Category: North America

Tax-Dodge Scrutiny in U.S. Repels Bidders From Bermuda Takeovers

The IRS’s scrutiny of tax avoidance in offshore locations has discouraged bidders from taking over reinsurers, potentially reducing the companies’ value. Montpelier Re Holdings Ltd. and Platinum Underwriters Holdings Ltd., both based in Bermuda, have each said in recent regulatory filings that potential suitors backed away last year because of… – Continue reading

Offshored jobs returning to mid-size U.S. cities

Verizon consolidated nearly 1,500 finance operations staff from more than 300 U.S. locations into service centers in Lake Mary, Fla., and Tulsa, Okla., indicative of a trend among companies placing business service operations in mid-size U.S. cities rather than offshore locations such as India, according to a new report. The… – Continue reading

DFSA and DIFC Registrar of Companies co-host FATCA Outreach Workshop

The Dubai Financial Services Authority (DFSA) and the Dubai International Financial Centre (DIFC), Registrar of Companies (RoC), jointly hosted an outreach workshop last week regarding the Foreign Account Tax Compliance Act (FATCA). FATCA is extra-territorial US legislation that affects Financial Institutions (FIs), particularly those which have accountholders who are US… – Continue reading

New Challenge to Tax Planning: Morality and Politics Are Now In Play

In 1934, a distinguished American jurist, Judge Learned Hand, famously opined that “one may so arrange his affairs so that his taxes shall be as low as possible; he is not bound to choose that pattern which will best pay the Treasury; there is not even a patriotic duty to… – Continue reading

Chairman Royce, Rep. Pallone welcome US-Amenia Trade & Investment Framework Agreement

The advantages of off-shore investments Two of the top reasons that South African investors are given to encourage offshore investments are that going offshore diversifies your portfolio and that it gives you access to sectors you could never find on the resource-heavy JSE. “While those are not reasons to be… – Continue reading

Indian move to check illegal capital outflows

THE BJP-led National Democratic Alliance government, which had made a lot of noise about black money and the illegal stashing of funds abroad in the run-up to general elections last year, finally got down to some serious work to tax ill-gotten wealth and curb its growth. Last week, the government… – Continue reading

OECD says countries won’t be able to game tax system

Short cuts, loopholes and other forms of skulduggery will not be tolerated when the automatic exchange of tax information comes into force, a top official from the Organisation for Economic Co-operation and Development (OECD) has promised Swiss bankers, reports FinFacts. Grace Perez-Navarro, second in command at the OECD’s tax policy… – Continue reading

UK: Non-UK Domiciliaries: Inheritance Tax Issues And Opportunities

This note is intended as an introduction to inheritance tax (IHT) issues that need to be covered where a “non-dom” (an individual domiciled outside the UK) is planning on becoming resident in, or is already resident in, the UK. It should be emphasised that this is a complex subject, and… – Continue reading

PANAMA UPDATE: New Regime on Bearer Shares Effective in 2015

Executive Summary: The Panamanian government has engaged in an extensive period of consultations with local and foreign experts, practitioners, professionals and regulators, in a concerted effort to ensure that the jurisdiction continues to embody the highest international standards in terms of functionality and transparency (while preserving confidentiality). To that effect,… – Continue reading

I-T targets 50 APAs with MNCs in FY16

The I-T dept has received over 500 applications from MNCs for signing APAs. Income-tax department has set a target of 50 advance pricing agreements (APAs) to be sealed with multinational companies in the current fiscal that will exempt cross-border transactions by these firms from rigorous auditing to check income suppression…. – Continue reading

Canada Needs to Act on Its Promise to Tackle Tax Havens

Luxembourg has been a prime destination for Canadians looking for a tax haven. Secretive. Discreet. Accommodating. These features were so attractive that Canadian companies, including a federal pension fund, sent $36 billion there in 2013. But new Statistics Canada data shows that more than $5 billion got pulled out of… – Continue reading

Can Another State Tax Your Trust?

Smartly setting up trusts requires knowledge of state tax laws, not just federal rules. Consider Robert L. McNeil, a chemist and onetime Pennsylvania resident who amassed a fortune as the business brain behind Tylenol. McNeil established trusts for his family but chose to locate them in Delaware, for tax purposes…. – Continue reading

FATCA – implications for financial institutions

Introduction to FATCA On December 16 2013 Malta and the United States entered into an intergovernmental agreement (IGA) to implement rules and regulations under the Foreign Account Tax Compliance Act (FATCA). FATCA, enacted in 2010 by the United States, requires US taxpayers and financial institutions to report financial information to… – Continue reading

You’d be stupid not to try to cut your tax bill, says Bono: U2 frontman branded ‘hypocritical’ in light of his ‘anti-austerity posturing’

Singer revealed he bases some business ventures in the Netherlands Tax rates in the European country far lower than in his native Ireland Bono said ‘smart people’ were ‘just be sensible’ about ‘the way we’re taxed’ Sunday Times Rich List ranked U2 as the country’s third richest musicians He has… – Continue reading

Unnerved by tax demands on capital gains, foreign funds flee for safety

The minimum alternate tax row has damaged the credibility of government promises to enforce an investor-friendly tax regime and made the Indian stock market Asia’s worst performer this year New Delhi/Mumbai: Castleton Investment Ltd, a unit of GlaxoSmithKline Plc (GSK), in 2012 asked an arm of the Indian finance ministry… – Continue reading

Chairman Royce, Rep. Pallone welcome US-Amenia Trade & Investment Framework Agreement

House Foreign Affairs Committee Chairman Ed Royce (R-CA) and Congressional Armenian Caucus Co-Chair Frank Pallone (D-NJ) were among the first Congressional leaders to welcome the May 7th signing of the U.S.-Armenia Trade and Investment Framework Agreement (TIFA), a longstanding policy priority for the Armenian National Committee of America (ANCA). Chairman… – Continue reading

Bank of Singapore Knows Family Matters

House Foreign Affairs Committee Chairman Ed Royce (R-CA) and Congressional Armenian Caucus Co-Chair Frank Pallone (D-NJ) were among the first Congressional leaders to welcome the May 7th signing of the U.S.-Armenia Trade and Investment Framework Agreement (TIFA), a longstanding policy priority for the Armenian National Committee of America (ANCA). Chairman… – Continue reading

IMF urges Luxembourg to diversify tax base

The International Monetary Fund has urged authorities in Luxembourg to consider diversifying the nation’s revenue sources in light of international tax changes that could negatively impact the country’s economy, reports Tax News. The Fund said in a statement that it welcomed Luxembourg’s continued participation in EU and OECD/G20 tax transparency… – Continue reading

Sean Foley,Global Leader, KPMG, says ‘India’s Transfer Pricing Rules Aggressive’

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

Bahamas Releases Proposed FATCA Legislation & Guidance Notes For Industry Consultation

The Bahamas Ministry of Financial Services released draft copies of the FATCA Legislation and the FATCA Guidance Notes to meet the International Tax Compliance Requirements of the Model 1 FATCA Intergovernmental Agreement (IGA) between the Bahamas and the United States of America (US). The new FATCA Bill was drafted in… – Continue reading

FATCA, Tax Havens, American Competitiveness And Hypocritical Politicians

While the Bureaucrat Hall of Fame and Moocher Hall of Fame already exist, the Hypocrite Hall of Fame is just a concept. But once it gets set up, Congressman Alan Grayson of Florida will definitely be a charter member. Here are some passages from a column in the Tampa Bay… – Continue reading

OECD condemns Silicon Valley for “extremely aggressive” tax planning

Head of forum’s tax policy will push for reform to cut down on avoidance. The OECD has attacked the “extremely aggressive” tax planning of companies such as Google, Amazon and Apple as it pushes for reform of global tax rules to cut down on avoidance. Pascal Saint-Amans, who heads up… – Continue reading

OECD insists tax playing field will be level

Short cuts, loopholes and other forms of skulduggery will not be tolerated when the automatic exchange of tax information comes into force, a top official from the Organisation for Economic Co-operation and Development (OECD) has promised Swiss bankers, reports Swiss Info. Grace Perez-Navarro, second in command at the OECD’s tax… – Continue reading

HMRC guidance on FATCA tax rules updated

HMRC has updated the reporting requirements under the US Foreign Account Tax Compliance Act (FATCA), which may mean that some organisations or taxpayers no longer need to submit a return by the 31 May deadline HMRC points out that two recent updates have changed the reporting criteria. Firstly, UK financial… – Continue reading

Financial Function Slowly Returns to the U.S.

After a decade of “offshoring,” financial executives are making the decision to bring some work home. Cities like Hyderabad and Bangalore being replaced with more familiar names like Syracuse and Jacksonville as more companies bring finance jobs back to the states after a decade of “offshoring.” Mid-size U.S. cities are… – Continue reading

Hong Kong: The Impact Of BEPS On Your Relationship With Customs Authorities

If you are moving or trading goods across borders, this topic should be of primary importance from both a Transfer Pricing and Customs perspective. There is potential for you to have Transfer Pricing and Customs exposures in your supply and value chains as a result of the OECD/G20 initiative on… – Continue reading

Fed Bars Indicted Former Credit Suisse Bankers From Industry

The Federal Reserve barred Markus Walder, the former head of North America offshore banking at Credit Suisse Group AG, and four other previously indicted ex-bankers at the company from employment in the banking industry. The five were indicted for conspiracy to defraud the U.S government by assisting U.S. citizens’ evasion… – Continue reading