Jan. 6 — Some dual-resident taxpayers don’t have to report specified foreign financial assets on Form 8938 for 2015, the IRS said. These taxpayers won’t have to do the reporting as long as they determine their income tax liability—for all or part of the taxable year—as if they were nonresident… – Continue reading
Mutual Fund houses will have to mandatorily provide compliance details for the new global tax avoidance law FATCA with regard to each client on the stock exchange’s mutual fund trading platform. In a circular, BSE said for each and every transaction mutual fund houses have been asked “to upload FATCA… – Continue reading
Viacom Inc. was accused by one of its former executives of plotting to hide revenue from “Teenage Mutant Ninja Turtles” in a Netherlands entity to avoid taxes. The ex-vice president for financial planning at Viacom claims she was fired after opposing what she believed was an illegal tax dodge. Nataki… – Continue reading
The Department of Justice announced today that Union Bancaire Privée, UBP SA (UBP), reached a resolution under the department’s Swiss Bank Program. UBP will pay a penalty of more than $187 million. “Today’s agreement marks the final resolution with UBP, which acknowledges its role in conspiring with U.S. taxpayers to… – Continue reading
Now that the final report on BEPS Action 7 has been released, “Preventing the Artificial Avoidance of Permanent Establishment Status” (Final Report), taxpayers are able to consider the final language to be incorporated into Article 5(5) of the OECD Model Tax Convention.1 This language also will be incorporated into the… – Continue reading
On December 18, 2015, the President signed the Omnibus Appropriations Act (the “Act”) into law.1 Notably, the Act contains a number of substantive changes to the tax laws applicable to “real estate investment trusts” (“REITs”). Although several changes will adversely affect certain REITs, on balance REITs and their investors fared… – Continue reading
UBP is the latest bank to reach a resolution under the Swiss Bank Program, launched in 2013, that allows Swiss banks to resolve potential criminal liabilities in the United States. UBP between 2008 and 2013 helped U.S. clients to open and maintain undeclared accounts in Switzerland and conceal assets and… – Continue reading
The investigation and prosecution of tax evasion has, in the last decade, grown from a specialized subcategory of law enforcement into a first-tier policy concern for the global community. Starting with the U.S. government’s crackdown on Swiss bank UBS in 2008, there has been a steady drumbeat of news about… – Continue reading
A Viacom whistleblower claims she was sacked by the media company for opposing its alleged plan to illegally avoid paying U.S. taxes on the international licensing rights to Teenage Mutant Ninja Turtles. In a complaint filed in Manhattan federal court on Tuesday, former vice president Nataki Williams said she was… – Continue reading
The Treasury Department and the Internal Revenue Service have proposed regulations setting out a new requirement for certain U.S. persons that are the ultimate parent of a multinational group (a “U.S. MNE group”) having annual revenue of at least $850 million to file an annual report (the “CbC report”). The… – Continue reading
Billionaire JP McManus is refusing to back down in a row with the US government over a tax bill of $5.2m (€4.8m). The racehorse owner has renewed efforts to secure a tax refund for the sum, court papers seen by the Irish Independent reveal. The disputed cash was part of… – Continue reading
(Reuters) – Texas tycoon Sam Wyly is set to face off against the Internal Revenue Service at trial on Wednesday over more than $2 billion the agency says he owes for using offshore trusts to engage in one of the largest tax frauds in U.S. history. The trial in federal… – Continue reading
(Special) – Winter brings with it the dream of many Canadian snowbirds of owning a piece of property in the sunny south. With the recent rebound in the U.S. housing market and a decline in the value of the Canadian dollar, however, buying vacation property south of the border may… – Continue reading
On Friday, December 18, 2015, President Barack Obama signed the “Protecting Americans from Tax Hikes Act of 2015” (“PATH Act”). Our December 10, 2015 client alert discussed significant proposed changes to the rules governing real estate investment trusts (“REITs”) and the Foreign Investment in Real Property Tax Act of 1980… – Continue reading
The US Department of Justice (DoJ) has announced that it has now completed agreements with 75 financial institutions, and imposed penalties in excess of US$1bn, under its Swiss Bank Program, reports Tax News. The DoJ’s Swiss Bank Program was signed by the US and Switzerland on August 29, 2013. It… – Continue reading
Lately, the IRS is warning offshore account holders to disclose before it’s too late. Under FATCA, banks everywhere want to know if you are compliant with the IRS. And the cost of compliance for many people is growing. The IRS updated its list of foreign banks where accounts trigger a… – Continue reading
Bahrain, Sudan also sever diplomatic ties with Iran; two mosques attacked in Iraq UNITED NATIONS/ WASHINGTON: The world community on Monday urged Saudi Arabia and Iran to observe restraint after tension over the execution of a prominent cleric Nimr Al-Nimr along with 46 others by the Saudi government. The UN… – Continue reading
Shortly before New Year’s, on Wednesday, December 30, 2015, the media reported that Julius Baer Group AG (“JB”) expected to pay about $547 million to settle the U.S. investigation into how the bank (and its bankers) assisted U.S. taxpayers in evading tax. This investigation began more than 4 years ago,… – Continue reading
Although the British Virgin Islands is often seen as an offshore tax haven, a closer look shows such opinions may be overstated There is a stereotypical image of the so-called ‘tax haven’ for ‘shady people to put their money’. While it is true that BVI Finance enjoys warm, sunny weather… – Continue reading
Increasing regulation has made transfer pricing complex for multinational enterprises. Technology can help simplify the process In recent years there has been an increasing focus on transfer pricing, in line with the proliferation of transfer pricing requirements from a growing number of countries around the world, and the OECD’s project… – Continue reading
As will be recalled from the previous blog posting that discussed so-called “Controlled Foreign Corporations” (CFC), a United States shareholder of a CFC can possibly be treated as having received “dividend” income at various times. These are when the US shareholder (i) has current income inclusions from the CFC under… – Continue reading
Two more top banks getting away with paying NO corporation tax in the UK: Credit Suisse and Citigroup are latest to admit using previous losses to slash their bills Seven foreign investment banks in London now pay no corporation tax Fines and lawsuits used to slash their tax bills by… – Continue reading
International art dealer Guy Wildenstein is going on trial in Paris on charges of defrauding the French state of half a billion euros (about $550 million) in taxes, after two relatives tipped off authorities about the family’s financial dealings. Wildenstein, 70, Franco-American heir of a New York art-dealing empire, is… – Continue reading
United States Vice President Joe Biden has never been one to hold his tongue. He certainly didn’t in his recent trip to Kiev. In a speech before Ukraine’s Parliament, Biden told legislators that corruption was eating Ukraine “like a cancer,” and warned Ukrainian President Petro Poroshenko that Ukraine had “one… – Continue reading
SEATTLE — When someone in Seattle buys a copy of Office at a Microsoft Store, that cash doesn’t take the short route to the company’s area headquarters. Instead, after accounting for state taxes, the profit goes to a Microsoft sales subsidiary in Nevada. From there, much of that money begins… – Continue reading
THE COUNCIL OF THE DISTRICT OF COLUMBIA (DC) recently enacted, as part of its budget, provisions that force entities doing business in any of 39 arbitrarily designated “tax havens” to report their income on worldwide combined reporting. Eighteen are Caribbean jurisdictions. A tax haven is defined by the DC code… – Continue reading
An Inter-Governmental Agreement between India and USA was signed for implementation of Foreign Account Tax Compliance Act (FATCA). The Government of India has also joined the Multilateral Competent Authority Agreement (MCAA) for Automatic Exchange of Information as per Common Reporting Standard (CRS). For implementation of FATCA and CRS, necessary legislative… – Continue reading
Although President Barack Obama likes to snarl about the unfairness of income inequality, under his administration, the 400 top earning American families now pay about one-third less of their income in taxes than under President Ronald Reagan. The IRS each year tabulates the effective tax rates paid by 400 individual… – Continue reading
Bermuda has “long been a popular tax haven” according to a story by gobankingrates.com, which ranked the island as one of the “top 10 best tax havens in the world.” The story said “Bermuda has long been a popular tax haven, said Ravi Ramnarain, an independent certified public accountant. “Wealthy… – Continue reading
The Minister of Finance has announced a decision on international information exchange based on the FATCA agreement. This decision contains a publication of the concluded in November 2015 between the competent authorities of the Netherlands and the US administrative arrangements for the practical application of the FATCA agreement EN-US 2013… – Continue reading
An Inter-Governmental Agreement between India and USA was signed for implementation of Foreign Account Tax Compliance Act (FATCA). The Government of India has also joined the Multilateral Competent Authority Agreement (MCAA) for Automatic Exchange of Information as per Common Reporting Standard (CRS). For implementation of FATCA and CRS, necessary legislative… – Continue reading
Two Swiss banks will pay a total of more than $107 million to the U.S. Department of Justice to avoid possible prosecution for helping Americans evade taxes, the department said on Thursday. Bank Lombard Odier & Co. Ltd, a Geneva-based unit of Lombard Odier Group, will pay $99.8 million in… – Continue reading
One of the leading Swiss banks Julius Baer Group AG is set to reach a deal with US authorities over a tax probe by paying $547 million early next year. Julius Baer, Switzerland’s third-largest wealth manager after UBS and Credit Suisse has been under criminal investigation since 2011 by the… – Continue reading
On December 30, 2015 on the website of the Dutch Staatscourant the text of the Competent Authority Arrangement between the Competent Authorities of the United States of America and the Kingdom of theNetherlands was published. The Competent Authority Arrangement between the Competent Authorities of theUnited States of America and the… – Continue reading
Multinational companies have enjoyed a sustained period of falling corporate tax rates around the world. However, with the conclusion of the OECD’s base erosion and profit shifting project earlier this year marking the start of fundamental changes to the international tax system, and with governments more determined than ever to… – Continue reading
KUWAIT CITY, Dec 26: The US passports of some 6,000 Kuwaitis, among other 250,000 GCC citizens are vulnerable to sanctions by early next year unless they pay their taxes next month, according to the Foreign Account Taxes Compliance Act (FATCA), reports Al- Shahed daily. As of the beginning of January… – Continue reading
Tax cheats are facing a series of year-end deadlines to come clean, as an international dragnet affecting both wealthy Canadians with offshore accounts and Americans in Canada who have failed to file U.S. tax returns keeps tightening. Lawyers say some Canadians with Swiss bank accounts have received letters demanding written… – Continue reading
MUMBAI: Many manufacturing and trading subsidiaries of Indian companies that are currently operating independently outside India may have to pay taxes in India as they could fail the new test set under the Place of Effective Management (POEM) guidelines. Not just that, some of the companies could see complications with… – Continue reading
At the House of the approval bill filed from between the Kingdom of the Netherlands, on behalf of Curaçao, and the United States of America Convention concluded improve international tax compliance and implementing FATCA (hereinafter Cur IGA). The Convention is published in Trb. 2015, 11 and 144. The approval is… – Continue reading
“Cash Booked Offshore for Tax Purposes by U.S. Multinationals Doubled between 2008 and 2014” In recent years, U.S. multinational companies have sharply increased the amount of money that they book to foreign subsidiaries. An April 2015 study by research firm Audit Analytics found that the Russell 1000 list of U.S…. – Continue reading
Penalties range from imprisonment to revoking nationally; anyone with a minimum of $10,000 in their bank accounts is subject to the law The US Internal Revenue Service (IRS) will start tracking Americans evading compliance with the Foreign Account Tax Compliance Act (FATCA) as of January 2016, according to Deputy Chairman… – Continue reading
Penalties range from imprisonment to revoking nationally; anyone with a minimum of $10,000 in their bank accounts is subject to the law The US Internal Revenue Service (IRS) will start tracking Americans evading compliance with the Foreign Account Tax Compliance Act (FATCA) as of January 2016, according to Deputy Chairman… – Continue reading
Effective Jan. 1, 2016, the IRS will compile a list of Americans in violation of new rule It is possible that the United States expats could have their passports revoked next month if they fail to comply with their tax and financial obligations under the Foreign Account Tax Compliance Act… – Continue reading
Pakistan and the US have decided to share intelligence on income tax and bank accounts of Pakistani citizens that have dual nationality. The two countries will agree on one of three options laid down in Foreign Accounts Tax Compliance Act (FATCA) approved by US Congress and sign the proposed US-Pak… – Continue reading
(MENAFN – AFP) US officials announced settlements with four more Swiss banks Wednesday to lift the total fines in the two-year disclosure program to more than 1 billion from 75 banks. “With today’s resolutions under the Swiss Bank Program, the department has reached agreements with 75 Swiss banks, imposed penalties… – Continue reading
Legislation introduced on Tuesday by U.S. Rep. Charles Boustany (R-LA) would safeguard companies in country-by-country reporting requirements. The Bad Exchange Prevention Act follows the issuance by the Treasury Department on Monday of guidelines for adhering to the country-by-country reporting requirements under the Organization for Economic Cooperation and Development’s (OECD) Base… – Continue reading
New Delhi: A government crackdown on black money has led to detection of undisclosed income of over Rs 16,000 crore since March 2014, while assets worth Rs 1,200 crore have been seized, Revenue Secretary Hasmukh Adhia said today. “In 2014-15 and 2015-16 (up to November), the Income Tax Department by… – Continue reading
KUWAIT CITY, Dec 22: Jim O’Neill, Vice-President of the American Bureau of Consulting and Audit who is also in charge of international activity was recently quoted as saying the passports of those who have obtained the American citizenship and reside outside the United States might be withdrawn if they fail… – Continue reading
On September 17, 2015, the IRS issued a statutory notice of deficiency to the Coca-Cola Company, increasing its federal income taxes for 2007-2009 by $3.3 billion, based primarily on transfer pricing adjustments exceeding $9 billion. On December 14, 2015, Coca-Cola petitioned the U.S. Tax Court to overturn the adjustments. This… – Continue reading
The Internal Revenue Service (IRS) has released the 2015 update to Publication 54, which provides guidance on the special tax compliance rules for US citizens and resident aliens who work abroad or receive income from foreign countries. The worldwide income of US citizens or resident aliens is generally subject to… – Continue reading
