Category: Jurisdiction

What Does Closing the ‘Double Irish’ Tax Loophole Mean for Pharma?

As the Irish government considers closing an infamous tax loophole for corporations, Wall Street has been scrambling to gauge the effect on the pharmaceutical industry. So far, the prognosis seems that damage will largely be minimal. Known as the ‘Double Irish,’ the loophole allows companies to send royalty payments for… – Continue reading

Bringing back black money: Swiss promise India details in time-bound manner

erne/New Delhi: In a major breakthrough in India’s fight against black money allegedly stashed abroad, Switzerland today said it will examine Indian requests for banking information on a priority basis and provide requested details in a time-bound manner. The Swiss authorities would also “assist in obtaining confirmation on genuineness of… – Continue reading

Fourth protocol to Canada-UK Treaty eliminates withholding tax on arm’s length interest, but preserves tax exemption for gains on disposition of shares and interests deriving value from Canadian real property

On July 21, 2014, the governments of Canada and the United Kingdom signed the fourth protocol (Protocol) amending the Convention between the Government of Canada and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion… – Continue reading

Isle of Man: Crypto-Currencies And The Isle Of Man

The Isle of Man is showing great enthusiasm for crypto-currencies – from the landlord at a popular Douglas drinking hole to the Lieutenant Governor, everyone is talking about digital currency and the potentially huge benefits to the Island. The Isle of Man Financial Supervision Commission (FSC) has announced plans to… – Continue reading

Harper Government Strengthens Tax Collaboration with India

Minister Findlay meets with Indian counterpart during trade mission to India DELHI, INDIA–(Marketwired – Oct. 15, 2014) – Canada Revenue Agency The Honourable Kerry-Lynne D. Findlay, P.C., Q.C., M.P., Minister of National Revenue, met today with Nirmala Sitharaman, India’s Minister of State for Commerce and Industry and Minister of State… – Continue reading

Steris, the latest to renounce U.S. Citizenship, Only Paid a 16.3% Tax Rate Over Three Years

After announcing Ohio-based Steris Co.’s plans to become British for tax purposes on Monday, CEO Walter Rosenbrough later said on a conference call, “We’re not typically users of aggressive tax policies and I don’t think we are here.” That’s his story, and he’s sticking to it. But even a cursory… – Continue reading

Time to Make Corporations Pay Taxes They’re Avoiding

Blue-ribbon corporations are deserting our country “to avoid paying taxes but expect to keep receiving the full array of benefits that being American confers, and that everyone else is paying for,” Fortune magazine reports. That’s right, Fortune wrote it; not Pravda. In a scathing article titled “Positively Un-American” by Allan… – Continue reading

Wealth Inequality Accelerates Worldwide on Inheritance, Tax Avoidance

Wealth inequality is growing worldwide, according to a new report by Credit Suisse. A greater share of wealth is being held by a smaller number of ultra-rich families worldwide as larger inheritances, family trusts, and similar arrangements to avoid taxes help the ultra-wealthy gain a greater portion of total capital… – Continue reading

3rd LD Writethru: EU FinMins agree on taxation information exchange

LUXEMBOURG, Oct. 14 (Xinhua) — EU finance minister meeting concluded on Tuesday with breakthrough in taxation exchange information to fight against tax avoidance. Italian finance minister Pietro Carlo Padoan, whose country holds the presidency of the EU, told press after the meeting that the EU has planned to build a… – Continue reading

Tokyo District Court Allows Tax Saving from Share Repurchase

On May 9, 2014, the Tokyo District Court reversed a large tax that had been imposed on a large U.S. multinational’s Japanese holding company (“Japan HoldCo”). Under the Japanese Corporate Tax Law, if a shareholder returns shares to an issuing company (i.e., the issuing company acquires treasury shares), a portion… – Continue reading

Freeman Tax Law Is The Keynote Speaker About FATCA At The American Chamber Of Commerce In Shanghai

The presentation on October 17, 2014 will discuss how FATCA has changed the world and provide perspectives for financial institutions and expatriates  SHANGHAI, China, Oct. 14, 2014 (GLOBE NEWSWIRE) — via PRWEB – As of June 30, 2014 China has signed Model 1 IGA (Intergovernmental Agreement) in cooperation with FATCA… – Continue reading

Malta Holding Companies 2014/15

Malta, like Cyprus, has been obliged to dismantle its old ‘offshore’ companies regime as a trade-off for joining the European Union. EU membership has, however, brought about certain benefits for Maltese companies trading across borders, and, coupled with investment-friendly government policies and some interesting tax planning opportunities, Malta remains one… – Continue reading

Firms Expect Transfer Pricing Policy Impact From BEPS Project

A vast majority of companies headquartered in the United States expect increased scrutiny of their transfer pricing practices in the short-term as a result of the Organisation for Economic Cooperation and Development’s (OECD’s) base erosion and profit shifting (BEPS) project. A recent EY survey, Connecting The Dots, concluded that 30… – Continue reading

Monaco Signs OECD Multilateral Tax Convention

Monaco has become the 84th jurisdiction to commit to strengthen international tax cooperation through its participation in the Multilateral Convention on Mutual Administrative Assistance in Tax Matters. Welcoming the signing by José Badia, Monaco’s Minister for Foreign Affairs and Cooperation, the Organisation for Economic Cooperation and Development’s (OECD’s) Secretary-General, Angel… – Continue reading

International tax avoidance: Is it eroding Canada’s tax base and how should we respond?

TORONTO , Oct. 2, 2014 /CNW/ – Aggressive international corporate tax avoidance by multinational corporations has become the subject of intense political scrutiny. U.S. politicians have called out some American multinationals, including Apple, Amazon, Starbucks and Google, for relocating profits abroad to avoid U.S. taxes. More recently, politicians accused Burger… – Continue reading

Tax-Lowering Deals Keep Coming as Steris Unfazed

The U.S. government’s attempt to prevent companies from seeking a tax address outside the country hasn’t stopped Steris Corp. (STE) The Mentor, Ohio-based provider of hospital sterilization products and services announced today that it will buy the smaller Synergy Health Plc (SYR) and establish the combined company’s tax address to… – Continue reading

Can the EU tame the multi-national tax dodgers? Why Europe wants to turn the screw on the big guns

The screw is being turned on American companies that use complex structures to whittle down their tax bills. But is the latest EU probe a paper tiger or a game changer? It was supposed to be good news. Amazon’s announcement yesterday that it would hire 1,000 staff was dressed up… – Continue reading

AbbVie Says It Reconsidering Deal With Shire

The drugmaker AbbVie said Tuesday it is having second thoughts about its deal to combine with British counterpart Shire after the U.S. government created new limitations on the tax benefits of incorporating overseas. North Chicago, Illinois-based AbbVie said it notified Shire that its board intends to reconsider the recommendation it… – Continue reading

UPDATE 3-Ireland calls time on austerity, “Double Irish” tax dodge

* Ireland to end tax regime that saved multinationals billions * Swift upturn ushers in tax cuts rather than austerity * Government faces backlash over uneven nature of recovery (Adds finance minister interview, Google comment) By Padraic Halpin and Conor Humphries DUBLIN, Oct 14 (Reuters) – Ireland will phase out… – Continue reading

Alleged mastermind of UBS tax evasion scheme faces trial

(Reuters) – Former UBS bank executive Raoul Weil was the mastermind of the Swiss bank’s illegal offshore operations that helped thousands of Americans evade taxes, prosecutors said at the start of his federal trial on Tuesday. Weil, 54, was the third-highest ranked executive at the Zurich-based wealth management firm and… – Continue reading

After years of pressure, Luxembourg drops bank secrecy rules

(Reuters) – Luxembourg agreed on Tuesday to end its bank secrecy rules from 2017, yielding to a decade of pressure from Germany and the United States and marking a breakthrough in global efforts to reduce tax evasion. Luxembourg, whose banks hold deposits worth 10 times the nation’s annual economic output,… – Continue reading

IRS Loosens Deadline for Banks to Document Foreign Status Under FATCA

Oct. 10 — Withholding agents and foreign financial institutions will be given extra time to comply with requirements for determining an account holder’s foreign status, the IRS said. The Internal Revenue Service, in Notice 2014-59 issued Oct. 10, said withholding agents, foreign financial institutions and payers have until Jan. 1,… – Continue reading

Swiss pledge to review business taxation

The Swiss finance minister, Eveline Widmer-Schlumpf, and her counterparts from European Union member states have signed a joint statement aimed at ending a controversy over corporate taxes. The declaration, signed in Luxembourg on Tuesday, includes the Swiss government’s plans to push ahead with abolishing certain preferential tax regimes for foreign… – Continue reading

Tax relief scheme for tech firms under threat from Europe

Hitech firms are being warned that they should take advantage of tax relief on patent related profits now before a threatened clamp down by the European Union according to Richard Hopes, Partner at Alliotts accountants based in Surrey and London. Richard Hopes, Partner at Alliotts accountants and a specialist in… – Continue reading

The Big Picture: Wealth and Estate Planning in Argentina

It is said that Argentina faces an economic and political crisis every 10 years. Whenever a crisis arises, Argentinians’ right of ownership is at risk. Devaluation, asymmetric pesification and the current foreign exchange restrictions are a few examples of the challenges we face. What’s more, according to a recent OECD… – Continue reading

What fund managers need to know about FATCA

Fund managers dealing with funds in Model 1 IGA countries must start focusing now on the application of FATCA to these funds. The U.S. Foreign Account Tax Compliance Act (“FATCA”) is becoming a reality. Fund managers around the world over are facing requests from U.S. withholding agents for FATCA documentation… – Continue reading

Put Another Notch in the DOJ Gun

In the history of the old west when gun fighters survived a gun fight they might put a “notch” in their pistol as a badge of honor. Well the U.S. Department of Justice can put another notch in its weapon of choice, threat of prosecution” because Deutsche Banks’ Swiss unit… – Continue reading

Changes made to IRS streamlined offshore compliance procedures

The IRS updated its streamlined offshore compliance program to provide procedures taxpayers residing both inside and outside the United States should use to participate in the program. The streamlined offshore compliance program is for taxpayers whose failure to comply with requirements to report offshore assets is nonwillful. It is designed… – Continue reading