This past December, the Multistate Tax Commission’s (MTC) transfer pricing advisory committee and its project facilitator Dan Bucks recommended what it calls the “preliminary design” approach for a proposed Arm’s Length Adjustment Services (ALAS) program. While still subject to approval, states have already put designs on increasing state transfer pricing… – Continue reading
More than 100 tax disputes involving Indian associates of US companies such as IBM and Microsoft are set to be settled out of court by April this year with the income tax department and the US Internal Revenue Service identifying disputes in the contract research, IT and software sectors for… – Continue reading
Feb 7 (Reuters) – A former Swiss banker charged by U.S. prosecutors with helping wealthy Americans evade taxes has been arrested in Germany pending extradition to the United States, his lawyer said on Saturday. Roger Keller, a onetime client adviser in Zurich at Wegelin & Co, was one of three… – Continue reading
This past December, the Multistate Tax Commission’s (MTC) transfer pricing advisory committee and its project facilitator Dan Bucks recommended what it calls the “preliminary design” approach for a proposed Arm’s Length Adjustment Services (ALAS) program. While still subject to approval, states have already put designs on increasing state transfer pricing… – Continue reading
The serious doubts expressed by many, most recently Professor Christians of McGill University, as to the Constitutional authority cited by the US Treasury1 in support of each Inter Governmental Agreement (an “IGA”) entered into by it on behalf of the United States government to implement FATCA have been rendered practically… – Continue reading
A swath of changes to corporation tax in the European Commission’s pipeline topped the Taoiseach’s agenda when he met the president of the European Commission, Jean Claude Juncker officially in Brussels. New rules that would force every country to make public the tax arrangements with larger companies, including multi nationals… – Continue reading
Report skewers PwC for creation of Shire tax shelter it calls ‘tax avoidance on an industrial scale’ Shire’s Ireland address has made the specialty drugmaker a prime takeover target. AbbVie was attracted but dumped the $55 billion buyout when the U.S. Treasury Department threw cold water on the deal with… – Continue reading
Are you confident that your clients will never be sued? And if they are sued, are you certain that they will be treated fairly by the U.S. legal system? People are now being forced to protect themselves and their assets from liabilities that were never a concern in the past. … – Continue reading
Bond trader Ben Eiler swapped life in suburban Georgia for an island in the Caribbean, and he didn’t even have to apply for a visa. The towering 38-year-old native of Arkansas is one of at least 250 people who’ve accepted Puerto Rico’s invitation to well-heeled U.S. citizens to move to… – Continue reading
As middle class flees, Puerto Rico tries luring rich people The towering 38-year-old native of Arkansas is one of at least 250 people who’ve accepted Puerto Rico’s invitation to well-heeled U.S. citizens to move to the island and enjoy life without taxes on capital gains, an enticing offer for those… – Continue reading
The latest numbers are in and they are impressive. Since 2009, over 50,000 taxpayers with delinquent FBAR forms have come forward. Although many taxpayers are now seeking to take advantage of the IRS’ offshore account amnesty program, the IRS continues to ramp up enforcement efforts against the stragglers that ignore… – Continue reading
The latest numbers are in and they are impressive. Since 2009, over 50,000 taxpayers with delinquent FBAR forms have come forward. Although many taxpayers are now seeking to take advantage of the IRS’ offshore account amnesty program, the IRS continues to ramp up enforcement efforts against the stragglers that ignore… – Continue reading
More than half of Australia’s trade is money being sent offshore by companies to their overseas arms – with almost a third going to Singapore and Switzerland. Australian companies sent more than $100 billion to related parties in the low-tax nation of Singapore and another $15.6 billion to “hubs” in… – Continue reading
MUMBAI: The Mumbai bench of the tax tribunal has clarified that additional tax liability cannot be claimed from competitive industries in the name of location savings arising out of the country’s low-cost manufacturing base. The ruling may benefit pharmaceutical, auto, IT and IT-enabled companies, among others, that are engaged in… – Continue reading
February 4: The Luxembourg tax authorities this week released a draft version of a new administrative circular for implementing the FATCA regime. The new draft guidance concerns the file format to be used for the automatic exchange of information between the Grand-Duchy of Luxembourg and the United States.
Google has told the Australian parliament that it would prefer issues around taxation of multinational corporations to be dealt with by the G20 or the Organisation for Economic Co-operation and Development (OECD), rather than have individual countries attempt to go it alone. The Australian government is attempting to tackle profit… – Continue reading
Jersey’s financial institutions are now able to register in Jersey in preparation for US FATCA, which commences this year. The Foreign Account Tax Compliance Act (FATCA) requires financial institutions outside the USA to report information on financial accounts held by their US customers to the Internal Revenue Service (IRS). A… – Continue reading
(Reuters) – U.S. federal prosecutors have launched a new probe into whether Swiss bank UBS AG helped Americans evade taxes through investments banned in the United States, the Wall Street Journal reported, citing people familiar with the investigation. UBS, which paid $780 million in 2009 to settle a separate Justice… – Continue reading
The US Internal Revenue Service (IRS) has clarified that a foreign financial institution must obtain a customer’s self-certification details when opening a new account, in a new addition to its Frequently Asked Questions on its Foreign Account Tax Compliance Act (FATCA) website. The IRS was asked: If a Reporting Model… – Continue reading
The US government is scrutinising UAE expats’ bank accounts in a bid to clamp down on tax evasion. Strict new rules that came into effect last year mean US expats who have retained dual nationality, and Gulf-based nationals born in the US or to an American parent, could be US… – Continue reading
On February 2, the Obama Administration released its fiscal year 2016 budget (FY 2016 Budget). The hallmarks of the FY 2016 Budget are proposals that would impose (i) a minimum tax on the current foreign earnings of U.S. corporations and their controlled foreign corporations (CFCs) and (ii) a one-time 14%… – Continue reading
HONG KONG — China’s tax officials plan to step up efforts to collect taxes from multinational corporations in the latest of a series of moves in the last year, mostly against Western companies. The activities have included police raids on the headquarters of companies’ China operations and heavy fines under… – Continue reading
New Delhi, Feb. 4: The notification of a social security deal with Norway – often called totalisation agreements — may pave the way for a similar pact with the US that has been hanging fire for a decade. Under the pact, employees sent by Indian firms to Norway on a… – Continue reading
Negotiations over the India-United States nuclear deal continued until “Air Force One landed in Delhi” carrying President Barack Obama. According to sources, the nuclear deal and other agreements announced during Mr. Obama’s visit to India for Republic Day were being finalised right down to the moment his plane touched down…. – Continue reading
The European Commission has turned a blind eye to secretive tax deals that Ireland and other countries have been doing with multinationals for decades. Only after complaints from the US did it launch investigations into the most high-profile cases — Apple in Ireland, Starbucks in the Netherlands, and Amazon in… – Continue reading
Some 776 American citizens or long-time residents renounced their status in the third quarter of 2014, according to the Treasury Department. If that trend continues, the U.S. will see more than 3,000 renunciations this year-a record. Why are so many Americans forfeiting their citizenship? In 2010, Congress passed the Foreign… – Continue reading
Time is ticking for India to sign its inter-governmental agreement (IGA) with the US under the Foreign Account Tax Compliance Act (FATCA) after it received a one month extension on the original December 31 deadline. President Obama’s visit to India last week fuelled speculation that the IGA could be signed… – Continue reading
The Internal Revenue Service (IRS) has released revised versions of its Tax Guide for Aliens, providing guidance for resident and nonresident aliens for use in preparing their 2014 tax returns, and of its Tax Guide for Individuals Receiving Income from the United States Possessions – American Samoa, Puerto Rico, the… – Continue reading
Law360, New York (February 03, 2015, 10:22 PM ET) — Casino operator Caesars Entertainment Corp. has created a new anti-money laundering position in the wake of federal inquiries into its practices, hiring away a top compliance expert from Wal-Mart Stores Inc., according to a spokesman. Former Wal-Mart compliance expert Ben… – Continue reading
The IRS has one foot in the 21st century, and the other in the days of Camelot. The majority of taxpayers can file their federal income tax returns online. And those eager to see how soon they’ll get their refunds can even use the IRS’s mobile app. But thanks to… – Continue reading
The ARIA Investment Platform has launched a range of portfolio strategies on its investment platform aimed at US Investors caught by increasingly tough legislation. The Cautious Income Balanced and Adventurous Strategies are advised by Parala Capital, based on its Parala Macro Multi-Asset Allocation strategies, and are available on the ARIA… – Continue reading
On 30 January 2015 the Legislative Council passed certain changes to the Mandatory Provident Fund Schemes Ordinance (“MPFSO”). Such changes, when they come into force, will enable the withdrawal of benefits on the terminal illness of an employee, and also enable a phased withdrawal of accrued benefits. In addition, the… – Continue reading
Many wealthy foreigners considering their options for investment, permanent residency or citizenship in the US are concerned about the US tax policy. Many have heard of the US income tax on worldwide income, but in reality, astute advisors can mitigate or eliminate the additional expense. US Freedom Capital, the premier… – Continue reading
The National Taxpayer Advocate Nina Olson is a strong and vocal advocate for taxpayer rights. Her annual report to Congress castigates the IRS for its unfair application of offshore account penalties, and its disparate treatment of innocent Americans caught in reporting snafus. Some of the report asks the IRS to… – Continue reading
GCC nationals with dual citizenship face IRS efforts to collect income tax from non-residents Thousands of Gulf States nationals could be US tax evaders and not even know it. According to Italian-Swiss lawyer Giovanni Rossi who works for a law firm handling many of similar cases, the number could reach… – Continue reading
Eleventh-hour legislation in December kept many tax breaks alive for the 2014 tax year, but they weren’t extended beyond that. (See chart on page 26.) So clients who want to take advantage of those breaks need to get with a knowledgeable practitioner—and quickly. “CPA firms nationwide face a staffing challenge… – Continue reading
India and US reach common ground on Mutual Agreement Procedure (“MAP)” and break new ground on Advance Pricing Agreements (“APA”) Suchint Majmudar Just ahead of Obama’s momentous R-Day visit to India, the Competent Authorities of India and US reached a landmark breakthrough in cases involving mutual agreement procedure under the… – Continue reading
The IRS issued two New Releases this week that restate its focus on offshore tax evasion. The first was January 29, 2015 which followed the First International Criminal Tax Symposium. “The Internal Revenue Service Criminal Investigation Division (IRS-CI) and Her Majesty’s Revenue & Customs (HMRC) co-hosted a three-day International Criminal… – Continue reading
Critics question whether Galuteria actually lives in Senate District 12, which he has represented since 2008. State Sen. Brickwood Galuteria admitted Monday that he has improperly claimed a rental property in Palolo as his primary residence and will likely have to pay back taxes on the nearly $1.8 million home…. – Continue reading
The Internal Revenue Service announced in January that its International Data Exchange Service (IDES) is open for enrollment, and that financial institutions and host country tax authorities will be able to use IDES to securely send their information reports on financial accounts held by Americans to the IRS under the… – Continue reading
SUMMARY On February 2, 2015, the Obama Administration (the “Administration”) released the General Explanations of the Administration’s Fiscal Year 2016 Revenue Proposals (commonly known as the “Green Book”), which contains significant detail about the fiscal year 2016 revenue proposals. This memorandum discusses certain aspects of the Green Book relating to… – Continue reading
Potential candidates can gain foreign experience and donations in the British capital but expatriate supporters want action on Obama’s onerous tax demands Republican donors in the UK are lobbying the presidential hopefuls visiting London in search of foreign policy credentials and wealthy corporate allies to abandon President Barack Obama’s aggressive… – Continue reading
With over 7 million Americans living abroad, many have complained about the rigorous IRS enforcement of global tax reporting, the risk of draconian FBAR penalties for reporting foreign accounts, and FATCA discrimination. FATCA, America’s global tax enforcement law, applies virtually everywhere. It is easy for the IRS to find you,… – Continue reading
(Bloomberg) — President Barack Obama will propose that U.S.-based companies pay a minimum 19 percent tax on their future foreign earnings, capturing profits that are now often beyond the government’s reach. Obama will also seek a 14 percent mandatory tax on about $2 trillion in stockpiled offshore profits, said two… – Continue reading
IRS threatens 30% withholding tax on non-compliant banks Dubai: Many people, including American citizens working in the Gulf state, received recently letters from their UAE-based banks asking them for more details and papers in compliance with American laws introduced by tax service. The move comes as many citizens of the… – Continue reading
NKY congressman says that current system amounts to ‘double taxation’ on people. His bill could save some seniors thousands of dollars. Are you a higher-income Social Security recipient who must pay federal taxes on your benefits? U.S. Rep. Thomas Massie is your friend. Massie, R-Garrison, last week introduced the latest… – Continue reading
My dog ate my tax return’ and ‘I had to look after parrots’ are among the excuses HM Revenue & Customs is given by people who have failed to file in time Time is running out for thousands of people who have yet to file their tax returns as the… – Continue reading
Feb 1 (Reuters) – The Chinese government’s vow to increase tax scrutiny of foreign companies has sent firms rushing to tax advisors ahead of the implementation on Sunday of new rules designed to rein in cross-border tax avoidance. Tax professionals and business lobbies alike have welcomed the move as an… – Continue reading
LIGHTNING RELEASES (1/30/2015) – Attorney Gary S. Wolfe of The Wolfe Law Group is pleased to announce, after 12 years of research, the publication of his 10th book, Offshore Tax Evasion: The IRS and Swiss Banks, now available for immediate download through the Amazon Kindle store. Switzerland is the epicenter… – Continue reading
At the US agency responsible for enforcing the Fatca tax withholding reporting law, an apparent lack of frequency in updating GIIN registrations, along with the as-yet-untested launch of its compliance service, reflect poorly on its capabilities I covered Foreign Account Tax Compliance Act (Fatca) developments in this space just two… – Continue reading
