Category: USA

Imagination at Work? GE Once Again Pays Less Than 1% in Federal Taxes

Notorious tax dodger GE recently released its annual financial report and the only thing eye-raising about the company’s paltry 0.9 percent federal income tax rate is that it’s marginally higher than the 0.4 percent average rate it paid over the past decade. Released without fanfare late in the afternoon last… – Continue reading

IRS Opens FATCA International Data Exchange Gateway

The Internal Revenue Service’s Large Business & International division has opened a gateway that financial institutions and the tax authorities abroad can use to send information on financial accounts held by U.S. taxpayers in accordance with the Foreign Account Tax Compliance Act. FATCA, which was included as part of the… – Continue reading

Corporate aristocracy holding out against tax revolution

Smaller companies, which innovate and create jobs, carry an unfair share of the burden In pre-revolutionary France aristocrats were exempt from direct taxation. On present trends the world’s elite corporations may soon find themselves similarly privileged. In the larger advanced countries the corporate tax base is eroding, partly because the… – Continue reading

Rwanda: Competing On Corporate Tax

Corporate tax reform has emerged as an area of potential bipartisan action in the United States Congress over the next few months. But fundamental questions about the right approach remain. There is widespread agreement that the US corporate tax system is deeply flawed. The rate is too high; the base… – Continue reading

Deadline Dates for Automatic Exchange of Tax Information under FATCA and CRS

In previous updates we have alerted clients to the introduction of Cayman Islands regulations1, which give effect to the automatic exchange of tax information principles established by the US and UK intergovernmental agreements (the “Cayman US Regulations” and the “Cayman UK Regulations”, respectively). While many Cayman Islands entities will be… – Continue reading

Deadline dates for automatic exchange of tax information under FATCA and CRS

In previous updates we have alerted clients to the introduction of Cayman Islands regulations1, which give effect to the automatic exchange of tax information principles established by the US and UK intergovernmental agreements (the “Cayman US Regulations” and the “Cayman UK Regulations”, respectively). While many Cayman Islands entities will be… – Continue reading

No respite for Vodafone as Arun Jaitley maintains status quo on past offshore deals

British mobile giant Vodafone hasn’t been bailed out, with Finance Minister Arun Jaitley maintaining status quo on taxing past offshore deals. However, foreign investors can draw comfort as tax will be charged in India only on certain offshore deals where the underlying asset and the value derived thereon are in… – Continue reading

No wonder Nick Clegg has gone quiet on tax dodging: His wife’s paid by law firm that helps rich avoid tax and his father is chairman of bank with ties to tax haven

‘His failure to make more noise is odd’ says prominent tax QC His father, Nicholas, has worked for banks operating in tax havens Wife, Miriam Gonzalez Durantez’s, firm advertises ‘tax-planning services’ Lib Dems insist there is no conflict of interest involved in his position Not long ago, a law firm… – Continue reading

IRS Clarification on Non-Willful Conduct Certification for Streamlined Offshore Compliance Procedures: Revisions to IRS Forms 14654 and 14653

Many U.S taxpayers are often surprised to discover that they have a U.S. tax reporting obligation on financial accounts or assets held overseas. Once they discover their obligation, there are a number of programs through which they can become compliant with their U.S. tax reporting obligation. One option, if the… – Continue reading

Israel regulator seeks bank provisions to cover possible tax settlements-Army radio

Feb 26 (Reuters) – Israel’s banking regulator has demanded that two of Israel’s largest banks set aside money to settle possible U.S. tax evasion investigations, Army Radio reported on Thursday. Citing an unnamed source, the radio said the request was made to Hapoalim, Israel’s largest bank, and Mizrahi Tefahot, the… – Continue reading

US Business Groups Add To Calls For DTA Approvals

In a February 20 letter to US Senate Majority Leader Mitch McConnell (R – Kentucky), the National Foreign Trade Council and other leading business organizations urged action on pending bilateral double taxation agreements (DTAs) and protocols. A coalition of ten business organizations, including the Business Roundtable, National Association of Manufacturers,… – Continue reading

Coutts’ Swiss operation faces German investigation over tax evasion claims

Bank’s subsidiary in Switzerland is already being investigated by US authorities about whether it helped Americans evade tax The venerable Coutts bank, home of the Queen’s personal accounts, has been drawn into the mounting controversy about private banking with an admission that its Swiss arm is under investigation for aiding… – Continue reading

Refund Management Services, Canada’s Leading U.S. Gaming Tax Recovery Service, Weighs in on Report: U.S. Tourism to See Boom in Overseas Visitors

Refund Management Services (http://www.RefundManagement.com), the number-one choice for Canada’s biggest winners for U.S. gaming and casino tax refunds, is weighing in on a recent report showing international travel and tourism-related activities within the U.S. increased in November. Refund Management Services is also commenting on how, despite the strong dollar, U.S…. – Continue reading

Tax break for Gilead as overseas profits jump 81%

Profits outside US exceed non-US sales for company selling $1,000 a pill HepC therapy Gilead Science, whose $1,000-a-pill hepatitis C treatment is one of the world’s most expensive drugs, is avoiding billions of dollars in US taxes by booking profits overseas. The company, which has operations in Ireland, reported foreign… – Continue reading

Leading Offshore Firm: The Inside View on the Cayman Islands Jurisdiction

MCC interviews three attorneys from Mourant Ozannes. Hayden Isbister is a partner and head of the Corporate practice in the Cayman firm. He specializes in investment funds, general corporate and commercial work. James Burch is a partner and leads the Structured Finance/Banks practice in the Cayman Islands, and Tim Dawson… – Continue reading

Citigroup unit probed by more authorities over money laundering

[NEW YORK] Citigroup Inc said additional government authorities have started probes of possible breaches of anti-money laundering laws at its Banamex USA unit. The Financial Crimes Enforcement Network, a unit of the US Treasury, and the California Department of Business Oversight have asked the company for information on its compliance… – Continue reading

The Common Reporting Standard: CRS brings the walls tumbling down

A country known for its clocks, chocolate and most importantly banks, the agreement by Switzerland’s government to share details of those super-secret bank accounts is one that will change the world at large. Gone are the days of the elusive Swiss bank account. The arrival of Common Reporting is upon… – Continue reading

HSBC chiefs to testify in tax scandal on tax evasion

First there was money laundering, then foreign-exchange rigging and now tax evasion. Politicians and analysts are asking if big banks became too big to manage from being too large to be allowed to fail HSBC Europe’s biggest bank, has endured a string of scandals and paid millions in penalties to… – Continue reading

New Non-adversarial Tax Regime: India Shows a Way

Mr. Akhilesh Ranjan, Joint Secretary Ministry of Finance, and also Competent Authority for the Government of India, spoke this past week at the Pacific Rim Tax Institute, February 19-20, reaffirming India’s commitment to a new non-adversarial tax regime to encourage foreign investment and fair treatment of taxpayers. Mr. Ranjan’s appointment,… – Continue reading

OECD Seeks Change In Global Taxation

Thanks in part to past concerns that globalization could lead to double taxation, corporations have numerous techniques at their disposal to reduce their tax bills, including the placement of subsidiaries and spinoff holding companies in low-tax jurisdictions. The Group of 20 wants to change that. The Organisation for Economic Cooperation… – Continue reading

US citizens in Greece and US taxes: A word to the wise, and a seminar

It is estimated that there are at least 100,000 Greeks with American citizenship living in Greece. In addition, thousands of US citizens live and work in Greece, either on a short-term or permanent basis. According to US law, all of these citizens, with very few exceptions, are required to file… – Continue reading

FATCA: The End of ‘Shadow Boxing’ in the Offshore Trust Industry

Not long after the U.S. Department of Justice’s Tax Division (“DOJ”) made international headlines in 2009 for its bombshell announcement that it had entered into a deferred prosecution agreement with the United Bank of Switzerland (UBS), lawmakers in Washington, D.C. began reviewing the testimony of hundreds of UBS’s U.S. clients… – Continue reading

Is international tax planning for contractors illegal or immoral?

The differentiation between tax avoidance, tax evasion and the moral duty to pay tax for the betterment of society has been intentionally screwed by politicians and bureaucrats. This is nothing new. I wrote an couple of articles several years ago questioning the terminology of ‘morally repugnant’ tax avoidance when it… – Continue reading

We stayed, you didn’t: Post-conflict Africa grapples with tensions of returnees from the diaspora

Although the importance to Africa’s diaspora is largely discussed around remittances, many Africans are also coming back to join the public service. SOMALIA’S parliament just approved a new parliament, a crucial step on the road to voting on a new constitution and presidential elections scheduled for 2016. A key role… – Continue reading

US Report Criticizes Repatriation Tax Proposals

A repatriation holiday would have a minimal economic impact and would be the wrong way to pay for the Highway Trust Fund or any other project, according to a new report by the Heritage Foundation. There have been differing congressional proposals recently to change the tax treatment of the USD2… – Continue reading

Was Bank Leumi too hasty in revealing U.S. clients’ info to the IRS?

The issue of whether Israeli banks should take the Swiss approach and refuse to disclose customer identities may be a moot point, in light of a new international anti-tax-evasion treaty that is taking shape. There is a direct line connecting the disclosure of the identities of 6,200 Israelis with Swiss… – Continue reading

Alberta online bank first in Canada to shun U.S. clients amid tax rules

An Alberta online bank is believed to be the first Canadian financial institution to deny service to Americans, citing the burden of complying with strict new U.S. tax rules. Canadian Direct Financial, a subsidiary of Edmonton-based Canadian Western Bank, is refusing to open new Internet accounts for U.S. citizens, even… – Continue reading

2 Investments to Avoid in Your IRA

IRA plans can be excellent ways to save for retirement, but there are some investments to avoid if you want to take full advantage of IRA tax savings. Two that come immediately to mind are tax-exempt municipal bonds and high-yielding stocks from foreign countries with dividend withholding taxes. Tax-exempt municipal… – Continue reading

Transfer Pricing Audits: With Changes on the Horizon, Upfront Planning Is Key

Transfer pricing policy in the United States is guided by Section 482 of the Internal Revenue Code (and by the Organization for Economic Cooperation and Development under its Base Erosion and Profit Shifting initiative), and its application is not limited to cross-border transactions. In fact, some states, such as New… – Continue reading

Everything U.S. Expats Need to Know About IRS Tax Forms (But Were Afraid to Ask)

This is the time of the year for millions of Americans to begin the annual ritual of gathering information about income, taxes, charitable giving, health insurance, expenses and sundry other items, and prepare to send mountains of information to the IRS –and to those who prepare their tax returns. Overseas… – Continue reading

Terry Baucher says a ‘rare generational shift’ is taking place in international tax – and the implications will be felt for decades

When I consider what’s likely to have the most impact in tax this year, I keep coming back to the massive shift in attitude by tax authorities in the aftermath of the Global Financial Crisis (GFC). Usually changes in the tax world are incremental, but what is going on now… – Continue reading

US, Dominican Republic start tax info exchange

Santo Domingo.- The US Internal Revenue Service (IRS) and Dominican Republic’s Internal Taxes Agency (DGII) have begun a process to exchange bilateral financial and tax information, as part of the on Foreign Accounts Tax Compliance Law (FATCA). A delegation of the IRS’ International Cooperation Program led by its senior manager… – Continue reading

HSBC Says Gulliver Paid Taxes After Opening Swiss Account

(Bloomberg) — HSBC Holdings Plc, struggling to contain a political storm over the bank’s facilitation of tax evasion through its Swiss unit, said Chief Executive Officer Stuart Gulliver paid taxes after setting up his own Swiss account and keeping his legal residence in Hong Kong. The bank, reacting to an… – Continue reading

Tax System Gives Edge To Foreign Buys Of U.S. Firms

The Treasury Department’s crackdown on tax inversions last year has slowed but not stopped the movement of U.S. headquarters abroad as American businesses try to reduce tax bills and foreign firms seek to grow. Indeed, with U.S. companies now virtually barred from relocating overseas in order to trim taxes, the… – Continue reading

Dorchester Minerals, L.P. Announces Its Fourth Quarter Distribution

DALLAS, TX–(Marketwired – Jan 15, 2015) – Dorchester Minerals, L.P. (NASDAQ: DMLP) announced today the Partnership’s fourth quarter 2014 cash distribution. The distribution of $0.485780 per common unit represents activity for the three-month period ended December 31, 2014 and is payable on February 5, 2015 to common unitholders of record… – Continue reading

For Bigger Bank Dividends, It Could Pay to Go International

Following the financial crisis, dividend yields from American banks have remained below the level many income investors are looking for. While all four major American banks yield less than 3%, U.S. investors can still get fat bank dividends by looking abroad. The United Kingdom London has long been a financial… – Continue reading

MNCs Beware: Country-By-Country Reporting Is Here!

UK, US, Australia, Brazil, India- governments of developed and developing countries are battling profit shifting by MNCs such as Amazon, Google, Apple and Starbucks. The allegation- MNCs are shifting profits to jurisdictions where there is little or no tax to be paid. The solution- OECD’s BEPS action plan which, among… – Continue reading