Category: USA

Carl Icahn Forms Super PAC Aimed At Tax Reform

Carl Icahn, the iconic activist investor, has shifted, if only for today, his cross-hairs of contempt from the boardrooms of corporate America to the nation’s capital. Icahn sends members of Congress a word of warning Wednesday saw Carl Icahn warn several members of Congress a letter laying out his plans… – Continue reading

CLINTON LIBRARY FUNDED BY OFFSHORE TAX HAVEN

Hillary Clinton is repeating the Democrat trope about “offshore tax havens” that immorally divert profits from workers and the taxman. Closing these is a central plank of her promised agenda as President, she explains in an op-ed laying out her economic agenda. Setting aside the economic merits of her plan,… – Continue reading

25% of Companies Expected to Miss BEPS Deadline, Survey Finds

A recent Thomson Reuters survey report reveals that European companies are outpacing all others in developing their Base Erosion and Profit Shifting (BEPS) action plans by Dec. 31, 2017 – the deadline set by the Organization for Economic Cooperation and Development (OECD). But most respondents voiced several concerns about BEPS… – Continue reading

The Self-Defeating Corporate Income Tax

For many years, policy makers have criticized the strategies that American corporations use to reduce their taxes by shifting income and capital offshore. The impetus behind these strategies is the U.S. corporate income-tax rate — at 35 percent, the highest of any industrialized nation, easily surpassing countries such as the… – Continue reading

HOUSING A TAX DODGE IN RICHMOND AND VANCOUVER

Some might be surprised to learn that certain areas of Richmond and Vancouver, despite being thoroughly decorated with mcmansions, monster homes, and incessantly rising land prices, are actually inhabited by low income residents that make up a surprising per cent of the population. Conservative Party leader Stephen Harper, during a… – Continue reading

London Wants to Become the Center of Chinese Currency Trading

Three years ago, Chinese officials said U.K. Prime Minister David Cameron had “seriously damaged” relations by meeting with the Dalai Lama, the exiled Tibetan leader. As planned talks between the two countries were canceled or failed to take place, worries emerged that Britain would miss out on building deeper economic… – Continue reading

United States: Tax Policy Update – October 13, 2015

NUMBER OF THE WEEK: 0 The number of House Republicans who want to be speaker and can actually secure the necessary 218 votes as of today. After Majority Leader Kevin McCarthy’s dramatic exit from the race last week, the House GOP conference is taking the week-long Columbus Day recess to… – Continue reading

Execs Weigh Impact of OECD BEPS Impact on U.S. Tax Reform

The impact of the Organization for Economic Cooperation and Development’s Base Erosion and Profit Shifting action plan is still unclear, but tax executives are planning ahead for changes on the international tax front. Earlier this month, the OECD unveiled its plan for combating tax evasion strategies by multinational corporations (see… – Continue reading

Surge in outbound payments hint at expats’ bid to escape American tax authorities

MUMBAI: There is a sudden, inexplicable surge in money that Indians are sending abroad for ” maintenance of close relatives“. Such fund transfers typically add up to $10-20 million a month. But in July 2015, according to the latest available data, total remittance under this head crossed $124 million. Also,… – Continue reading

The President signed a law allowing the implementation of FATCA

President Andrzej Duda signed last Friday a bill whose aim is to implement FATCA legislation – said the office of President. The law is designed to prevent US taxpayers hiding income abroad. The Act creates a legal basis that will allow implementation of the provisions under the international agreement ws…. – Continue reading

Financial Information Month – FATCA

The local implications for the Foreign Accounts Tax Compliance Act (FATCA) are far reaching. So said First Caribbean International Bank (FCIB) representative Norlan Gabriel, who was a panel member on NBC Radio’s “Views on Issues” programme last Sunday. The latest edition of the radio programme was aimed at disseminating information… – Continue reading

Guernsey: Guernsey Is On Track For The Next Stage In Automatic Exchange Of Information

KEY POINTS What is the issue? Guernsey will be required to gather data for the calendar year 2016 for reporting under the Common Reporting Standard (CRS) in 2017. What does it mean for me? Practitioners should be aware that due diligence and reporting procedures are set to be amended and… – Continue reading

IRS Offshore Account Penalties Go Up, More Banks Sign U.S. Disclosure Deal

The number of banks with deferred prosecution agreements with the U.S. government keeps growing. The subject is tax evasion involving American account holders. Today, under FATCA, banks everywhere want to know if you are compliant with the IRS. And the IRS keeps updating its list of foreign banks where offshore… – Continue reading

Internal Revenue Service Issues Stern Warning To Non-Compliant Taxpayers With Offshore Holdings

Just one day after the October 15 deadline for filing personal income tax returns on extension, the Internal Revenue Service issued a strongly-worded warning to non-compliant taxpayers: take action now to fix your problem, or face serious consequences. At the same time, the IRS revealed, for the first time, that… – Continue reading

EY: Four out of 10 Czech businessmen asked for bribe; Czech police reveal corruption in driving licenses for Germans; No. of Czech firms with owners in tax havens up in Q3

EY: Four out of 10 Czech businessmen asked for bribe Four out of 10 Czech entrepreneurs have been explicitly asked for a bribe and up to six out of 10 have encountered the possibility of gaining an advantage in their business in exchange for a bribe, according to a survey… – Continue reading

Caribbean likely to suffer collateral damage from tax havens crackdown

A little over a week ago the British parliamentarian, Sir Eric Pickles – a cabinet member until May of this year and a former Chairman of the Conservative Party – told the London Guardian that the British Prime Minister, David Cameron, was determined to have the BVI and the Cayman… – Continue reading

IRS Offshore Voluntary Disclosure Program Results in $8 Billion in Collections

With more than 54,000 taxpayers coming in to participate in offshore disclosure programs since 2009, the Internal Revenue Service is reminding U.S. taxpayers with undisclosed offshore accounts that they should strongly consider existing paths established to come into full compliance with their federal tax obligations. Both the Offshore Voluntary Disclosure… – Continue reading

Putin Allies Said to Be Behind Scrutinized Deutsche Bank Trades

Several close associates of Russian President Vladimir Putin may have benefited from Deutsche Bank AG trades that are now coming under the glare of U.S. prosecutors, according to people familiar with the matter. The U.S. Department of Justice is investigating whether Germany’s biggest bank properly vetted as much as $6… – Continue reading

Black banks’ targeted in latest anti-graft crackdown

The central government is stepping up its anti-graft drive by cracking down on illegal lending and money-laundering operations in a bid to prevent outbound flows of stolen assets. The Ministry of Public Security says “black banks” and illegal currency exchanges have facilitated the flights of a number of former government… – Continue reading

Rules on tax-dodging multinationals must be thoroughly implemented

The following editorial appears in Friday’s Yomiuri Shimbun: International cooperation must be bolstered to close tax loopholes that can be exploited by multinational business corporations. The Group of 20 major economies and the Organization for Economic Cooperation and Development have worked out new international taxation rules to clamp down on… – Continue reading

US Justice Department Announces BBVA Suiza S.A. Reaches Resolution Under Swiss Bank Program – Bank Will Pay Penalty Of More Than $10 Million And Continue To Cooperate With Department

The Department of Justice announced today that BBVA Suiza S.A. has reached a resolution under the department’s Swiss Bank Program. “Swiss banks such as BBVA Suiza S.A. are providing detailed information regarding their efforts to conceal U.S.-related accounts, and are turning over the names of individuals and entities that facilitated… – Continue reading

Orica fights $50 million tax bill over ’round-robin’ financing

Orica has again found itself at odds with the Australian Taxation Office, this time over the circular financing arrangements the explosive maker put in place in 2002 to improve profits for the then struggling group. Orica has disputed the amended tax assessment from the ATO in relation to its “round-robin”… – Continue reading

Could Medtronic Move R&D To Ireland For Tax Purposes?

With Medtronic being one of Ireland’s largest employers, analysts say there is a new incentive for the medical device maker to prioritize its Dublin headquarters for R&D. In the eyes of developed nations, Ireland has become notorious for baiting multinational firms to its land with the offer of friendly tax… – Continue reading

IRS updates guidance on US-Canada DTA

The Internal Revenue Service (IRS) has released a revised October 2015 version of its Publication 597, which provides information on the United States-Canada double taxation agreement (DTA), reports Tax News. A number of DTA provisions that most often apply to US citizens or residents who may be liable for Canadian… – Continue reading

Federal Court of Canada dismisses challenge to CRA’s automated data collection and disclosure regime under FATCA

In a summary judgment released on September 16, 2015, the Federal Court of Canada examined and disposed of the non-constitutional arguments in the Hillis and Deegancase[1] generally finding that the automatic data collection and disclosure of taxpayer information to the United States by Canada pursuant to the Canada-U.S. Intergovernmental Agreement… – Continue reading

Matthew Freud: ‘I paid 684 times more tax than Facebook’

PR chief, who pocketed more than £11m from his agency last year, attacks tax system for foreign-owned companies Matthew Freud has attacked the pittance Facebook pays in UK tax after footing a bill for almost £3m last year, as he pocketed more than £11m from his PR and marketing agency… – Continue reading

Is a Canada Revenue Agency landlord avoiding taxes via offshore havens?

The Canada Revenue Agency (CRA) rents office space from a Vancouver-based property developer – a company that exploits offshore tax havens in Liechtenstein, the British Virgin Islands and Channel Islands. Larco Investments Ltd. owns three buildings in Montreal, Calgary and Edmonton where they rent office space to the CRA. Larco… – Continue reading

Rare Praise For IRS For FATCA Work

The Treasury Inspector General for Tax Administration has generally praised the US Internal Revenue Service for its implementation of the Foreign Account Tax Compliance Act. To improve US taxpayer compliance in reporting foreign financial assets and offshore accounts, Congress passed FATCA in March 2010. FATCA is intended to ensure that… – Continue reading

The World is About to Become More Financially Transparent, Whether or Not the U.S. Participates

In just over two months, thousands of U.S.-based financial institutions will face new requirements for sharing financial information. These businesses should get ahead of the deadline and start preparing for the impact these rules will have on their operations and bottom lines. The Organisation for Economic Co-operation and Development’s new… – Continue reading

New Report Sounds Alarm on US Corporate Tax Rate

Do your individual clients howl about paying too much federal income tax? Just wait until you get an earful from your business clients. Advertisement A new report from the Tax Foundation, a conservative-leaning think tank located in our nation’s capital, found that the United States has the third-highest marginal corporate… – Continue reading

Mylan CEO Heather Bresch: We needed tax inversion in order to grow

The chief of the generic drug company discussed her “counterintuitive” strategy for creating U.S. jobs. Mylan is one of a handful of U.S. companies that has recently completed a controversial tax inversion, as the generic drug company moved its official base to the Netherlands earlier this year. While the decision… – Continue reading

Guernsey Association of Compliance Officers keeps Guernsey out in front

The Guernsey Association of Compliance Officers (GACO) October seminar covered the introduction of the Information Gateway Online Reporter (IGOR), an online portal for the purpose of collecting and exchanging Automatic Exchange of Information. https://igorforum.digimap.gg GACO chairman and Carey Olsen partner Mark Dunster said it is a key objective for the… – Continue reading

The Algeria and the United States sign an agreement on sharing tax information

The Algeria and the United States signed Tuesday in Algiers an intergovernmental agreement on the sharing of tax information between the two countries and to promote financial transparency and the strengthening of bilateral and international fight against tax evasion. The agreement, first of its kind concluded by the US with… – Continue reading

FACTA and the New Frontier in Offshore Reporting Enforcement

FATCA was passed to prevent U.S. citizens from evading tax by focusing primarily on foreign financial institutions with U.S. account holders. The Foreign Account Tax Compliance Act (FATCA) was enacted as part of the 2010 Hiring Incentives to Restore Employment Act, and its provisions became effective as of 7/1/14. FATCA… – Continue reading

Conference Focuses on Intersection of Tax Law and Citizenship

Tax experts from the United States, United Kingdom, Canada, Brazil and Israel spoke at a two-day conference at Michigan Law about the challenges of the Foreign Account Tax Compliance Act (FATCA) and a multitude of other issues at the intersection of the law of taxation and citizenship. Panel discussions at… – Continue reading

Newly signed CAAs facilitate FATCA data exchange between U.S.-U.K & Australia

To facilitate the exchange of Foreign Account Tax Compliance Act (FATCA) data under the intergovernmental agreements (IGAs) with Australia and the U.K., the U.S. Competent Authority has signed Competent Authority Arrangements (CAAs) with the Competent Authority of each country, announced IRS officials on September 24. The CAAs are the first… – Continue reading

ANCA Welcomes Congressman Ted Lieu’s Advocacy for a U.S.-Armenia Double Tax Treaty

LOS ANGELES—The Armenian National Committee of America – Western Region (ANCA-WR) is expressing its appreciation to Congressman Ted Lieu for authoring a letter to U.S. Treasury Secretary Jacob Lew in support of a U.S.-Armenia Double Tax Treaty. The accord, if concluded, would, by limiting the prospect of double taxation, remove… – Continue reading

Warn employers about FATCA law

Thanks to an agreement between the Department of Revenue’s Tax Administration Service (SAT) from September 30, all information regarding Mexicans with bank accounts in the United States and American citizens with bank accounts in Mexico agreement is being mutually sent. During the monthly breakfast Coparmex, the tax lawyer Jorge Alberto… – Continue reading

CBDT inks 4 more advance pricing pacts

MUMBAI: The Central Board of Direct Taxes (CBDT) on October 13 signed four unilateral advance pricing agreements (APAs), including India’s second APA with a rollback provision. The nature of the transactions covered under these agreements varied from software development to share price valuation. According to government sources, the total number… – Continue reading

A Pakistani, who has failed in Pakistan, combating tax evasion abroad

ISLAMABAD: Talent is universal, opportunities are not. A Pakistani is combating tax fraud in America and Russia using the same technology he earlier employed in Pakistan discovering 3.5 million out-of-tax-net rich individuals. Unlike the appreciation of his efforts abroad, the data he compiled in Pakistan has been thrown into the… – Continue reading

Ireland plans 6.25 per cent patent-box tax as `Double Irish’ ends

Ireland will introduce a new lower tax on intellectual property to keep and win more overseas investment as the government phases out a controversial loophole known as the “Double Irish.”, reports Bloomberg. The new knowledge development box will tax profits from patented innovations such as technological and pharmaceutical developments at… – Continue reading

The U.S. Companies With The Most Offshore Cash

The use of tax havens is ubiquitous across America’s 500 largest companies. Collectively, they hold $2.1 trillion in offshore cash, according to a recent study by Citizens for Tax Justice and the U.S. PIRG Education Fund. Establishing foreign subsidiaries in places with little or no tax such as Bermuda or… – Continue reading

Putting the Final BEPS Reports into Perspective: from Recommendations to Implementation

The Organization of Economic Cooperation and Development (OECD) released its final reports on the G20/OECD Base Erosion and Profit Shifting (BEPS) Project on Monday October 5th, 2015. The final package of BEPS measures includes new minimum standards on: country-by-country reporting, which for the first time will give tax administrations a… – Continue reading