HSBC Swiss unit to pay $192 mln in latest U.S. tax evasion deal
Trouble for the Swiss private banking unit of HSBC Holdings Plc HSBA.L. ... - Continue reading
Category: USA
Deutsche Bank slapped with €15m fine in money laundering case
German authorities raided Deutsche Bank's offices, including its Frankfurt base, in connection with the probe in 2018. ... - Continue reading
GRI issues international corporate tax reporting standard
The Global Reporting Initiative has issued a new international tax reporting standard that aims to ensure multinational companies are much clearer about how much they pay in taxes, and where. While the standard has no legal force, it could influence the ongoing debate in the U.S. and abroad on how… – Continue reading
A Run Through On Tax Evasion By Bitcoin Criminals
A report released by the Internal Revenue Service (IRS) has put quite some focus on Bitcoin’s scope for committing tax evasion ... - Continue reading
IRS touts 91% conviction rate for its 2019 tax crime cases
The Internal Revenue Service has a message for tax criminals: "We will not stop in our pursuit." ... - Continue reading
US FATCA crackdown pushing demand for tax advice
As the US IRS cracks down on tax avoidance overseas with FATCA, the number of Treasury-licenced tax advisers with addresses outside of the US has jumped about 50% since 2016 according to figures from the agency. ... - Continue reading
Indirect linkages to Tax Havens
According to the most current Federal Tax Compliance Research Report, there is an estimated US Net Tax Gap (Tax Not Collected) of $406 Billion. ... - Continue reading
U.K. broker pleads guilty to conspiring to evade FATCA
The broker also facilitated manipulative trading in a U.S. company, authorities said ... - Continue reading
RenTech’s Billion-Dollar Tax Cloud Darkens After IRS Ruling
A little-noticed decision by the Internal Revenue Service’s appeals unit may spell trouble for legendary investor Jim Simons, who’s embroiled in a multibillion-dollar tax dispute with the agency. ... - Continue reading
Nearly a million Canadian bank records sent to IRS
Number of government transfers of records of bank accounts held by Canadian residents to U.S. has been rising ... - Continue reading
When A New York Exempt Resident Trust Meets The Sale Of A Business
Insights into the functioning of a trust ... - Continue reading
Ukraine, U.S. ratify agreement on FATCA de-offshorization
The bill foresees that the Ukrainian banks will open information about the accounts of U.S. citizens in this country; Ukraine, on the other hand, will not be able to get the respective information about Ukrainian accounts in the States The Verkhovna Rada of Ukraine has passed the document about ratification… – Continue reading
U.S. govt deficit hits 7-year high
The U.S. government ended fiscal year 2019 with the largest budget deficit in seven years as gains in tax receipts were offset by higher spending and growing debt service payments, the Treasury Department said on Friday. It is the first time since the early 1980s that the budget gap has… – Continue reading
US IRS tells banks not to close accounts just because of missing tax ID number: FATCA
The US Internal Revenue Service has eased the rules of FATCA compliance by telling banks overseas that they are not required to close the accounts of their accidental Americans clients who have not provided their tax identification number by January 2020. FATCA was passed in 2010 and forces banks wanting… – Continue reading
Dutch ditching their US citizenship over tax fears
Some 1,700 ‘accidental’ Dutch Americans have applied to give up their US nationality this year, a six-fold rise on three years ago, before a new tax law is implemented next year. As FATCA is enforced, these Dutch Americans must file a tax return in the United States. If they do… – Continue reading
‘Who is buying Seattle?’: New report issues warnings on Seattle’s luxury housing boom
Seattle’s luxury housing boom will worsen inequality and affordability in the city, according to a new report, which calls for officials to require more transparency on who is actually buying luxury real estate in the area. The report — “Who is Buying Seattle? The Perils of the Luxury Real Estate… – Continue reading
United States: Webinar: Supreme Court’s reconsideration of Auer Deference may undermine FFIEC manual.
Regulations governing BSA/AML compliance are often ambiguous, leading to disagreements with regulators about whether financial institutions are in compliance with those regulations. ... - Continue reading
Utah man failed to submit proper tax returns, avoided paying taxes for 12 years
A man from Pleasant Grove, Utah, was convicted of multiple counts of tax evasion for failing to submit proper tax returns and avoiding paying his taxes for 12 years. Robin Kartchner, 69, has been convicted of 15 counts of tax evasion, according to a Tuesday press release from the Utah… – Continue reading
Switzerland: Amended Protocol Of Double Taxation Agreement Between Switzerland And USA
On 20 September 2019, Switzerland and the USA ratified the protocol of amendment of their double taxation treaty ("DTA"). ... - Continue reading
US IRS addresses expiration of temporary section 385 debt/equity regs
The US IRS on October 11 released IRS guidance addressing the expiration of debt-equity documentation temporary regulations under code Section 385. ... - Continue reading
United States: Senators Introduce Bill To Require Reporting Of Beneficial Ownership Information
A bipartisan group of senators introduced a bill which would impose federal beneficial ownership reporting requirements for legal entities established under state law, intended to assist law enforcement in fighting money laundering and terrorist financing ("AML/CFT"). ... - Continue reading
Accidental Americans’ sue France over FATCA disclosure rules
A group representing French-American taxpayers has filed a complaint against France with the European Commission over its compliance with the US Foreign Account Tax Compliance Act (FATCA), in a bid to avoid being blacklisted by French banks starting in January. France is a signatory to an agreement to give the… – Continue reading
NRIs or RNORs are generally not liable to pay tax in India on foreign income
If you wish to retain the NRI status to avoid clubbing of US salary with Indian income for tax purposes, it would be advisable for you to restrict your stay in India to less than 60 days during FY20 ... - Continue reading
Imminent Changes To US Immigration Program
There has been a lot of recent media attention surrounding the EB-5 Investment Visa Program, and for good reason. South African residents are not able to emigrate for exchange control purposes (sometimes referred to as a financial emigration) unless they have a lawful right of abode in the country to… – Continue reading
US/UK tax series: US citizens moving to the UK
If you are a US citizen who is becoming UK resident you will continue to be subject to US tax and reporting obligations but will also become subject to UK tax. ... - Continue reading
CITIRA set to replace outdated tax scheme
Finally, the outdated and “dysfunctional” tax regime based on gross income earned is now about to end with the expected enactment into law of the new Corporate Income Tax and Incentives Rationalization Act (CITIRA), which the House recently passed with a vote of 170 versus eight against and six abstentions. … – Continue reading
Foreign investors inject $143.6 million in t-bills since July
KARACHI: Foreign portfolio investors invested $143.633 million in treasury bills from July onwards as the present government started betting on overseas funds into debt securities to finance budget deficit and refinance maturities. The State Bank of Pakistan’s (SBP) latest data showed that outflow from portfolio investors amounted to $5.808 million… – Continue reading
FATCA blamed for one in five US expats planning to give up passport
One in five US citizens living abroad are on the verge of giving up their passports according to a survey published by US tax consultants Greenback. The Greenback survey – which was conducted by more than 3,000 US expats – studies the expat community’s opinions on taxation, citizenship renunciation, and… – Continue reading
Salary received abroad by ‘resident and ordinary resident’ is taxable in India
You may evaluate claiming foreign tax credits under the India-US Double Tax Avoidance Agreement, for the taxes, if any, paid in the US on the salary received during the assignment, subject to satisfaction of conditions ... - Continue reading
IRS offers tax break to some American expats
The Internal Revenue Service (IRS) has outlined new procedures for some “accidental Americans,”, giving them the chance to comply with their US tax and filing obligations and in turn qualify for relief from back taxes, penalties and interest. The changes would allow people with less than $2m in net worth… – Continue reading
Tax avoidance drives nearly 40% of global FDI: IMF
Nearly 40% of worldwide foreign direct investment (FDI), amounting to $15trn, “passes through empty corporate shells” with “no real business activities”, a study by the IMF and the University of Copenhagen reveals. According to the report, ten economies including Luxembourg, the Netherlands, Hong Kong, BVI, Switzerland, Singapore, Ireland, the Cayman… – Continue reading
US-born British citizen launches crowdfunding campaign to stop FATCA
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
Ukrainian government approves bill ratifying FATCA
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
US AND LUXEMBOURG RATIFY DOUBLE TAXATION PROTOCOL
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
Canada: Frozen Bank Accounts Of US Citizens In Europe – What Does It Mean For Canada
Why are French and British banks threatening to freeze or close the bank accounts of US citizens?
... - Continue readingBritish citizens born in America face having bank accounts frozen
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
United States: D.C. Circuit Expands U.S. Prosecutors’ Reach Over Foreign Bank Documents
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
European Union: The Increasing Link Drawn By Regulators Between State Aid & Taxation Systems
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
US, France reach deal on digital services tax
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
United States: Captive Insurance Strategies Can Pay Off For Real Estate Operators
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
Worldwide: New Double Taxation Treaty Between US And Spain
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
United States: FinCEN Director Addresses Gaming Industry
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
US appeals court sides with Amazon in $1.5 billion transfer pricing dispute
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
FATCA could push French banks to close up to 40,000 account
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
IRS to resume challenges to treatment of stock-based compensation in cost-sharing arrangements
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
United States: Anti-Money Laundering And Sanctions: Trends And Developments Emerging Under The Trump Administration
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
US-Dominican Republic FATCA agreement enters into force
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
