Category: Jurisdiction

Canada: Treaty Shopping Proposals – A Review Of 2013 And 2014 Developments

In Budget 2013, the Government announced its intention to consult on possible measures to combat treaty shopping. Eleven months later, in Budget 2014, the Government invited comments on a proposed domestic anti-treaty abuse rule. This article briefly reviews developments arising between the two budgets and provides high level comments in… – Continue reading

Govt plan to drop conciliation offer prompted Vodafone arbitration move

Telecom major Vodafone‘s international arbitration notice in its Rs 24,000-crore tax dispute with the government came after the income tax department decided to withdraw its conciliation offer in the matter without waiting for a tribunal’s decision in the transfer pricing case. Officials said the tax department had prepared a Cabinet note to withdraw conciliation on… – Continue reading

United States: Israel Inks Model 1 FATCA IGA

Bloomberg BNA is reporting that Israel has signed a FATCA IGA.  The agreement is a Model 1 agreement, meaning that Israeli financial institutions will will report information about U.S. customers’ accounts to the Israeli  tax authorities, who will then send that information to the IRS. The news comes only a… – Continue reading

Netanyahu included? Israel to punish citizens who hide their money in the US by seizing 50% of concealed funds

Last week, Israel and the US signed an information-sharing agreement for financial assets (primarily bank accounts) belonging to Israeli and US citizens, in an attempt to improve tax enforcement in both countries. “US residents who do not disclose information about accounts they hold in Israel could risk fines of up to 50%… – Continue reading

Israel Enters a FATCA Pact, Concludes Terms of the IGA

Monday, May 5 saw the Finance Ministry of Israel confirm that the US and the Jewish-majority state had concluded the text of an intergovernmental agreement (IGA) for the implementation of the Foreign Account Tax Compliance Act (FATCA). Earlier, with Israel and the US reaching an agreement over sharing of tax… – Continue reading

Alexander Lukashenko approves a draft agreement with USA on compliance with international tax rules

The President of the Republic of Belarus, Alexander Lukashenko, approved a draft agreement between the Government of the Republic of Belarus and the Government of the United States of America on the improvement of compliance with international tax rules and the implementation of the Foreign Account Tax Compliance Act (FATCA) as a basis… – Continue reading

Belize – Fiscal Paradise with High Level of Confidentiality

An IBC is the most popular type of offshore corporation as it is designed for any international business activity, does not pay any taxes in the jurisdiction where is established, provides confidentiality to its owners and is not subject to reporting requirements. “According to different lists of international organizations, there… – Continue reading

Tax tip: Amnesty time

The tax office has announced an amnesty for taxpayers with unreported offshore financial activities, codenamed Project DO IT (disclose offshore income today). Among the transactions it’s interested in are interest income from offshore bank accounts, undeclared capital gains on overseas assets and ongoing income flows from businesses owned overseas. Though… – Continue reading

iCreate and Convey team up to help global banks fast-track FATCA compliance

• Partnership creates end-to-end solution for enabling and ensuring FATCA compliance, including: data consolidation, indicia identification, additional KYC data/document capture, alerts/notifications and dashboards to monitor compliance, withholding calculations and remittance, and tax reporting. Banking analytics, risk and compliance pioneer, iCreate, today announced a strategic partnership with tax information reporting leader,… – Continue reading

Belize – Fiscal Paradise with High Level of Confidentiality

ICO Services, the international company specialized in the formation of offshore companies and offshore banking, has recently expanded their services to the American business world by launching their service of setting up a company in Belize, the only fiscal paradise in Central and South America where English is the official… – Continue reading

Multinationals escape tax due to ‘exceptional’ rules, study claims

Large subsidiaries of multinationals, such as Apple and Google, which are based in Ireland are able to escape paying corporation tax due to an “exceptional” interpretation of tax laws by the Revenue Commissioners, a new study claims. A research paper by James Stewart, associate professor in finance at Trinity College… – Continue reading

Pakistan Warns Banks To Register For FATCA

Because of a delay in the negotiation of an intergovernmental agreement (IGA) to implement the Foreign Account Tax Compliance Act (FATCA), the State Bank of Pakistan (SBP) advised Pakistani financial institutions, as a precaution, to complete registration with the United States Internal Revenue Service (IRS) by May 5, 2014, at… – Continue reading

Finance Says Kuwait Joins US FATCA In Substance

Ministry Asks Cabinet To Issue Decree   KUWAIT CITY, May 4, (KUNA): The Ministry of Finance has announced that the State of Kuwait joined the list of countries which agreed initially in substance on the FATCA (Intergovernmental Agreement). The Ministry disclosed that they have agreed on substance regarding the FATCA… – Continue reading

Cayman Islands, Belgium Sign Tax Information Exchange Agreement

The Cayman Islands and Belgium have officially signed a tax information exchange agreement. Cayman Financial Services Minister Wayne Panton and Belgian Ambassador Godelieve Van den Bergh signed the agreement last week at the Government Administration Building in Grand Cayman. The tax information exchange agreement is the 35th into which the… – Continue reading

Cayman Islands: A Legal Overview Of M&A In The Cayman Islands And British Virgin Islands

Against global trends, gradual growth in both the Cayman Islands and the British Virgin Islands (“BVI”) merger and acquisition (“M&A”) activity continued through 2013, led by flagship deals in both established and emerging markets. The flexibility, certainty and efficiency of the statutory merger regimes make both of these leading offshore… – Continue reading

U.S. plans to unleash IRS on Russian banks

Washington • As the United States attempts to punish Russia for its actions in Ukraine, the Treasury Department is deploying an economic weapon that could prove more costly than sanctions: the Internal Revenue Service. This summer, the U.S. plans to start using a new law that will make it more… – Continue reading

Centre gives names of all account holders in Liechtenstein Bank to Supreme Court

NEW DELHI: After resisting for more than three years, the Centre on Tuesday revealed names of 18 people in the Supreme Court who allegedly stashed black money with LST bank in Liechtenstein and against whom prosecution have been launched by the income tax department. Centre also placed in a sealed… – Continue reading

British Virgin Islands: BVI FATCA – Update US And UK

United States Intergovernmental Agreement The British Virgin Islands (“BVI”) Government on 6 March 2014 initialled a “Model 1 intergovernmental agreement” (the “BVI-US IGA”) with the government of the United States of America with respect to the “Foreign Account Tax Compliance Act” provisions of the Internal Revenue Code (“FATCA”), designed to… – Continue reading

Singapore, U.S. Reach Deal on Tax-Evasion Law

SINGAPORE–Financial institutions based in Singapore will need to regularly report information on U.S.-owned financial accounts, after the Asian financial center agrees a deal that would help the U.S. curb offshore tax evasion. The move is part of Singapore’s push to toughen mechanisms for tackling cross-border tax offenses, as it emerges… – Continue reading

Australia signs FATCA agreement

Australia has signed an intergovernmental agreement (IGA) with the US in order to “reduce the burden” on financial institutions when complying with FATCA. Australian treasurer Joe Hockey said the IGA will “minimise costs” by simplifying due diligence requirements, as well as broadening arrangements between the Australian Tax Office and the… – Continue reading

Oman, Spain sign agreements

MoUs cover defence, tourism, archives and double taxation — MUSCAT — Oman and the Kingdom of Spain signed a memorandum of understanding (MoU) in the field of archive and documentation at Al Alam Palace within the framework of the Spanish monarch’s visit to the Sultanate, yesterday. The Government of Oman… – Continue reading

Tax pact with Japan effective May 22

The Tax Information Exchange Agreement (TIEA) signed by Macau and Japan comes into force on May 22, the Ministry of Finance of Japan said in a press release published yesterday. Starting from May 22, both contracting parties can request information for criminal tax matters without regard to the taxable year… – Continue reading

India’s top court told names of 26 alleged tax evaders with bank accounts in Liechtenstein

New Delhi – The government Tuesday disclosed to the Supreme Court the names of 26 people who had accounts in banks in Liechtenstein, revealed to India by German authorities. A bench of Justice H.L.Dattu, Justice Ranjana Prakash Desai and Justice Madan B. Lokur were given these names by Solicitor General… – Continue reading

NRIs’ India MF play to get thin as US Fatca kicks in

Heavy compliance cost may render equity purchases in mother country not worth their while Indians residing in America might, from July, find it tough to invest in products offered by the Indian mutual fund (MF) sector. The Foreign Account Tax Compliance Act (Fatca), that country’s new anti-tax evasion law, which takes effect… – Continue reading

FATCA

The IRS announced on 2 April 2014, that the deadline for foreign financial institutions registering for a GIIN, in order to appear on the first issued IRS list of foreign financial institutions, has been pushed out from 25 April 2014 to 5 May 2014. They have also indicated that registrations… – Continue reading

Australia and US pen FATCA agreement

The federal government has entered into an intergovernmental agreement with the United States to “reduce the burden on Australian financial institutions” in complying with the US Foreign Account Tax Compliance Act. Treasurer Joe Hockey announced yesterday that the agreement with the US government has been completed, heralding ramifications for “a… – Continue reading

Guernsey: Stepping Up To FATCA

Laila Arstall of Carey Olsen charts Guernsey’s path to automatic exchange of information. In 2013, UK Prime Minister David Cameron turned the political spotlight on international tax compliance, with his focus on trade, tax and transparency at the World Economic Forum in Davos. He was riding the current trend towards… – Continue reading

Singaporean DTA With Barbados In Force

The double taxation agreement (DTA) between Singapore and Barbados came into force on April 25, 2014, after the completion of ratification procedures by both sides. The DTA is intended to boost cross-border trade and investment between Singapore and Barbados by providing greater clarity on both parties’ taxing rights to ensure… – Continue reading