Category: Brazil

OECD lists the top 10 toughest countries on tax evasion

The Organisation for Economic Cooperation and Development (OECD) is behind the new measures to automatically exchange tax information between nations and manage the differences on how tax issues are dealt with. Top ten countries The contractor management specialist CXC Global has identified the ten countries with the most aggressive approach… – Continue reading

Brazil: Tax Information Exchange Agreement With Brazil

On December 29, 2014, Uruguayan Congress ratified the Tax Information Exchange Agreement entered into between Uruguay and Brazil (“the TIEA”). The TIEA is patterned after the OECD Model. The Contracting Parties undertake to cooperate with each other through the exchange of any information which might be foreseeably relevant for tax… – Continue reading

Brazil: BEPS: Rule Of Law Can Avoid Mountains And Cloudy Skies For Companies

The tax world followed with great interest today´s launch of the final package of BEPS. Having the BEPS report finalized is indeed a great achievement and, as pointed out by Mr. Angel Gurría, OECD Secretary General, in his Twitter, “Agreement of #BEPS package is a historic day in our effort… – Continue reading

Internal Revenue Service Begins Reciprocal Automatic Exchange of Tax Information Under FATCA IGAs

On October 2, 2015, the Internal Revenue Service announced that it had achieved a key milestone in implementation of the Foreign Account Tax Compliance Act (FATCA), a critical anti-tax evasion law passed by Congress in 2010 but not fully implemented until July 2014. The milestone announced by the IRS was… – Continue reading

It’s Here; The Automatic Exchange of Information Under FATCA Began September 30th

The IRS has announced that as of September 30, 2015 it will implement the automatic exchange of tax information as set forth in the Foreign Account Tax Compliance Act, (FATCA). The IRS Commissioner in announcing the implementation of the automatic exchange of information stated: “This information exchange is part of… – Continue reading

US Has World’s Third-Highest Corporate Tax Rate

Not only does the United States retain the dubious distinction of having the highest corporate tax rate in the Organisation for Economic Cooperation and Development country grouping, it now has the third-highest rate of corporate tax in the world, according to the Tax Foundation. The non-partisan tax policy think tank… – Continue reading

US Treasury Department adds India to its FATCA list

MUMBAI: The US Treasury Department has issued a list of 34 countries which includes India with whom it would share information under FATCA (foreign account tax compliance act) regulations. The pact aims to cover automatic sharing of information on bank accounts and other instruments like mutual funds, insurance and equities… – Continue reading

Austria: Successful Appeal Regarding Taxation Of Foreign Interest Income

On 26 February 2015, the Austrian Supreme Administrative Court decided in favor of an appeal filed by WOLF THEISS for a client who received tax exempt interest income from other countries. An Austrian taxpayer received interest from Greek, Brazilian and Argentinian government bonds between 2003 and 2007. According to the… – Continue reading

Untapped funds can help pay for Sustainable Development Goals

Development Goals (SDGs) but poorer countries should exercise caution when borrowing money, Gail Hurley, a development finance expert with the UN Development Program (UNDP), told Xinhua. “There’s a lot more finance available now—public and private, domestic and international — (but) a lot of it is loan finance, so we do… – Continue reading

American Dream Relocates to Bermuda, Says Fishman, Blaming Taxes

Jay Fishman, who built New York-based Travelers Cos. into one of the world’s biggest insurers, lamented that disparities in tax rates are pushing established rivals and industry newcomers outside the U.S. Over the past 15 years or so, “we’ve counted 10, 12, maybe even 15 Bermuda-based startups that ultimately became… – Continue reading

Brazil’s BTG Open to More Swiss Private-Banking Acquisitions

(Bloomberg) — Grupo BTG Pactual, the only publicly traded investment bank in Brazil, said it’s willing to consider more acquisitions in Switzerland after completing the purchase of BSI, the Swiss private-banking unit of Assicurazioni Generali SpA. “We are looking. We are always looking,” Renato Cohn, a BTG partner and member… – Continue reading

Venezuelan President’s Visit to China Indicative of Growing Sino-Latin American Trade and Opportunities

On September 1, Venezuelan President Nicolas Maduro arrived to Beijing in an effort to strengthen economic ties between Venezuela and China. In his second visit this year, the Venezuelan President signed a number of deals that will strengthen cooperation in new areas beyond the current focus on the oil industry…. – Continue reading

Another FC Barcelona Star Could Face Tax Evasion Charges Despite Paying Up

Superstar-laden FC Barcelona might be among the top teams in the Spanish Liga BBVA this season but the team is making news – again – for a more undesirable reason: tax investigations. As Lionel Messi awaits trial on tax evasion charges, another Barcelona star may be joining him. Spanish news… – Continue reading

Transfer pricing remains thorny issue for international trade

Multinational companies are facing far more expansive and complex audits by tax authorities fighting over the same pot of profits as budget deficits continue to increase, reports BD Live. An inevitable outcome of efforts globally to prevent tax bases from erosion is double taxation and increased disputes over adjusted assessments… – Continue reading

Managing the transfer pricing of intangibles in the oil and gas sector

Intangible assets in the oil and gas industry have become incredibly valuable. Taxpayers need to understand how to manage compliance to mitigate their transfer pricing risks What do recent Western economic sanctions against Russia; the US’ growing energy independence; and ultra-deepwater oil and gas (O&G) discoveries off the coast of… – Continue reading

U.S. Expatriates Find Financial and Tax Planning in Rio: Sponsored

Amit Ramnani, director of Ipanema Wealth, an independent financial consultancy firm, discusses the key issues facing U.S. expatriates. RIO DE JANEIRO, BRAZIL – Many United States citizens living overseas are unaware of the potential tax liabilities they could be facing in near future. To help out the Rio-based firm Ipanema… – Continue reading

Brazil Ruling No. 1,580/2015: changes in the deadline for filing the electronic financial return (“e-Financeira”)

On August 17th, 2015, Ruling No. 1,580/2015 was published, containing amendments to Ruling No. 1,571/2015 concerning the “e-Financeira”, which is the tax return to be filed for the purpose of informing financial transactions of interest to the Federal Revenue Office. The deadline for filing the e-Financeira, in relation to triggering… – Continue reading

The critical importance of the Cayman Islands to the U.S. economy

In May of 2012, and soon before Facebook’s IPO, Eduardo Saverin renounced his U.S. citizenship. Saverin was a co-founder of the social-networking site, and the consensus was that he gave up his citizenship to avoid U.S. taxes that would be levied after the offering. Saverin was widely denounced for his… – Continue reading

Brazilian taxpayers now required to disclose tax planning structures

The July 21 edition of the Brazilian Official Gazette contained provisional measure 685 (PM 685), which creates an obligation on taxpayers to formally report to tax authorities certain transactions that result in tax benefits. The requirement is supposedly in line with the OECD’s base erosion and profit shifting (BEPS) project… – Continue reading

“Fatca Relief Coming for U.S. Expats” (The Wall Street Journal)

Financial Adviser Jonathan Lachowitz of White Lighthouse Investment Management published the following editorial regarding FATCA on the The Wall Street Journal on Tuesday July 28th: Managing personal financial issues is challenging for most people. For American expats, the normal complexities and expenses are compounded by a panoply of post-financial crisis… – Continue reading

Getting to Grips with How Latin America’s Tax Laws Impact Outsourcing Operations

With different tax laws, exemptions, double taxation treaties and free trade zones for services exports affecting outsourcing operations across Latin America, gaining a solid understanding of the distinct tax obligations in each country is imperative. In a bid to attract investment, several Latin American countries have introduced double taxation treaties,… – Continue reading

Brazil implements disclosure mechanism in the context of BEPS Action Plan 12

Following the trends of countries such as Spain and Mexico, among others, Brazil has begun to amend and introduce new legislation to reflect BEPS recommendations in its internal legislation. Provisional Measure (PM) 685 was issued this month, determining a disclosure procedure as a result of BEPS Action Plan 12 (Mandatory… – Continue reading

Brazilian Federal Revenue Secretariat clarifies application of PCI and PECEX methods

Consultation Solution no. 176, published by the Brazilian Federal Revenue Secretariat on July 8, 2015, made clear the tax administration’s position to require application of the PCI and Pecex methods on import and export transactions involving commodities, by determining the reliable sources of information to obtain the parameter prices for… – Continue reading

Company executives convicted in Brazil’s Petrobras scandal

SAO PAULO (AP) ” Three top officials of Brazil’s Camargo Correa construction company have become the first business executives to be convicted in the corruption-kickback scandal engulfing state-run oil company Petrobras. The Federal Prosecutor’s Office says Judge Sergio Moro on Monday sentenced the three on charges of money laundering, corruption… – Continue reading

Rexam’s predator seeks to play down competition concerns as EU launches probe into drinks can makers’ takeover

The US can making giant vying to buy British industrial champion Rexam has sought to play down fears that the deal will stifle competition and could lead to higher prices. Earlier this year Ball Corporation swooped on Rexam in a £4.3billion takeover that will create the world’s largest beverage can… – Continue reading

Normative Ruling RFB No. 1,571/2015: creation of the Electronic Financial Return (“e-Financeira”)

Normative Ruling RFB No. 1,571/2015, which institutes the Electronic Financial Return, the so-called “e-Financeira”, was published on July 3rd, 2015. The e-Financeira is a statement, transmitted electronically to the Public Digital Bookkeeping System (“SPED”), compulsory for insurance companies and legal entities with activities relating to (i) structuring and selling private… – Continue reading

Brazil: Congress Approves Agreement Between Brazil And The United States For The Automatic Exchange Of Financial Information

Congress just approved the intergovernmental agreement between Brazil and the United States for the automatic exchange of financial account information (Legislative Decree 146/2015, published on June 26). According to the terms of the agreement, Brazilian financial institutions (or Brazilian branches of foreign financial institutions) must identify financial accounts of United… – Continue reading

Brazil police arrest another former Petrobras executive

Brazil’s federal police have arrested another former Petrobras (PBR +1.8%) executive as part of an investigation into a broader corruption scandal surrounding the company. Police arrested Jorge Zelada, the company’s director of international operations during 2008-2012; he replaced Nestor Cerveró, who has been convicted of money laundering and sentenced to… – Continue reading

Brazil and U.S. Working To Mend Ties

Brazilian President Dilma Roussef met with President Barack Obama at the White House this week. Below is the new multi-faceted partnership. The United States and Brazilian relationship has been unstable since the U.S. spying policy became known in 2013. Brazilian President Dilma Roussef canceled a 2013 visit to Washington, D.C…. – Continue reading

Ethiopia, Brazil Conclude Avoidance of Double Taxation Agreement

Ethiopia and Brazil concluded an agreement for the avoidance of double taxation on profits derived from international air and shipping transport on June 22, 2015 in Brasilia, according to Fana Broadcasting corporate. H.E Ambassador Sinknesh Ejigu, Special Envoy, Ambassador Extra ordinary and plenipotentiary of the Federal Democratic Republic of Ethiopian… – Continue reading

FATCA – Which Countries Are In And Out

FATCA – Which Countries Are In And Out The controversial US Foreign Account Tax Compliance Act (FATCA) law is set to start from July 1, 2014, so with less than 21 days to go, here’s a look at which countries are in and who is outside of the tax network…. – Continue reading

Swiss attorney general cites 53 possible money-laundering incidents in FIFA World Cup probe

BERN, Switzerland – Reeling from an American federal investigation of bribery in soccer, FIFA was put under more pressure Wednesday as the scale of a separate Swiss investigation of suspected money laundering was revealed. Banks in Switzerland have flagged up 53 possible acts of money-laundering that could be linked to… – Continue reading

Wal-Mart Has $76 Billion in Overseas Tax Havens, Report Says

Wal-Mart Stores Inc. owns more than $76 billion of assets through a web of units in offshore tax havens around the world, though you wouldn’t know it from reading the giant retailer’s annual report. A new study has found Wal-Mart has at least 78 offshore subsidiaries and branches, more than… – Continue reading

HSBC to Shed 50,000 Jobs in Overhaul of Global Business

LONDON — Like other global institutions, HSBC, Europe’s largest bank, has been under severe pressure since the 2008 financial crisis to cut costs, meet stringent new regulatory demands and satisfy restless shareholders. To that end, the British bank said on Tuesday that it would shed as many as 50,000 of… – Continue reading

Domestic Woes Drive Brazilian Wealth to Offshore Markets

The country’s affluent investors have roughly doubled their offshore investment, curbing growth at Brazil’s wealth management firms. Scandal, recession and weak oil prices have caused economic vitality to seep out of Brazil. Now the money is following. Wealthy Brazilians are sending more of their assets overseas because of concerns about… – Continue reading

The Bahamas Chooses the Path of Innovation, Compliance

The past decade or more has not been an easy road to manoeuvre for IFCs. The Bahamas like other IFCs has faced the combined challenges of international initiatives, increased competition, industry consolidation, changing client demographics, emerging market requirements; legacy market stagnation and of course the financial crisis just a few… – Continue reading

International tax and withholding considerations for US companies and their directors

To staff their board of directors with the best and most diverse talent, multinational companies commonly elect boards with international representation. It is also common for companies to convene periodic board meetings outside the United States. This may be done, for example, to provide board members with an opportunity to… – Continue reading

Chairman Royce, Rep. Pallone welcome US-Amenia Trade & Investment Framework Agreement

The advantages of off-shore investments Two of the top reasons that South African investors are given to encourage offshore investments are that going offshore diversifies your portfolio and that it gives you access to sectors you could never find on the resource-heavy JSE. “While those are not reasons to be… – Continue reading

Unnerved by tax demands on capital gains, foreign funds flee for safety

The minimum alternate tax row has damaged the credibility of government promises to enforce an investor-friendly tax regime and made the Indian stock market Asia’s worst performer this year New Delhi/Mumbai: Castleton Investment Ltd, a unit of GlaxoSmithKline Plc (GSK), in 2012 asked an arm of the Indian finance ministry… – Continue reading