Wright Medical Group Inc. (WMGI), a U.S. maker of bone implants, will merge with Tornier NV, creating a new company valued at $3.3 billion in the latest proposed tax inversion since tighter rules were announced last month. The legal address for the new company, to be called Wright Medical Group… – Continue reading
(Bloomberg) — The U.S. attempt to stop companies from leaving the country for tax reasons won’t stop Pfizer Inc., which is still considering a deal to move America’s biggest drugmaker abroad, said Chief Executive Officer Ian Read. “I see no reason why we wouldn’t be able to do an inversion,”… – Continue reading
The secret binder lay wedged in a hidden drawer inside a filing cabinet in his office on the Bahnhofstrasse in Zurich, the heart of the world of Swiss private banking. Martin Liechti, a former top private banker at Swiss bank giant UBS, privately called the binder his “CYA file,” a… – Continue reading
Here in America, tax collectors know when you earn interest on your bank deposits. That’s because U.S. banks are obliged to collect such information and report it to the IRS. This makes it impractical for would-be tax evaders to purposefully underreport their interest income for tax purposes. They’d be easily… – Continue reading
At the Justice Department, senior officials like to congratulate themselves on the headline-making, big bucks settlements they have imposed upon banks and lenders for their part in causing the 2008 mortgage meltdown that sparked the biggest American financial crisis since the Great Depression. But wait a moment. Those settlement figures… – Continue reading
NEW YORK–(BUSINESS WIRE)–Tax inversion deals have effectively been repriced by the US Treasury signaling an end to “hop-scotch” loans and other tax structuring opportunities, according to Fitch Ratings. AbbVie’s purchase of Shire and the planned merger of Salix Pharmaceuticals and Cosmo Technologies, both pulled since the Treasury announcement, were scuttled… – Continue reading
Finance ministers from at least 37 countries will take the biggest step yet in fighting tax evasion at a conference this week hosted by Germany’s Wolfgang Schaeuble, German officials said. Fifty states and jurisdictions are sending representatives to Berlin to sign an agreement on Oct. 29 on the automatic exchange… – Continue reading
There is nothing illegal about tax planning. Yet some things are legal while others are not, and the lines can sometimes get fuzzy. Add to that the fact that some people go to extraordinary lengths to avoid paying taxes, and it can be a recipe for disaster. Increasingly, if you… – Continue reading
An informed, mature and realistic debate on black money is too much to ask for in a country where the issue attracts intense, almost emotional public reaction. It does not help when political games and systemic problems in the economy that aid tax evasion and stashing of illicit money in… – Continue reading
73 per cent of Americans who live outside the U.S. are tempted to give up their U.S. passports in response to the introduction of FATCA (Foreign Account Tax Compliance Act), reveals a new survey by one of the world’s largest independent financial advisory organizations. The findings come as Federal Register… – Continue reading
The number of Americans renouncing U.S. citizenship increased 39 percent in the three months through September after rules that make it harder to hide assets from tax authorities came into force. People giving up their nationality at U.S. embassies increased to 776 in the third quarter, from 560 in the… – Continue reading
The Treasury Department has spent millions of dollars on federal contracts for companies that have shifted their legal address abroad, even as the Obama administration pushes to rein in the practice. Just last month, Treasury Secretary Jack Lew moved to limit the appeal of those tax deals, known as inversions,… – Continue reading
Significant numbers of people are continuing to renounce their U.S. citizenship or end their long-term U.S. residency. There are 776 names on the Treasury Department list published Friday for the third quarter of 2014. That’s the third highest quarterly figure ever, according to Andrew Mitchel, an international tax lawyer in… – Continue reading
The sovereignty of individual nations is increasingly under threat from international governance bodies that want to force a range of new regional and international taxes on states. The latest attempt to bypass state sovereignty occurred when the World Health Organization (WHO) met behind closed doors in Moscow last week. In… – Continue reading
Introduction The economy has come to the forefront of the Second U.S. House District race between incumbent Democrat Dave Loebsack and Republican challenger Dr. Mariannette Miller-Meeks. Loebsack’s campaign accuses Miller-Meeks of being in favor of “special tax breaks to outsourcing corporations” and claims she partnered with a company that sent… – Continue reading
(Reuters) – Lawyers representing 73 Swiss banks seeking to avoid a tax-evasion probe by U.S. authorities wrote a letter to the U.S. Department of Justice raising questions over a dozen demands, including the banks’ cooperation with other nations. In the letter dated Oct. 21, the lawyers questioned the terms of… – Continue reading
The Swiss Federal Council has launched a consultation on legislation for the unilateral application of the Organisation for Economic Cooperation and Development’s (OECD’s) Standard on the Exchange of Information to all double tax agreements that are not already in line with this model. The legislation would only involve the exchange… – Continue reading
One of the stories that firms deserting our country like to tell is that by moving their corporate domicile (but not their actual headquarters) outside U.S. borders to duck taxes, they will be able to use cash they have parked offshore to expand their operations in the United States. So… – Continue reading
There’s no doubt the arms length principle has holes, and it may be the time to reconsider the way governments approach transfer pricing Amazon, Fiat, Vodafone, Starbucks, Apple… The list of companies facing scrutiny for their failure to properly implement the arms length principle into their transfer pricing policies this… – Continue reading
With the announced end of banking secrecy for non-residents, the time has come to make use of favourable repatriation schemes, such as the voluntary disclosure regime in Italy. Despite increasing pressure for fiscal transparency and exchange of information, beneficial owners still have a choice: move the capital out (of Luxembourg),… – Continue reading
Since all economic theories – even Marxism and socialism – recognize that capital formation is a key to long-run growth, higher wages, and improved living standards, it obviously doesn’t make sense to penalize saving and investment. Yet that’s exactly what happens because of double taxation in the United States, as… – Continue reading
On October 14, 2014, the Irish Minister for Finance released proposals as part of the 2015 Irish Budget that would cause Irish incorporated non-resident (“INR”) companies to be treated as tax resident in Ireland beginning January 1, 2015. The goal is to shut down the use of so-called “Double Irish”… – Continue reading
Wednesday, October 22, 2014 – The BVI Advantage was the theme of a feature presentation at the recent China Offshore Summit. The summit was held from October 15-16 in Shanghai, China. Global Head of BVI Practice at Maples and Calder, Mr. Michael Gagie presented on behalf of the BVI International… – Continue reading
“The issue of substance and taxation is, and always will be, a core column of the Irish taxation system,” Michael Noonan, Ireland’s Finance Minister, said at his Department’s Tax Policy Conference on October 21, 2014, underscoring that Ireland’s strategy is to play fair but play to win. Beginning by discussing… – Continue reading
Countries that work together like Ireland and the US “need to be cognisant” of the impact their tax policies have on each other, new US Ambassador to Ireland Kevin O’Malley said in a speech yesterday. He said cross-border mergers can make the Irish and American economies stronger, but that “these… – Continue reading
Around $180 million in undeclared offshore income has now been recovered as part of the amnesty, the ATO said. A further $1 billion in assets has also been recovered. Photo: Louie Douvis The Tax Office is keeping a close eye on foreign banks as part of its push to stop… – Continue reading
On June 18, 2014, the Internal Revenue Service introduced significant changes to both its Offshore Voluntary Disclosure Program (OVDP) and its Streamlined Filing Compliance Procedures (Streamlined) and posted updated Frequently Asked Questions on its website.1 These changes apply to new OVDP “submissions” (which most practitioners believe refer to the Offshore… – Continue reading
(Reuters) – A key witness in the federal tax evasion trial of a top Swiss bank executive took the stand on Thursday to testify against his former boss, Raoul Weil, who is accused of conspiring to conceal up to $20 billion in U.S. taxpayers’ assets in secret offshore accounts. The… – Continue reading
The number of companies lobbying the U.S. government on tax inversions more than doubled in the quarter ended Sept. 30, as they sought to prevent Congress and the Obama administration from imposing new restrictions. Novartis AG (NOVN), SAP SE, and Eaton Corp Plc (ETN) were among companies that began lobbying… – Continue reading
Corporate tax “inversion” deals became a prime target this year of President Barack Obama, as part of his running theme that many U.S. corporations are stealing from Americans by not paying their fair share. After the August announcement of Burger King’s plans to merge with Canada-based Tim Hortons, the administration… – Continue reading
Democratic House and Senate candidates seem likely to lose the votes of a large constituency they rarely think about over a law that most Americans have never heard of. The issue is FATCA — the Foreign Account Tax Compliance Act — passed by Congress and signed into law in 2010…. – Continue reading
For now, while the benefit for American corporations to buy or merge and move overseas may be over, as evidenced by AbbVie cancelling its merger with Shire Pharmaceutical, that doesn’t mean that consolidation within the industry is through. A new research report from Merrill Lynch features three top companies, dubbed… – Continue reading
The lower house of Parliament has approved legislation that allows the exchange of information about banking accounts with other countries. The bill is a prerequisite for the implementation of the FATCA agreement with the United States which will require Czech financial institutions to inform US authorities about account owned by… – Continue reading
If the house always wins, then the taxman isn’t far behind – at least not during the last year. Inland Revenue won outright almost 85 per cent of litigation it was in over the 12 months to June 30 – its highest rate of success since at least 2010. It… – Continue reading
Facebook was today facing a fresh row over offshore tax avoidance as UK accounts showed it paid no corporation tax for the second year in a row while granting shares worth tens of millions of pounds to London staff. Research firm eMarketer estimates Facebook’s London operation in Euston made £371… – Continue reading
Oct. 20 — U.S. insurance companies don’t like the extra reporting burdens their overseas operations are facing under the Foreign Account Tax Compliance Act combined with existing requirements. The industry is asking the Internal Revenue Service to lighten that burden, asserting that the layers of reporting now being imposed could… – Continue reading
Standard Chartered has notified thousands of UAE small and medium enterprise customers it is closing their accounts as it responds to pressure from US regulators to cut its risks following an anti-money laundering settlement. “We regret to notify you that Standard Chartered Bank will no longer be able to provide… – Continue reading
Samuel Wyly, the U.S. businessman who may have to forfeit as much as $400 million after being found liable for using offshore trusts to hide stock holdings and make illegal trades, filed for bankruptcy. Wyly, 80, listed assets and debt of $100 million to $500 million each in a Chapter… – Continue reading
As of July 1, 2014, the Internal Revenue Service (IRS) has implemented several changes to the streamlined filing procedures for offshore compliance, as well as the Offshore Voluntary Disclosure Program (OVDP). These programs provide taxpayers with offshore assets an avenue to bring their tax obligations into compliance. The expanded programs… – Continue reading
The U.S. government’s move to hamper tax-inversion deals is good for the drug industry because it forces companies to focus on intrinsic business reasons for transactions, Actelion Ltd. Chief Executive Officer Jean-Paul Clozel said. Since the U.S. Treasury said last month that it would tighten tax rules, three of eight… – Continue reading
Senate Finance Committee Chairman Ron Wyden has indicated that, as companies appear to be reconsidering inversions following the administrative measures put forward by the Treasury Department last month, he is focused on reforming the US tax code, rather than pressing for immediate anti-inversion legislation. “While it looks like the rush… – Continue reading
Background The Foreign Account Tax Compliance Act, commonly known as FATCA, was signed into law on March 18, 2010. FATCA generally requires U.S. withholding agents to withhold tax at a 30 percent rate on certain U.S. payments to a foreign financial institution (“FFI”) unless the FFI has entered into an… – Continue reading
AbbVie Inc. (ABBV) and Shire Plc agreed to terminate what would have been the biggest U.S. tax inversion after AbbVie pulled its support for the deal in the wake of proposed changes to U.S. rules governing such transactions. AbbVie, based in North Chicago, Illinois, planned to buy Shire for an… – Continue reading
Echegaray says account holders can take part in country’s fiscal amnesty If Argentines who hold 4,040 undeclared bank accounts in Switzerland don’t normalize their fiscal status and pay their debts, the AFIP tax bureau will file a complaint before the Office of Economic Crime and Money-Laundering (PROCELAC) requesting it investigates… – Continue reading
Foreign structures are tempting targets for governments, says Vanessa Houlder. When governments around the world embarked on a drive to plug tax loopholes in 2012, the urgency of the move was underpinned by rising tensions over austerity and inequality. Widespread public outrage over alleged tax-dodging by wealthy individuals and multinationals… – Continue reading
DALLAS (CN) – Former Texas billionaire Sam Wyly filed for bankruptcy protection after a federal jury ordered him to pay as much as $400 million for using offshore trusts to hide stock trades. A noted philanthropist and contributor to Republican causes, Wyly, 77, of Dallas, made his fortune… – Continue reading
If you are a US taxpayer with overseas bank accounts or investments, you need to take immediate steps to show you are reporting your overseas earnings to avoid tax penalties under Foreign Account Tax Compliance Act (FATCA). Now FATCA is in full swing with foreign financial institutions filing reports on… – Continue reading
The Organization for Economic Cooperation and Development’s (OECD) plan for base erosion and profit shifting (BEPS) is already affecting corporations, according to speakers participating in a Captive Insurance Companies Association (CICA) transfer pricing webinar. Polling results during the webinar revealed attendees’ opinions were in line with tax industry surveys indicating… – Continue reading
The tide of tax inversions has started to recede, taking with it a substitute for real growth at some of our biggest companies. AbbVie Inc. just decided to bail out of an acquisition that would have moved its headquarters overseas where corporate tax rates are lower than U.S. rates. AbbVie… – Continue reading
Dividend represents a share of the company’s post-tax profit that is divided among its shareholders. In other words, once corporate tax has been paid on profit, the remaining earnings are distributed amongst shareholders as dividend. So far, so good. Then, this dividend is characterised as income in the hands of… – Continue reading
