A deal between Stryker Corp. (SYK) and Smith & Nephew Plc (SN/) makes as much sense now as it did six months ago. It just might be tougher to pull off. Stryker is considering structuring the takeover as a tax inversion, allowing the Kalamazoo, Michigan-based company to move its legal… – Continue reading
Canadian taxpayers with an interest in a partnership that holds specified foreign property (as defined in subsection 233.3(1)) may face uncertainty when assessing their form T1135 (“Foreign Income Verification Statement”) filing obligations. Depending on the partnership’s structure, either (1) the taxpayer may be required to file form T1135 in respect… – Continue reading
Martin Lock was formerly the top withholding-tax specialist at the Tax Office, a role that encompassed oversight of profit shifting by multinationals. He is one of many former officers who have voiced their concerns to Fairfax Media about the challenge of arresting the slide in tax receipts from multinational companies… – Continue reading
The central bank resumed its foreign-exchange support through selling the US dollar to the commercial banks after nearly two years and a half to keep the market stable, officials said. As part of the move, the Bangladesh Bank (BB) sold US$45 million at market rate to five commercial banks directly… – Continue reading
RBC Wealth Management has announced plans to discontinue its private wealth management business in the Caribbean. The strategy to “realign certain businesses within [its] international operations” was presented to staff in an internal memorandum last Thursday. It is not clear whether the business will be closed or sold. Paul French,… – Continue reading
The Government of Barbados and the United States have signed an inter-governmental agreement (IGA) to facilitate compliance with the US Foreign Account Tax Compliance Act (FATCA). FATCA, which was enacted by the US Congress in 2010 and took effect on July 1, 2014, is intended to ensure that the US… – Continue reading
“Miserable.” That’s how Internal Revenue Service (IRS) Commissioner John Koskinen described the upcoming tax season to a group of tax practitioners at the AICPA National Tax Conference in Washington, D.C. earlier this month. Citing concerns about extenders, increased responsibilities due to the Affordable Care Act (ACA) and the Foreign Account… – Continue reading
Should London’s Mayor Boris Johnson pay U.S. taxes and file FBARs? Born in New York, the iconic London mayor never gave up his U.S. citizenship. But rather than quietly paying U.S. taxes, Mr. Johnson in an NPR interview called it ‘outrageous’ to tax U.S. citizens on their global income. Mayor… – Continue reading
The Future of the Department of Justice’s High Visibility Offshore Tax Evasion Initiative. On August 29, 2013, the U.S. Department of Justice (“DOJ”) Tax Division announced the Program for Non-Prosecution Agreements and Non-Target Letters for Swiss Banks (the “Program”). The announcement of this unprecedented program was the culmination of the… – Continue reading
(CNS Business): Following the G20 summit in Brisbane last week questions remain over how much the latest talks on global tax transparency will impact Cayman and other offshore jurisdictions. Despite the bluster from international politicians in the build-up to the summit over clamping down on multinational corporate tax dodging, illicit… – Continue reading
(Reuters) – China has levied about $140 million in back taxes from Microsoft Corp in the first major case concerning cross-border tax evasion in the country, as regulators ramp up pressure on U.S. corporations doing business there. According to an article published by China’s Xinhua official news agency on Sunday,… – Continue reading
When is a Chinese company not Chinese? When it’s a complex web of offshore vehicles rooted in anonymous tax havens. That description includes some of the People’s Republic’s most successful and innovative companies. It will make the country’s apparent new push on tax evasion hard to enforce. Authorities have extracted… – Continue reading
The Government of Barbados and the United States have signed an inter-governmental agreement (IGA) to facilitate compliance with the US Foreign Account Tax Compliance Act (FATCA). FATCA, which was enacted by the US Congress in 2010 and took effect on July 1, 2014, is intended to ensure that the US… – Continue reading
Each U.S. citizen and permanent resident must report worldwide income to the IRS even when paying taxes elsewhere. Moreover, you must file an annual FBAR (now called FinCEN Form 114) disclosing your foreign bank accounts if their aggregate value exceeds $10,000 at any point during the year. The penalties for… – Continue reading
Boris Johnson has a point about his U.S. tax bill, but he should still cough up. The London mayor objects to the fact that his dual UK and U.S. citizenship means he has been issued with an American tax bill, and he says he won’t pay. Though many U.S. expats… – Continue reading
This Black Friday, legions of shoppers will throng to their local Walmart in frenzied pursuit of holiday deals. But it turns out that Walmart has saved the sweetest deals for itself. In a recent analysis of Walmart’s tax spending, Americans for Tax Fairness (ATF) found that the company “avoids $1… – Continue reading
Companies based in the United States now have over $2.1 trillion stashed overseas shielded from U.S. taxes. That’s a sixfold increase in 12 years, NBC News reported citing research provided by Capital Economics. Generally, the U.S. tax policy allows companies based in the country to defer any tax obligation on… – Continue reading
By closing the tax gap, South Africa can reap billions of rands to benefit the economy. A global crackdown on tax avoidance has begun and South Africa is forging ahead in a bid to tackle wealthy individuals and corporates who practise this tactic. The initiative is better poised to succeed… – Continue reading
Jamaican banks and other financial institutions affected by the US Foreign Account Tax Compliance Act (FATCA) will have to bear the cost to implement the programme, says the Jamaica Bankers Association (JBA). “Though no formal research has been undertaken by the JBA to ascertain the cost implications for its members… – Continue reading
Credit Suisse AG (CSGN)’s $2.6 billion plea bargain resolving allegations it helped wealthy Americans avoid paying taxes faces a final hurdle from a federal judge who will decide whether to accept it or throw it out. The first global banking unit in more than a decade to plead guilty to… – Continue reading
Washington, DC – Credit Suisse AG was sentenced today for conspiracy to aid and assist U.S. taxpayers in filing false income tax returns and other documents with the Internal Revenue Service (IRS). Credit Suisse pleaded guilty to conspiracy on May 19. The sentencing of the Swiss corporation is the result… – Continue reading
On September 16, 2014, the Organisation for Economic Cooperation and Development (“OECD”) released seven reports addressing certain aspects of the base erosion and profit shifting (“BEPS”) project. The seven BEPS reports released by the OECD include tax challenges of the digital economy (Action 1), hybrid mismatch arrangements (Action 2), countering… – Continue reading
The FATCA Readiness Self-Assessment Survey indicates companies are not as prepared for the new regulation as they should be. As part of an initiative to better understand client requirements in accordance with FATCA regulation, software development company, Blue Bison recently conducted a FATCA Readiness Self-Assessment Survey among financial institutions across… – Continue reading
People curious to know the amount of “black money” stashed by Indians in foreign banks may be in for yet another disappointment after the Supreme Court monitored Special Investigation Team (SIT), submits its findings. After six months in office, the Narendra Modi Government has not been able to lay its… – Continue reading
A while back we talked about how very complicated it seems to have been for U.S. citizens to avoid taxes on Swiss bank accounts. Here’s a criminal case that New York U.S. Attorney Preet Bharara just brought against a Kentucky resident (OK!) who allegedly did some of that tax avoidance…. – Continue reading
The Central Bank says it is only a matter of time before this country becomes fully compliant with the United States’ Foreign Account Tax Compliance Act (FATCA), which was enacted by the US Congress in March 2010. FACTA is a US law designed to prevent tax evasion by US citizens… – Continue reading
A recent Internal Revenue Service ruling now allows certain individuals to move after tax contributions from a 401(k) or IRA to a Roth IRA on a tax free basis. Fatca has caused local banks to document which of its clients are US citizens or residents and who are not. And… – Continue reading
Small- and medium-sized firms are unprepared for tough new US tax reporting legislation, a survey has found. Software firm Blue Bison, part of the Ignition group of companies, found that more than half of respondents to its readiness survey admitted that understanding the requirements of the Foreign Account Tax Compliance… – Continue reading
U.S. multinational corporations are hoarding an estimated $2 trillion “offshore” to take advantage of a loophole in our tax laws. At our 35 percent top federal corporate tax rate, that represents up to $700 billion in taxes owed but “deferred” because they are “offshore.” This is not imaginary or future… – Continue reading
Nobody likes paying taxes. The rich, however, can reduce the burden more easily than others because capital is more mobile than labour. A clever new paper in the Journal of Economic Perspectives by Gabriel Zucman attempts to measure how much government revenue is lost because of the careful re-routing of… – Continue reading
Barbados has agreed to share information with the U.S. under a new law aimed at preventing offshore tax evasion by American citizens. One of the most controversial laws of the Barack Obama administration, the Foreign Account Tax Compliance Act (FATCA) requires financial firms to report information on U.S. account-holders to… – Continue reading
Former billionaire Samuel Wyly’s Dallas church is taking on the might of the U.S. government for a scrap of the businessman’s remaining fortune. Wyly, who filed for bankruptcy after losing a fraud lawsuit by the Securities and Exchange Commission, owes $20,000 to the Third Church of Christ, Scientist, under a… – Continue reading
Thirty-five-year-old Rocky Martin travelled from his home in Sundre, Alta., to Tijuana, Mexico to get rid of his U.S. citizenship. And he saved himself about $1,800 by doing so. Martin, born in Canada, inherited U.S. citizenship from his mother, who registered him as an American born abroad when he was… – Continue reading
On November 13, 2014, Hong Kong announced that it had signed a Model 2 FATCA IGA. Under the agreement Hong Kong financial institutions will enter into separate FFI agreements with the IRS and will report information on U.S. account holders directly to the IRS. Hong Kong indicated its intention to… – Continue reading
Should London’s Mayor pay U.S. taxes? How about filing FBARs and other forms that make it easy for the IRS to track his bank accounts? London’s Mayor Boris Johnson is English, but being born in New York means he’s American too. Turns out he never gave up his U.S. citizenship,… – Continue reading
Is corporate CEO pay really out of control? Well, consider Fleecing Uncle Sam, a new report from the Institute for Policy Studies and the Center for Effective Government. Of the 100 highest-paid CEOs in the US, the study finds, twenty-nine of them received more compensation than their companies paid in… – Continue reading
The United States has treaty language that allows us to work with the taxing authorities in other countries to collect U.S. taxes owed from U.S. Citizens or their property located in those countries and to allow those countries to have IRS collect from their citizens or property located in the… – Continue reading
(Reuters) – A Swiss banker charged in the United States last year with helping wealthy Americans avoid taxes said in a court filing on Tuesday that he wanted to fight the charges and asked a federal judge to consider his application for bail before he travelled to the United States…. – Continue reading
Earlier today, Treasury and the IRS issued yet another correcting amendment to the previously-issued regulations implementing the Foreign Account Tax Compliance Act (FATCA). FATCA become effective on July 1, 2014, and generally requires participating foreign financial institutions (FFIs) to begin reporting information regarding their U.S. account holders to the U.S…. – Continue reading
Seven of the biggest U.S. corporations received billions of dollars in tax refunds from the Internal Revenue Service, while dolling out an average of US$17.3 million to CEOs. While Congress is set to renew a slew of corporate tax breaks, new research published Tuesday found some of United States’ biggest… – Continue reading
November 18: The Treasury Department and IRS today released for publication in the Federal Register final and temporary regulations (T.D. 9704) concerning the treatment of U.S. and foreign persons that fail to file gain recognition agreements (GRAs) or that fail to satisfy other reporting requirements associated with transfers of property… – Continue reading
CEG says the U.S. corporate tax system is in desperate need of reform A recent report from the Center for Effective Government (Fleecing Uncle Sam) highlights that many large U.S. companies pay little to no corporate taxes, and a few even get tax rebates from the federal government. Moreover, in… – Continue reading
The New York Times’ report on prominent American think tanks receiving some $92 million from a minimum of 63 governments since 2011, prompted Rep. Frank Wolf (R-Va.) to ask Attorney General Eric Holder, a long overdue question: “Should think tanks be allowed to take undisclosed donations from foreign governments?” According… – Continue reading
November 18: The IRS, by releasing a transmittal message, noted that final versions of Form 1099-DIV and the related instructions for 2015 reflect the FATCA filing requirements for certain foreign financial institutions (FFIs). The instructions [PDF 181 KB] to Form 1099-DIV note that beginning in 2014, an FFI with a… – Continue reading
THE GOVERNMENT of Barbados is committed to the implementation of global standards for the supervision and regulation of the international business and financial services sector. This affirmation came today from Minister of Industry, International Business, Commerce and Small Business Development, Donville Inniss, prior to signing a Foreign Account Tax Compliance… – Continue reading
MetLife, Inc. (NYSE:MET) today announced that it had completed the mergers of its subsidiaries MetLife Insurance Company of Connecticut, MetLife Investors USA Insurance Company, MetLife Investors Insurance Company and Exeter Reassurance Company Limited. The merged company has been renamed MetLife Insurance Company USA and is domiciled in Delaware. All necessary… – Continue reading
Fifty-one countries signed the Multilateral Competent Authority Agreement in Berlin on Oct. 29 to fight offshore tax fraud and evasion. The agreement aims to put an end to banking secrecy by sharing tax-related information with member states. Missing from the signatory list are the United States and China. China’s absence… – Continue reading
The limited liability company, or LLC, has become a popular form for organizing a business. Using an LLC generally avoids the double layer of taxation encountered with a corporation while providing limited liability for its members, and offers more flexibility than S corporations in which corporations may not be shareholders. … – Continue reading
A high-profile businesswoman accused of using Cayman Islands bank accounts to dodge more than $7 million in taxes is seeking to challenge the use of information obtained by the U.S. Internal Revenue Service through a tax information exchange request. Cheryl Womack, a Kansas City businesswoman who has a home and… – Continue reading
November 17: The Treasury Department and IRS today released for publication in the Federal Register a correction to a package of final and temporary regulations (T.D. 9657) issued previously in 2014 to harmonize the information reporting and withholding rules under chapters 3 and 61 of the Code to the regulations… – Continue reading
