ESPN FC’s Fernando Palomo previews the upcoming UCL action, highlighting that Barcelona will have to learn to play without Messi. Also Mou faces his old Club, while Bayern may be playing at their best. Barcelona star Javier Mascherano was charged with two counts of defrauding the Spanish tax authorities of… – Continue reading
International families are establishing domestic trusts at a record pace.1 Previously, these families set up trusts in the United States only if they had family and/or assets in the United States. This strategy still remains popular for international families, but now they’re also using domestic trusts even if they don’t… – Continue reading
Since its inception in August 2014, the SMU-TA Centre for Excellence in Taxation has worked tirelessly with industry practitioners, international academics and various key stakeholders to produce its first set of research works. On September 17, the Centre successfully presented its inaugural conference titled “A New Equilibrium in Tax Competition… – Continue reading
Financial institutions, partner jurisdictions and affected stakeholders have been working to implement the Foreign Account Tax Compliance Act (“FATCA”) since its enactment in March 2010. Time and again, as key implementation dates draw near, stakeholders redouble their efforts to satisfy these deadlines. Nonetheless, some stakeholders are not as prepared as… – Continue reading
French economist Gabriel Zucman, a protégé of Thomas Piketty, has a new book outlining how to avoid this. To Gabriel Zucman, protégé of rock star French economist Thomas Piketty, the United States is starting to look a lot like Europe in the late 1800s. “There’s been this great reversal where,… – Continue reading
The Department of Justice announced today that Migros Bank AG (Migros) and Graubündner Kantonalbank (Graubündner) have reached resolutions under the department’s Swiss Bank Program. These banks will collectively pay penalties totaling more than $18 million. “It is abundantly clear from the agreements reached to date that for decades, many foreign… – Continue reading
The UK’s tax treatment of US limited liability companies (LLCs) will remain mostly unchanged despite a recent Supreme Court decision in favour of the taxpayer, HM Revenue and Customs (HMRC) has confirmed.25 Sep 2015 HMRC said that the decision of the UK’s highest court in favour of George Anson, a… – Continue reading
The Foreign Account Tax Compliance Act, passed in 2010, is a tool devised to help the U.S. locate funds of U.S. citizens being held in foreign banks. (See this earlier FATCA report on LBN). The law requires foreign banks to report data about accounts owned by U.S. citizens to the… – Continue reading
Reading companies’ annual reports to the Securities and Exchange Commission is a reliable cure for insomnia. Every so often, though, there is a significant revelation in the paperwork. Last year, one of the most important revelations came from Microsoft’s filings, which spotlighted how the tax code allows corporations to enjoy… – Continue reading
Two more Swiss banks will pay fines to the United States as part of settlements that mean they will not face criminal charges for helping Americans avoid taxes, U.S authorities said on Friday. Migros Bank AG will pay approximately $15 million and Graubündner Kantonalbank will pay $3.6 million, the U.S…. – Continue reading
The Internal Revenue Service has entered into landmark Competent Authority Agreements with authorities in Australia and the United Kingdom to support the implementation of the Foreign Account Tax Compliance Act (FATCA). The US has signed FATCA intergovernmental agreements with both of these nations. Each of these agreements provides that Competent… – Continue reading
Automatic exchange of information for tax law enforcement purposes started first in Europe with the EU Savings Tax Directive, went international with the US Foreign Accounts Tax Compliance Act, and, from 2017, will go global with the recently-agreed Common Reporting Standard, the subject of this feature. Introduction To The Common… – Continue reading
When Delta, a South Africa-based property investment fund, decided to switch the offshore domicile of its international operations from Bermuda to Mauritius a year ago, it gained unexpected benefits, reports the Financial Times. “We’ve been very pleased,” says Bronwyn Corbett, head of Delta, as she reflects on the success of… – Continue reading
On September 18, 2015, the IRS issued Notice 2015-66 (the Notice), which provides that the Treasury Department and the IRS intend to amend regulations issued under Sections 1471-1474 of the Internal Revenue Code (commonly known as FATCA). The Notice, among other things, indicates that the Treasury and the IRS will… – Continue reading
Tax avoidance is a key problem for European countries, with the EU taking several steps to try and limit the ability of businesses to shift their profits to low-tax jurisdictions. Peter Dietsch writes on the nature of the problem and what can be done to tackle it. He argues that… – Continue reading
Notice 2015-66 was issued on 18 September 2015 announcing that the US Treasury Department and IRS intend to amend section 1471-1474 of the regulations. Transitional Rules The transitional rules provided in Notice 2015-66 are intended to allow for and facilitate an orderly transition for withholding agents and FFIs regarding FATCA… – Continue reading
US taxpayers with secret bank accounts in Belize are about to feel the full force of the Internal Revenue Service (IRS). A federal court in Miami has issued summonses against Belize Bank International and Belize Bank aiming to identify accounts controlled by US taxpayers from 2006 until 2014. Belize banks… – Continue reading
On September 16, 2015, the Honorable Mr. Justice Martineau rendered summary judgment in the matter of Hillis and Deegan v. The Attorney General of Canada, docket T-1736-13 (2015 FC 1082). As a matter of background (and as discussed in a previous post), on August 11, 2014, the plaintiffs, Hillis and… – Continue reading
The IRS recently replaced Rev. Proc. 2006-54 for requesting assistance under the Mutual Agreement Procedure (“MAP”) article of U.S. tax treaties, and Rev. Proc. 2006-9 for requesting Advance Pricing Agreements (“APAs”). The new Rev. Procs. (2015-40 and 2015-41, respectively) largely track draft procedures issued in 2013 (Notices 2013-78 and 2013-79),… – Continue reading
A former Valparaiso man has admitted lying about his control of a Bahamian trust account worth millions of dollars, for the purpose of stonewalling attempts to collect $188 million in civil judgments against him. On Tuesday, Peter G. Rogan, 69, pleaded guilty to perjury in the U.S. District Court in… – Continue reading
Prime Minister Narendra Modi is scheduled to attend the UN Sustainable Development Summit as part of his second visit to the United States. INDIA IS likely to talk on the increased global efforts against tax avoidance and tax evasion at the United Nations later this month. Prime Minister Narendra Modi… – Continue reading
NEW YORK, NY–(Marketwired – September 23, 2015) – With the global implementation of FATCA and anticipation of the Common Reporting Standard (CRS), legal and compliance professionals within the banking industry have never seen such a regulatory overload and focus on ensuring proper compliance processes. As these multi-national regulations become implemented… – Continue reading
The tax office is beefing up efforts to catch international tax cheats by swapping banking information with US authorities. Details of more than 30,000 financial accounts worth over $5 billion held in Australia by US citizens will be provided to US Internal Revenue Services under the first wave of transparency… – Continue reading
Chief Minister Allan Bell has written to the District of Columbia Council to outline his concerns at the island’s inclusion in a blacklist of tax havens. Washington DC released the list of 39 ‘tax havens’ as part of its Budget Support Act, which was signed by the Mayor in August…. – Continue reading
The IRS has let Americans living abroad wrongly claim tax credits on their foreign income, according to a new report from the agency’s watchdog. The Department of Treasury’s inspector general for tax administration said the IRS allowed taxpayers to wrongly claim around $95 million between 2010 and 2012 in foreign… – Continue reading
A long-awaited legal challenge against the US Foreign Account Tax Compliance Act (FATCA) was rejected in the courts. The Federal Court of Canada rejected an attempt from Virginia Hillis and Gwendolyn Deegan claiming that FATCA infringed the Canadian Charter of Rights and Freedoms and their right to enjoy security of… – Continue reading
Valeant is famous for wringing cost savings out of its buyouts, and its tax-advantaged Canadian domicile helps on that front. Now, it’s leveraging another address to pare down Salix’s tax bill by more than $560 million. But how? According to documents seen by The Wall Street Journal, the strategy used… – Continue reading
About 30 percent of foreign investors in Korea are from overseas tax havens, a lawmaker said Tuesday. Citing data from the Financial Services Commission and the Korea Customs Service, Rep. Park Kwang-on of the main opposition New Politics Alliance for Democracy (NPAD) said that the number of corporate or individual… – Continue reading
What constitutes an HNI is a tricky question? In general parlance, HNIs are understood to be the individuals with ultra-high networth with deep pockets having surplus investible funds. As per the Credit Suisse global wealth report, currently India is home to around 1,500 ultra-high networth individuals with wealth of at… – Continue reading
Marginal rate ninth highest in 34 OECD countries, pre-budget submission claims Ireland risks deterring high- calibre foreign executives from moving here because of its relatively high tax rates, the Irish Tax Institute has warned. In a pre-budget submission, the institute said Ireland’s marginal tax rate of 52 per cent was… – Continue reading
(OTTAWA) – Elizabeth May, Leader of the Green Party of Canada (Saanich-Gulf Islands), issued a letter to Stephen Harper, urging him to extend the IRS deadline for Foreign Accounts Tax Compliance Act (FATCA). “The private banking information of hundreds of thousands of Canadian citizens and permanent residents is set to… – Continue reading
A former financial services minister yesterday branded as “inconsequential” concerns over the District of Columbia’s (DC) pending ‘tax haven’ blacklisting of the Bahamas and 16 other Caribbean nations. Ryan Pinder, now a senior executive at Deltec Bank & Trust, was responding to concerns raised by Opposition finance spokesman, K Peter… – Continue reading
Development Goals (SDGs) but poorer countries should exercise caution when borrowing money, Gail Hurley, a development finance expert with the UN Development Program (UNDP), told Xinhua. “There’s a lot more finance available now—public and private, domestic and international — (but) a lot of it is loan finance, so we do… – Continue reading
On September 18, 2015, the Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issued Notice 2015-66, providing that the regulations under chapter 4, sections 1471-1474 of the Internal Revenue Code of 1986, as amended, commonly referred to as FATCA, will be amended to extend certain transitional rules…. – Continue reading
The Treasury Department said Friday it would delay enforcement of one key part of a 2010 law that is aimed at curbing offshore tax evasion, in a regulatory victory for banks, reports the Wall Street Journal. The law, the Foreign Account Tax Compliance Act, or FATCA, requires foreign banks to… – Continue reading
With less than two weeks remaining until many countries are required to exchange tax information with the U.S. pursuant to the Foreign Account Tax Compliance Act (FATCA), the U.S. has agreed to provide partner jurisdictions with more time to implement information exchange systems. Today, the Treasury Department and the Internal… – Continue reading
The Indian Government must assure investors that it is committed to improving its legal framework, including the tax code, if it is to meet its economic objectives, a senior US State Department official has said. Ahead of Indian Prime Minister Narendra Modi’s visit to the US this week, Nisha Desai… – Continue reading
There are many Non-Resident Indians (NRIs) from the US that are fearful of being involuntary discovered through the impending Foreign Account Tax Compliance Act (FATCA) disclosures of their Indian accounts by their foreign banks. The US Internal Revenue Service has issued a notice extending the time under which certain transitional… – Continue reading
The OECD Common Reporting Standard (CRS) and FATCA in the United States are long-winded. So the OECD published on August 7 a much shorter and lighter guide: the “Common Reporting Standard Implementation Handbook” (the CRS Handbook). The CRS and FATCA represent a sweeping change toward automatic information exchange and away… – Continue reading
With the August recess now well in the rearview mirror, Congress is already deep into grappling with the imminent expiration of the U.S. Government’s funding authority on September 30. Amid the debates over the “Continuing Resolution” and related funding issues, the Iran deal, and other high-profile issues, the work on… – Continue reading
The Georgian side has taken responsibility to inform the Revenue Office of the United States (US) about the financial assets of US residents living in Georgia. From September 18, when Parliament of Georgia ratified an agreement on Foreign Account Tax Compliance Act (FATCA) with the US, all Georgian financial institutions,… – Continue reading
A new wave of global tax compliance regulation is a game changer in the way asset owners and investment management companies report activities. Globalization of financial markets has made it increasingly simple to make, hold and manage investments outside an asset owner’s own tax domicile. A standard on automatic exchange… – Continue reading
The Grand Duchy of Luxembourg is ranked third in the world for the number of financial institutions per-country that have now signed up to report under the Foreign Account Tax Compliance Act (FATCA). IRS figures report 8,525 Luxembourg firms have registered with the FATCA portal, and the total is surpassed… – Continue reading
New Delhi, Sept. 20: A bilateral investment treaty between India and the US is unlikely to be finalised before Prime Minister Narendra Modi’s visit to America later this week. Both Modi and US President Barack Obama have been pushing their respective bureaucracies to prepare the pact. Modi will be in… – Continue reading
High-net-worth, tax-evading South Africans will soon have nowhere to hide, because in future income tax returns will specifically ask them to declare if they have offshore trusts, or directly or indirectly control an offshore trust, Judge Dennis Davis, the convener of the Davis Tax Committee, says. If the South African… – Continue reading
The Caribbean has just 18 congressional working days from Sunday September 20 to try to have the US Congress or the District of Colombia address an act naming 17 Caribbean nations as “tax havens”. If passed without amendment it could have the effect of reputationally damaging the countries concerned with… – Continue reading
On Friday, Coca-Cola Co. said that it may owe the IRS an extra $3.3 billion in federal income taxes. According to the company, the Internal Revenue Service found after a five-year-long audit that the soft drink giant may owe the federal government $3.3 billion along with interest for the 2007… – Continue reading
A small office shared with three other companies deep in the bowels of the Outsource IT Tower on Auckland’s Khyber Pass Road opposite a reservoir isn’t necessarily where you’d expect to find the global headquarters of a financial service provider that claims to be following in the footsteps of three… – Continue reading
The Internal Revenue Service has issued a notice extending the time under which certain transitional rules for the Foreign Account Tax Compliance Act, or FATCA, will apply. FATCA was included as part of the HIRE Act of 2010 and requires foreign financial institutions to report on the assets of U.S…. – Continue reading
CORNING — Corning Inc.’s handling of profits it earns overseas has quickly become an issue in the 2016 presidential campaign. The Fortune 500 company’s refusal to bring back to the U.S. more than $12.4 billion in overseas profits first drew criticism from U.S. Sen. Bernie Sanders, an independent from Vermont…. – Continue reading
