get

Yesterday was quite a day for corporate tax geeks. We saw a corporate tax inversion that comes with a long, Baroque history; an estimate by Reed College economist Kim Clausing that inversions and other income-shifting techniques reduced Treasury revenues by as much as $111 billion in 2012; and a new… – Continue reading

Anguilla Best Flat Tax Country for a Low Tax Lifestyle

Anguilla levies a 3% flat rate of personal income tax and is otherwise a tax haven with a stunning climate and amazing Carribean lifestyle Whilst there are various categories of flat tax, including marginal flat tax and Hall-Rabushka flat tax, in its simplest form flat tax is simply a rate… – Continue reading

Here We Go Again … IRS Destroys Another Hard Drive

The Internal Revenue Service appears to have violated a court order once again requiring the preservation of evidence needed by investigators looking into questionable practices at the agency. In a case sure to stir up memories of the Lois Lerner investigation, which saw IRS Commissioner John Koskinen dragged before Congress… – Continue reading

S. Korea, Macau to sign tax information exchange agreement

Macau’s Financial Services Bureau (DSF) has confirmed to Business Daily that the local authority is to sign a Tax Information Exchange Agreement (TIEA) with South Korea, which would add to the existing 15 jurisdictions that have already signed this agreement with the territory. According to the Bureau, its South Korean… – Continue reading

US firm Johnson Controls to cut tax bill with $16bn Tyco takeover

Car battery and heating equipment maker accused of ‘stranding honest taxpayers’ Johnson Controls, a US maker of car batteries and heating and ventilation equipment, has agreed to buy Irish-based peer Tyco International in a $16.5 billion (€15.23 billion) deal that will lower its tax bill. By redomiciling to Tyco’s headquarters… – Continue reading

Anguilla Best Flat Tax Country for a Low Tax Lifestyle

Whilst there are various categories of flat tax, including marginal flat tax and Hall-Rabushka flat tax, in its simplest form flat tax is simply a rate of tax that remains consistent with a constant marginal rate. What this means is, as an income tax payer in a country with such… – Continue reading

Google Strikes Deal With U.K. Tax Authority

DAVOS, Switzerland—Google said Friday that it has struck a deal with U.K. authorities that will settle a tax dispute and boost its corporate taxes in Britain, part of a broader effort by European governments to wring more out of big firms in the tech sector. As part of the settlement,… – Continue reading

GE Healthcare: US healthcare giant makes fortune from NHS but pays hardly a penny in tax

GE division makes millions in sales to health service, and is net beneficiary from UK Exchequer One of the biggest suppliers of equipment and testing services to the NHS pays barely any corporate tax in the UK, despite receiving hundreds of millions of pounds a year from medical sales to… – Continue reading

BEPS rules to be made compulsory from 1 April

India to change laws in Union Budget to make country-by-country reporting mandatory for Indian multinationals New Delhi: India will change laws in the upcoming budget to make country-by-country reporting mandatory for Indian multinationals to ensure they follow so-called base erosion and profit shifting (BEPS) guidelines. The norms were announced in… – Continue reading

Adobe Shifts Hundreds of Millions Offshore, Revealing, Like PDF Documents, Its Profits Are Portable Too

While most computer users are likely familiar with Adobe products, they are probably not aware of the company’s tax-dodging practices. The maker of the ubiquitous PDF reader and Flash software earlier this week released its annual report, which revealed the company is rapidly diverting profits offshore. Its stash of “permanently… – Continue reading

5 Tax Deductions Homeowners Won’t Want to Miss

One of the biggest financial benefits of owning a home is qualifying for the tax breaks that homeowners are eligible to receive. Many of the tax deductions for home-related expenses are well-known, but others often slip under the radar. Below, we’ll run through the list of deductions for homeowners that… – Continue reading

HMRC tax dispute specialist joins global alliance of lawyers

London-based international law firm Edwin Coe has become a member of a global alliance of lawyers spread across 41 countries. The International Alliance of Law Firms, founded in 1990, already has 60 member firms in EMEA, the US, Latin America, Canada, and Asia-Pacific. Its website describes itself as “an international… – Continue reading

Tax-dodging by the superrich is driving global inequality, Oxfam says

Tax dodging by the super-rich is one of the main drivers of global income inequality and must be sharply curtailed, according to a new report from the global nonprofit Oxfam. Citing research by Berkeley economist Gabriel Zucman — a protégé of Thomas Piketty, author of the global bestseller on inequality,… – Continue reading

The hidden wealth of nations

India’s biggest source of FDI is India itself, money departing on a short holiday to a tax haven and then routed back as FDI. Will the government muster up the political will to clamp down on the tax-allergic business elite? This could be a bumper year for the ever-lucrative tax… – Continue reading

Minister Brantley Highlights Implications of FATCA on the Federation

Basseterre, St. Kitts, January 21, 2016 (SKNIS): The Honourable Mark Brantley, Minister of Foreign Affairs and Aviation, said that the Foreign Account Tax Compliance Act (FATCA) is demonstrative of the Federal Government’s seriousness in playing its role in an ever-changing global environment. He made these comments during an appearance on… – Continue reading

Apple Steps Up Lobbying Efforts Against European Tax Probe

Apple Inc. is pushing back against an European tax investigation that could force the iPhone maker to pay more than $8 billion in back taxes. Chief Executive Officer Tim Cook met with the European Commission’s antitrust chief Margrethe Vestager in Brussels on Thursday to press the company’s case. After the… – Continue reading

The Netherlands implements OECD BEPS Country-by-Country Reporting as well as the amendments to the EU Parent-Subsidiary Directive

As from 1 January 2016, new rules have become effective in the Netherlands that require multinational enterprises (“MNEs“) to comply with new transfer pricing documentation requirements, including the obligation to prepare a Country-by-Country Report (“CbC Report“), a Master File and a Local File. These rules essentially implement Action 13 of… – Continue reading

Don’t believe the ‘loopholes’ hype

Recent media coverage has prompted impassioned calls for Congress to close the “loopholes” that supposedly explain why the 400 richest taxpayers paid an average federal individual income tax rate of 16.7 percent in 2012. Unfortunately, these calls are based on outdated numbers and an incomplete picture of the tax system…. – Continue reading

Asia-Pacific financial institutions unprepared for FATCA and GATCA compliance

Best positioned firms will upgrade technology infrastructure Financial institutions across Asia-Pacific are behind the curve when it comes to being prepared for evolving global tax reporting regulations. That’s according to a recent survey by Wolters Kluwer Financial Services and the GRC Institute, which indicates that more than 90% of financial… – Continue reading

Intl bodies to fight global tax evasion / Maximum of $240 bil. said to be dodged

The Yomiuri Shimbun Four international organizations will join forces to devise unified global tax rules aimed at preventing tax evasion by multinational companies. The four entities involved are the Organization for Economic Cooperation and Development, the United Nations, the International Monetary Fund and the World Bank. The OECD — whose… – Continue reading

Get a reward for helping Canada Revenue find offshore tax cheats

THE Canada Revenue Agency (CRA) has a new program that offers rewards to individuals who provide precise details about Canadians hiding money or assets offshore and not paying the taxes they owe. It is not illegal to invest money or hold accounts offshore but Canadian residents must report their worldwide… – Continue reading

Tanzania: Managing Tax Risks – Double Tax Treaties and Implications to Undertakings of Multinationals

The term double taxation refers to an exposure to tax more than once on the same profit or income. There are two types of double taxation i.e. economic double taxation and juridical double taxation. Economic double taxation is broad and occurs in a situation where an amount of income is… – Continue reading

Lionel Messi’s tax fraud trial conflicts with Copa America

MADRID (AP) – Lionel Messi’s tax fraud trial has been set for May 31-June 3, conflicting with the start of the centennial Copa America in the United States. The Copa America Centenario will kick off June 3, meaning the five-time world player of the year will not have the best… – Continue reading

IRS: Banks Get More Time to Certify Accounts Under FATCA

Jan. 19 — Foreign financial institutions will have more time to certify whether their pre-existing accounts are owned by U.S. taxpayers under the Foreign Account Tax Compliance Act, the IRS said in Notice 2016-8. The Jan. 19 notice answers many significant questions raised by taxpayers on compliance with the law…. – Continue reading

Exclusive: EU plans faster investment tax refunds from 2017 – document

European Union countries will have to introduce rules from 2017 to speed up tax refunds on cross-border investments, part of a drive to improve the working of financial markets and lift economic growth, according to an EU document seen by Reuters. The executive European Commission wants to simplify “withholding tax”… – Continue reading

Cayman copies US tax haven’s limited liability law

Cayman Islands has introduced limited liability company (LLC) legislation that combines the key features of a company and a partnership, intended to increase the structuring options for US investment funds. US clients have reportedly been requesting this legislative development for some time to provide a better match with the Delaware… – Continue reading

PROPERTY TAX POST: ROLL OF THE ‘D.I.C.E.’ —BUSINESS PERSONAL PROPERTY TAX RELIEF IS A CRAP SHOOT

Each year, states enact tax law changes and create local government programs that provide personal property tax breaks for businesses. These concessions come in various forms—deductions, incentives, credits and exemptions (i.e., D.I.C.E.), and they have a significant impact on whether businesses remain viable. Many states commonly impose ad valorem tax… – Continue reading

QROPS – The Great American Pension Nightmare

The American dream can turn into a nightmare for expats wanting to switch their UK pensions to a Qualifying Recognised Overseas Pension Scheme (QROPS). Thousands of expats cross the Atlantic both ways with London home to Americans in sectors such as finance, entertainment and media, while Florida is a popular… – Continue reading

Hong Kong: Business Compliance Changes At A Glance

According to the World Bank’s ‘Doing Business 2016 Report’, Hong Kong continues to be one of the world’s easiest places to do business, and tops the ranks in Asia Pacific for starting one. To sustain its economic growth and competitiveness, the Hong Kong government underwent three key changes in 2015:… – Continue reading

British Virgin Islands: Adoption Of The OECD Common Reporting Standard In The British Virgin Islands

On 1st January 2016, an amendment to the Mutual Legal Assistance (Tax Matters) Act, 2003 came into force which implements the Organisation for Economic Co-Operating and Development (OECD) Common Reporting Standard for the exchange of tax information (CRS) in the British Virgin Islands (BVI). Globally this means that participating jurisdictions… – Continue reading

US TIGHTENS UP ON LUXURY PROPERTY PURCHASES THROUGH OFFSHORE COMPANIES

The US’s Financial Crimes Enforcement Network has announced it will be investigating the individuals behind secretive all-cash purchases of high-end luxury real estate in a six-month trial programme intended to enhance the treasury’s anti-money laundering efforts. The initiative will focus on all-cash property purchases of over $3 million in New… – Continue reading

It’s time for Canada to take action on its offshore real estate problem

The U.S. Treasury Department has launched a new initiative aimed at identifying anonymous cash buyers of luxury properties. Currently, purchasers can hide their identities by acquiring real estate through limited liability companies or other shell vehicles that prevent their names from being linked to any specific address. The new rule… – Continue reading

Important Amendments to the British Virgin Islands (BVI) Business Companies Act of 2004

The BVI Business Companies Act of 2004 has been amended by the BVI Business Companies (Amendment) Act of 2015. This amendment has come into effect on the 15th January 2016. The key amendments mainly relate to the following highlighted areas: Register of Directors (ROD): In the case of a new… – Continue reading

On tax avoidance

The only thing worse than paying taxes is the idea that other people avoid paying their fair share of them. On the subject of tax avoidance by other people, I can think of at least three principal feelings. As the kids say, I feel all the feelings. Outright tax fraud… – Continue reading

Apple Inc. (AAPL) May Face $8 Billion Tax Bill in European Probe

Apple Inc. (NASDAQ:AAPL), the world’s company by market capitalization, may face more than $8 billion tax bill in connection with the investigation of the European Commission regarding its tax policies, according to Bloomberg. Matt Larson, a litigation analyst Bloomberg Intelligence analyzed the European Commission’s investigation against Apple, which was accused… – Continue reading

Expat eyes drift offshore

Offshore Financial Centres (OFCs) are jurisdictions, usually self-governing, which because of their low tax regimes, have specialized in providing commercial services to corporations and individuals, whether or not they are normally resident in that jurisdiction. The better-known offshore financial centres are small and sparsely populated countries or islands, and are… – Continue reading

Apple could owe $8billion of back taxes in Europe amid claims company sheltered overseas profits in Irish tax havens

European Commission is due to rule on Apple’s tax affairs in March But recent rulings suggest that report is likely to go against tech giant Probe investigating if firm negotiated low tax rate with Irish authorities If taxes are recalculated at higher rate, Apple could end up owing $8bn Apple… – Continue reading