A Laguna Beach doctor was sentenced today to probation and ordered to pay about $235,000 in fines and restitution for hiding an offshore bank account. Baruch Fogel, an obstetrician and gynecologist, diverted at least $8 million to an undeclared bank account in Luxembourg through the Israel-based Bank Leumi, according to… – Continue reading
Training and planning have helped insurance brokers meet new tax reporting regulations for 2015, and compliance is moving into the “another part of doing business” phase. Initial reporting under the Foreign Account Tax Compliance Act, meant to help combat international money laundering, began Jan. 1. “The go-live in January was… – Continue reading
India and the US recently signed a tax information sharing agreement that will facilitate exchange of information between the two countries, beginning October. Foreign Account Tax Compliance Act (Fatca) was enacted by the US government in 2010, as part of the Hiring Incentives to Restore Employment (HIRE) Act. Fatca requires… – Continue reading
HC order had exempted Mauritius-based Copal Group from capital gains tax liability in India The income tax department has approached the Supreme Court seeking to quash a Delhi High Court order that exempted a series of transactions by Mauritius-based Copal Group — having assets in the US and in India… – Continue reading
The Barbados Revenue Authority (BRA) was subjected to rigorous assessments by the United States Internal Revenue Service (IRS) recently in a bid to verify the island’s readiness to enact the Foreign Account Tax Compliance Act (FATCA), reports Barbados Today. Anthony Gittens, the BRA’s manager of policy and planning, said as… – Continue reading
Second-quarter data on US citizenship renunciations is out, with a surprising trend—the lowest quarterly number of people giving up their American citizenship since late 2012, according to a recent release by the Treasury Department, reports the Wall Street Journal. Since the Foreign Account Tax Compliance Act (Fatca) was enacted in… – Continue reading
The United States finally took its first step toward a more competitive tax position for intellectual property in the United States. Although some might call it a baby step, the release this week of a discussion draft of legislation proposed to lower the tax rate on income from intellectual property… – Continue reading
The tax authorities in Portugal today announced that the initial reporting deadline for foreign financial institutions has been extended to 30 November 2015 (from the original deadline of 31 July 2015). Also, while it has been reported that negotiations for an intergovernmental agreement (IGA) between Portugal and the United States… – Continue reading
The U.S. Department of the Treasury on its webpage that is dedicated to FATCA has published the FATCA Agreement that was concluded between the Government of the United States and the Government of the Republic of Turkey. The agreement is a so-called Model 1 IGA. Already in June 2014 the… – Continue reading
The month of July has seen several significant developments regarding implementation of the Foreign Account Tax Compliance Act (FATCA), which has been fully effective since July 1, 2014. First, the IRS Office of Chief Counsel issued an advice memorandum regarding the applicability of the tax returns and return information confidentiality… – Continue reading
On July 27, 2015, the U.S. Tax Court issued a stunning rebuke to the IRS by invalidating the part of the Internal Revenue Services’ (IRS) cost-sharing regulations under code section 482 that says taxpayers have to take into account, among other costs, the costs of stock-based compensation. The Altera decision… – Continue reading
First it was three years, now it’s three months. The Senate’s attempt to pass a multiyear highway bill ran off the road this week after House Republicans announced they will adjourn one day early for the month-long August recess. The House’s early departure forced the Senate to acquiesce to a… – Continue reading
Canadian financial institutions will be subject to the Organisation for Economic Co-operation and Development’s (OECD) Common Reporting Standard as of July 1, 2017 with the first exchanges of financial account information beginning in 2018. The CRS, known formally as the Standard for Automatic Exchange of Financial Account Information in Tax… – Continue reading
Since July 1, eleven more Swiss banks have entered deferred prosecution agreements with the U.S. government. The subject is tax evasion involving American account holders. Today, banks everywhere want to know if you are compliant with the IRS. Under FATCA, the entire world is lending the IRS a hand. Meanwhile,… – Continue reading
Donald Trump did not like the tax reform Ronald Reagan signed into law in 1986. In an op-ed in The Wall Street Journal, he called it “one of the worst ideas in recent history.” The reason for his dislike was that the reform put the kibosh on real estate tax… – Continue reading
While preparing its bid for Tim Hortons Inc. last year, Burger King Worldwide Inc. initially wanted to set up the new parent company of Canada’s iconic supplier of double-doubles and maple-glazed doughnuts across the Atlantic in Britain, to avoid taxes. Miami-based Burger King’s first offer to buy the doughnut chain… – Continue reading
The Cyprus Tax Department announced that Financial Institutions which report information to the Cyprus tax authorities under the Cyprus – United States Foreign Account Tax Compliance Act (FATCA) Agreement will not be required to file nil returns. The FATCA Agreement between Cyprus and the United States was signed on 2… – Continue reading
The Foreign Account Tax Compliance Act (FATCA)[LR1] is generally associated with reporting requirements for foreign banks and foreign entities to disclose the names of U.S. individuals using such foreign vehicles to hide U.S. financial accounts. (See all three blog posts in this series on FATCA compliance.) However, there is an… – Continue reading
Tax savings drove the acquisition strategy of Valeant Pharmaceuticals International Inc. and led to Burger King’s move to Canada, according to a U.S. Senate committee report. Taxes appear to be much more important to the deals than the companies say, according to an advance copy of the report and testimony… – Continue reading
GOVERNMENT HAS TAKEN key steps to meet the requirements of the Foreign Account Tax Compliance Act Intergovernmental Agreement (FATCA IGA), which allows for the reciprocal exchange of information between the USA and Barbados. Minister of Finance, Christopher Sinckler, outlined the key steps as amending the Income Tax Act and putting… – Continue reading
MUMBAI: The identity of taxpayers who opt for an advance pricing agreement (APA) in the field of transfer pricing will continue to remain confidential. Such information cannot be made available under the provisions of the Right to Information Act (RTI), according to the Central However, responding to a second appeal… – Continue reading
There is an intimate relationship between art and finance. In the public sphere, the state plays a predominant role in funding and maintaining national art collections. The private sphere is dominated by private patronage. For example, artists in medieval Italy were funded by wealthy families such as the Medici, and… – Continue reading
As U.S. expats struggle with the IRS’s punitively strict tax reporting requirements, Canadian expats are now grappling with harsh government measures of their own. Ontario’s top court has ruled that Canadian expats who have lived abroad for five years should not be allowed to vote in federal elections because it… – Continue reading
An investor, who purchased shares of Silver Wheaton Corp. (USA) (NYSE:SLW), filed a lawsuit in the U.S. against Silver Wheaton Corp. in connection with certain allegedly false and misleading statements made between March 30, 2011 and July 6, 2015. Investors who purchased a significant amount of shares of Silver Wheaton… – Continue reading
The Mauritius Revenue Authority has extended the Foreign Account Tax Compliance Act (FATCA) reporting deadline to 31 August 2015. The FATCA Agreement between Mauritius and the United States was signed on 27 December 2013. FATCA seeks to obtain information on accounts held by U.S. taxpayers in other countries. It requires… – Continue reading
Blaming foreigners for homegrown economic woes is a tradition of sorts in Washington. In recent years, the favored scapegoat has been China and its folkloric trade indiscretions. But, lately, some have taken to demonizing foreign companies for the sins of a broken U.S. corporate tax system. Given the importance of… – Continue reading
A U.S. Senate investigative subcommittee, which has used its power for more than a decade to scrutinize corporations and financial institutions for wrongdoing, is shifting its focus to keeping tabs on the government. The U.S. Senate Permanent Subcommittee on Investigations is slated to hold its first hearing under new leadership… – Continue reading
On July 28, 2015 the Dutch Government published the English text of the Agreement between the Kingdom of the Netherlands, in respect of Aruba, and the Czech Republic for the exchange of information on tax matters (hereafter: the TIEA), which was signed in the Hague on June 29, 2015. Although… – Continue reading
A litigation suit has been filed against the US federal government arguing the Foreign Account Tax Compliance Act (FATCA) is “unconstitutional” and violates privacy rights, with implications for Australian financial institutions. The controversial FATCA tax legislation – which was introduced by the Obama Administration in 2010 – requires foreign financial… – Continue reading
A Huddersfield tycoon, accused of masterminding one of Europe’s biggest tax frauds, is expected to be extradited from the USA to Germany. Mohammad Safdar Gohir has been in a Las Vegas jail for more than a year and is now awaiting deportation to Germany following a US court’s decision. Gohir,… – Continue reading
The Barbados Revenue Authority (BRA) will host a public seminar this week entitled “Implementing the Foreign Account Tax Compliance Act: Where Are We Now?” The event will provide representatives and employees of financial institutions who do business with US persons with an update on the US Foreign Account Tax Compliance… – Continue reading
Billionaire offshore tax cheat Igor Olenicoff has won a big one in his long running court battle with his former Swiss bank, UBS AG, and his former UBS banker turned whistleblower, Bradley Birkenfeld. In a ruling from the bench Thursday, Orange County Superior Court Judge Kim G. Dunning shot down… – Continue reading
REPRESENTATIVES AND EMPLOYEES of various financial institutions on the island who do business with US persons will soon get an update on the Foreign Account Tax Compliance Act (FATCA). The Barbados Revenue Authority (BRA) will host a public consultation entitled Implementing the Foreign Account Tax Compliance Act: Where Are We… – Continue reading
Tax season is daunting enough at home – let alone in a foreign country. That’s why expats David and Carrie McKeegan started Greenback, the tax company designed specifically for American expats. The Local talked to the couple about how to handle taxes in Switzerland. Taxes are complicated enough in your… – Continue reading
The Revenue Agency has confirmed that it has finalized its instructions for Italian financial institutions (FIs) to transmit their data to comply with the Foreign Account Tax Compliance Act (FATCA) inter-governmental agreement (IGA) between Italy and the United States. FATCA, enacted by the US Congress in 2010, is intended to… – Continue reading
Where a foreign company renders professional services to a South African company in South Africa, it is important that the foreign entity considers whether, as a result of rendering such services, the foreign company will create a permanent establishment in South Africa. The reason why this becomes important is that… – Continue reading
White-collar criminals who launder billions by buying luxury UK properties must be tackled, Prime Minister David Cameron said on Tuesday. Experts warn these fraudsters are distorting the UK property market and pushing up house prices in the process. Cameron’s criticism of money laundering formed part of a broader speech on… – Continue reading
Fraudsters behind the latest phone scam making the rounds appear to believe that Canadians pay taxes to the American Internal Revenue Service. “Notice against your name for tax fraud, for tax evasion,” the recorded message begins and continues with its threatening tone. “So before this matter goes to complaint goes… – Continue reading
Former Attorney-General Mark Pettingill describes the suggestion he had someone seeking payment of a bribe on his behalf as “ridiculous” A developer’s allegations of Government corruption over the development of the Hamilton waterfront are “farcical” and based on “hearsay, innuendo and lies”, according to Mark Pettingill, the One Bermuda Alliance… – Continue reading
A senior GOP lawmaker will roll out a plan Wednesday to cut taxes for income spurred by intellectual property, as House Republicans lay the groundwork for a potential major highway and tax reform deal. Rep. Charles Boustany (R-La.) said his so-called “innovation box” would be a central part of the… – Continue reading
This article deals with the manner in which Canada has complicated, and rendered controversial, what in most other countries is straightforward — the deductibility of business related interest expense. The reasons to write about it are threefold: the almost-concurrent issuance of the Canada Revenue Agency’s administrative views on the matter… – Continue reading
Financial Adviser Jonathan Lachowitz of White Lighthouse Investment Management published the following editorial regarding FATCA on the The Wall Street Journal on Tuesday July 28th: Managing personal financial issues is challenging for most people. For American expats, the normal complexities and expenses are compounded by a panoply of post-financial crisis… – Continue reading
San Jose, California, USA – As a result of the much anticipated initial public offering of transportation game-changer Uber, more and more executives of start-up companies and their investors are interested in tax planning related to their own company’s IPO or buyout. Whenever a well-known start-up company appears that it… – Continue reading
A litigation suit has been filed against the US federal government arguing the Foreign Account Tax Compliance Act (FATCA) is “unconstitutional” and violates privacy rights, reports the Investor Daily. The complaint was officially filed in a federal court in Dayton, Ohio on Tuesday, and names the Treasury Department and Inland… – Continue reading
The IRS released the fourteenth FATCA GIIN list of foreign financial institutions (FFIs) that have registered with the IRS through its FATCA portal. The IRS provides these FFIs a Global Intermediary Identification Number (GIIN). The FFI may then use its unique 19 digit GIIN to complete the IRS tax self… – Continue reading
Over the past few weeks the European Union has published a list of 30 countries which have been listed as non-cooperative jurisdictions. This publication was part of a wider publication: the “Action Plan for Fair and Efficient Corporate Taxation in the EU” which also includes the Re-Launching of the CCCTB…. – Continue reading
Citigroup’s headache over inquires into its Mexican subsidiaries Banamex and Banamex USA’s alleged lax compliance with U.S. federal anti-money-laundering rules just got worse. Last week, the Department of Justice expanded its money-laundering probe of Banamex, Bloomberg reported on Friday. In January, the Department of Justice issued a subpoena to Banamex,… – Continue reading
With different tax laws, exemptions, double taxation treaties and free trade zones for services exports affecting outsourcing operations across Latin America, gaining a solid understanding of the distinct tax obligations in each country is imperative. In a bid to attract investment, several Latin American countries have introduced double taxation treaties,… – Continue reading
A recent decision of the Third Circuit Court of Appeals illustrates the futility of expecting that the Fifth Amendment Privilege Against Self-incrimination will shield taxpayers from production of offshore financial records. The trial court was asked to protect a U.S. taxpayer from enforcement of an IRS Summons for production of… – Continue reading
Recent revelations that Wal-Mart, the world’s biggest corporation, is maintaining secret subsidiaries in well-known offshore tax havens are outrageous but far from surprising to small business owners. That’s because we’re used to seeing large corporations abuse the tax system in ways that hurt our businesses, communities and families. Wal-Mart’s hidden… – Continue reading
