A US-born British citizen has started a crowdfunding campaign to stop HMRC sharing her personal information with the US Internal Revenue Service (IRS) under the US Foreign Account Tax Compliance Act (FATCA). Law firm Mishcon de Reya has taken on the UK case for a client who alleges HMRC is… – Continue reading
The Cabinet of Ministers has approved a bill to ratify the Agreement between the governments of Ukraine and the United States to improve tax compliance and application of provisions of the U.S. Foreign Account Tax Compliance Act (FATCA) and related bills, the Ukrainian Finance Ministry’s press service reported. “On September… – Continue reading
Luxembourg and the US have amended their double taxation convention, updating the exchange of information article to harmonise it with that of the US model income tax treaty and the OECD. US ambassador to Luxembourg Randy Evans and Luxembourg finance minister Pierre Gramegna (DP) on Monday announced the ratification of… – Continue reading
Transfer pricing disputes in Canada have, predominately, been resolved through either a request for competent authority assistance under the Mutual Agreement Procedure ("MAP") of a treaty, or, to a much lesser extent, through the notice of objection process with CRA Appeals. Regardless of the recent increase in transfer pricing cases being brought before the Courts, the MAP will likely continue to be the dispute resolution process most often utilized by a Canadian corporation in transfer pricing cases because, in the absence of a 100% reversal of a transfer pricing adjustment by either CRA Appeals or a Canadian court, economic double taxation may still exist as a consequence of the CRA upward transfer pricing adjustment. The correlative relief provided by the treaty partner under a MAP settlement resolves that double taxation. ... - Continue reading
A bill was introduced to the Mexican Congress on August 21 to tax digital platforms. ... - Continue reading
Barbados’ removal from the European Union’s (EU) blacklist has been welcomed by the Institute of Chartered Accountants of Barbados (ICAB). During her welcome remarks at the 15th Annual ICAB International Business Workshop, at the Barbados Hilton Resort, ICAB’s Executive Director, Kathy-Ann Hewitt, stated: “We are indeed happy that this change… – Continue reading
Canada and Switzerland on August 8 deposited with the OECD their instruments of ratification for the Multilateral Convention to implement tax treaty-related measures to prevent base erosion and profit shifting (BEPS MLI). The BEPS MLI, negotiated by over 100 countries and jurisdictions, updates the existing network of tax treaties and… – Continue reading
Canada and Switzerland have deposited their instruments of ratification for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI), the OECD today announced. ... - Continue reading
Tens of thousands of British citizens born in the US but only lived there for a few months or years face having their bank accounts frozen as part of a crackdown by the US tax authorities. The Internal Revenue Service (IRS) is ordering British banks to hand over the… – Continue reading
In a recent decision, the U.S. Court of Appeals for the D.C. Circuit unanimously affirmed a district court order compelling three Chinese banks (not currently identified) to produce financial records in response to subpoenas issued by U.S. federal prosecutors, including records that were unrelated to the banks' U.S. operations or U.S. correspondent accounts. ... - Continue reading
In 2018, the European Commission (EC) concluded two more investigations into whether the tax ruling practices of Member States breached European Union (EU) State aid rules: the first, a finding of unlawful State aid resulting from tax rulings by Luxembourg in favor of Engie; the second, a rare finding of no aid in respect of the treatment by Luxembourg of McDonald's under the Luxembourg-U.S. double taxation treaty. These decisions are discussed below. ... - Continue reading
French President Emmanuel Macron today confirmed that the US and France have reached a compromise agreement which requires France to refund all digital services tax (DST) paid by multinationals once a new international system for taxing multinationals in the digital sector is in place. ... - Continue reading
Federal tax law has permitted U.S. businesses to form so-called "captive" insurance companies for many years, and numerous large companies have done so. ... - Continue reading
It is estimated that the use of tax havens is costing federal and provincial governments at least $7.8 billion in lost tax revenue. Low and middle income Canadians are the ones paying for that missing $7.8 billion in tax revenue. Ottawa (11 Aug. 2016) — The leak of the Panama… – Continue reading
On July 16, 2019, the US Senate ratified a new protocol that amends the 2013 Double Taxation Treaty signed between the US and Spain. ... - Continue reading
On August 13, Financial Crimes Enforcement Network ("FinCEN") Director Kenneth Blanco addressed the 12thAnnual Las Vegas Anti-Money Laundering Conference and provided insights on his agency's expectations for the ever-evolving gaming industry. ... - Continue reading
19 August 2019, Since 1993, Dominica has been at the forefront of the citizenship by investment (CBI) industry, setting high standards in due diligence, processing times, and most recently, transparency. Indeed, this month the nation liaised with prominent international professional services firm PricewaterhouseCoopers (PwC) to release a report clarifying the… – Continue reading
A US federal appeals court on Friday affirmed the Tax Court’s decision in Amazon, ruling that cost sharing buy-in payments made by Amazon’s Luxembourg subsidiary in exchange for Amazon’s transfer of intangible property should not include compensation for transferred residual business assets such as workforce in place, goodwill, and going concern value. ... - Continue reading
Banks in France have warned that they could be forced to close up to 40,000 accounts belonging to US citizens because of ongoing difficulties with the Foreign Account Tax Compliance Act (FATCA). ... - Continue reading
"Canada has not only the largest in terms of numbers, but also the most elaborate and longest-standing skilled labour migration system in the OECD," the report says. ... - Continue reading
In 2016, Costa Rica’s economy grew at a good 4.2% of GDP, but this year this figure is comparable to Ukrainian tortoise runs (we have 2.7% they have 2.9%). The success recipes of highly developed countries are in many cases not applicable to low-income countries such as Ukraine. Therefore, it… – Continue reading
The US IRS will once again examine allocations between group members of employee stock-based compensation in cost-sharing arrangements for transfer pricing purposes. ... - Continue reading
Bank Secrecy Act/anti-money laundering (BSA/AML) and sanctions matters continue to be a core focus of regulators, law enforcement agencies, policymakers and Congress, and the story of the Obama and Trump Administrations on AML and sanctions is one of general continuity. ... - Continue reading
The US Treasury has announced on its website that the US-Dominican Republic Model 1 FATCA intergovernmental agreement (IGA) entered into force as of July 17, 2019. ... - Continue reading
An OECD-led 131-country coalition, known as the “Inclusive Framework on BEPS,” has approved an assessment which concludes that 12 low or zero-tax countries do not have “harmful” tax regimes, the OECD today announced. ... - Continue reading
The Inter-American Center of Tax Administrations (CIAT), on July 15, released comprehensive and detailed proposals aimed at preventing abusive transfer pricing in low-income countries and in countries on the path to development. ... - Continue reading
Hot topics for discussion at the conference included taxation of the digital economy, approaches for "hard to value intangibles", the adoption of technology within the tax department, and lessons learned from country-by-country reporting. ... - Continue reading
The United States Senate could soon approve ratification of four long-pending double tax avoidance treaty protocols. ... - Continue reading
On July 3, 2019, the Seychelles Government announced that it has signed an intergovernmental agreement (IGA) with the United States to implement the requirements of the US Foreign Account Tax Compliance Act (FATCA). ... - Continue reading
I am interested in purchasing real estate in the US as an investment. Can a Thai citizen own property in the US? There are several things Thai investors need to be aware of when considering purchasing a house or condominium in the United States. The buying process is relatively straightforward… – Continue reading
Taiwan expected to share financial information with Japan and Australia in 2020 TAIPEI (Taiwan News) – Taiwan is expected to exchange financial information with a number of countries in September of next year as part of the Common Reporting Standard (CRS) program designed to combat tax evasion. Developed by the… – Continue reading
Taiwan expected to share financial information with Japan and Australia in 2020 TAIPEI (Taiwan News) – Taiwan is expected to exchange financial information with a number of countries in September of next year as part of the Common Reporting Standard (CRS) program designed to combat tax evasion. Developed by the… – Continue reading
Bill C-82, An Act to implement a multilateral convention to implement tax treaty related measures to prevent base erosion and profit shifting, has received royal assent. ... - Continue reading
On April 25, 2019, the OECD released the 2017 full version of the Model Tax Convention on Income and on Capital ("MTC"). ... - Continue reading
Researchers and campaigners from around the world have been presenting radical solutions on tackling tax abuse and financial crime at the Tax Justice Network’s annual conference held in the heart of London’s finance centre, on 2 – 3 July 2019. With over 200 attendees including prominent politicians, whistleblowers and economists,… – Continue reading
This legislation will force owners of US companies to reveal their identities. ... - Continue reading
The US today announced it is negotiating a competent authority agreement with Monaco that would provide for the exchange of country-by-country reports concerning multinationals operating in their countries. ... - Continue reading
Holtec International told New Jersey regulators that Ohio was competing for its new headquarters. But officials there stripped the firm of past tax awards for failing to create the jobs it promised.n January 2014, as Holtec International explored sites for a new national headquarters and high-tech manufacturing center, the New… – Continue reading
The fate of funds in foreign accounts remain in the balance, however.The imprisoned daughter of Uzbekistan’s late president has reportedly published a statement tentatively admitting responsibility for years of larceny and said that she has paid $1.2 billion into the state coffers. Gulnara Karimova’s statement was posted on an Instagram… – Continue reading
The fight against tax avoidance continues.. ... - Continue reading
In the midst of controversy regarding allegations of tax avoidance at the Sihanoukville Special Economic Zone, the Commerce Ministry recently issued a press release stating that it has found no Chinese companies that are using the SSEZ to avoid tariffs on transshipped goods to the US.According to Reuters on Wednesday… – Continue reading
The European Union has removed the Caribbean island of Dominica from its list of uncooperative jurisdictions in tax matters. Dominica changed its tax rules to comply with EU requirements meant to reduce the risks of tax evasion, the EU said in a statement. Dominica implemented its commitments and addressed EU… – Continue reading
Guidance on the final GILTI regulations ... - Continue reading
Tax rules regarding offshore tax planning amended ... - Continue reading
The head of the economic experts, Christoph Schmidt, has spoken out for tax cuts. “Other countries such as the United States have reduced business taxes. Germany has fallen back in the international tax competition,” said Schmidt of the German press Agency in Berlin. The tax burden had increased in the… – Continue reading
Tax technology giants to be taxed by the Group of 20 nations ... - Continue reading
