Category: Legislation

Manny Pacquiao Ordered To Explain His Taxes In Court: Is Pacman Now Taxman?

On top of his many boxing titles, including world championships in eight weight classes, Manny Pacquiao is on tap for a possible Senate seat in 2016. First, he has to get his taxes resolved. The Supreme Court of the Philippines ordered the boxing champ and potential Senator to answer the… – Continue reading

Amazon faces European Union tax avoidance investigation

Amazon, the online retailer, is to face a formal investigation into its European corporate tax practices, the European Commission has announced. The Commission – the executive division of the 28-member European Union – says it will look at the tax agreement made between Amazon and Luxembourg. It suspects the deal… – Continue reading

Canada: Tax Court Of Canada Allows Foreign Tax Credit Generator Arrangement

Major changes have occurred with respect to foreign tax credit (FTC). The Department of Finance announced in the federal budget of March 4, 2010, a proposed legislation regarding FTC generators (FTCG) and released modified draft legislation on August 27, 2010. These new FTCG rules target the FTC per subsections 126(4.11)-(4.13)… – Continue reading

Death & Taxes: Bloomberg BNA’s 2014 Trust Nexus Survey Reveals Significant Issues for Unsuspecting Practitioners, Particularly Double Taxation

Double taxation of trust income is a very real problem. The issue arises because trusts are subject to state income taxes on their entire income when they are classified as resident trusts under a taxing state’s law. Each state has its own definition of “resident trust,” which leads to the… – Continue reading

OECD bolsters relationship with Ukraine

7/10/14 – The 34-member countries of the Organisation for Economic Co-operation and Development (OECD) welcomed a Memorandum of Understanding (MOU) between the OECD and Ukraine which will help Ukraine’s efforts to tackle corruption, strengthen its tax system and promote competitiveness. Announced today in Paris, the MOU seeks to tap OECD… – Continue reading

Ireland’s tax regime nurtures innovation in avoidance

A tax-based industrial policy will not produce an innovative economy, writes James Stewart High quality global journalism requires investment. Please share this article with others using the link below, do not cut & paste the article. See our Ts&Cs and Copyright Policy for more detail. Email ftsales.support@ft.com to buy additional rights. http://www.ft.com/cms/s/0/bde702e4-4d5e-11e4-bf60-00144feab7de.html#ixzz3HKJXRQha Irish… – Continue reading

Washington resists Hockey’s tax crackdown on Silicon Valley giants

OHN KEHOE The global tax plan being pursued by Australia as G20 president, to compel low-tax paying multinationals such as Google and Apple to ­contribute more revenue to government coffers, could be derailed by political resistance in the United States. A prominent US senator in congress who would likely become… – Continue reading

Tax probes into wealthy foreigners stepped up

High quality global journalism requires investment. Please share this article with others using the link below, do not cut & paste the article. See our Ts&Cs and Copyright Policy for more detail. Email ftsales.support@ft.com to buy additional rights. http://www.ft.com/cms/s/0/b2926d28-4b08-11e4-b1be-00144feab7de.html#ixzz3FSimy6uT The UK tax authority has significantly increased the amount of extra money it obtains… – Continue reading

‘Earnings stripping’: The next tax-dodging strategy in Obama’s crosshairs?

When the Obama administration clamped down last month on companies that reincorporate abroad to escape high U.S. taxes, it did not address a tax-dodging technique known as “earnings stripping,” leaving some to wonder if it is the next target. Earnings stripping is widely practiced and covers a range of financial dealings that… – Continue reading

Osborne bid to fight tax avoidance ‘may empty, not swell, state coffers’

British chancellor George Osborne’s promise to clamp down on a tax avoidance loophole widely used by multinational technology companies could actually result in a reduction in the amount of money the government takes in, the Chartered Institute of Taxation has warned. Patrick Stevens, the group’s tax policy director, admitted the… – Continue reading

EU’s investigation into Fiat deal an ‘all-out attack’ on Luxembourg’s tax practices

BRUSSELS : The European Union’s tax investigation of Luxembourg focuses on a single unit of the Italian auto company Fiat. But the implications of the inquiry could in some ways be more far-reaching for multinational companies and their tax accounting than the bloc’s separate Apple-Ireland inquiry, experts said Tuesday. “I… – Continue reading

eBay pays just £620,000 tax on £1.3bn sales

eBay accused of tax avoidance, but insists it complies with letter of the law By Emma Woollacott, Sep 29, 2014Updated: September 30, 2014 7:24 AM Online auction site eBay got away with paying just £620,000 in tax on sales of over £1.3 billion last year, its latest accounts reveal. The… – Continue reading

Transfer pricing, tax evaders and IT: HMRC UK to assist FBR on tax reform initiatives

Her Majesty’s Revenue and Customs (HMRC) UK will assist Federal Board of Revenue (FBR) on tax and customs reform initiatives encompassing development of special skills to identify cases of transfer pricing, techniques to catch tax evaders and use of IT to control tax avoidance. It is learnt on Monday that the… – Continue reading

It’s Very Difficult To See How George Osborne’s Google Tax Could Possibly Be Legal

George Osborne, the Chancellor of the Exchequer over here in the UK, has just announced at the Conservative party conference that he’ll be changing the tax laws to make sure that Google GOOGL +0.16% and other tech multinationals (Facebook, Microsoft MSFT -0.17%, possibly Apple AAPL +0.64%, among them) end up… – Continue reading

Tax shelter shake-up hits home

A federal crackdown and a new act make life tougher for lawyers and accountants. Criminal tax attorney Robert Fink views the conviction and sentencing of his client Dr. Michael Canale—on tax fraud charges in New York state federal court in 2012—as representative of everything that’s wrong with the government crackdown… – Continue reading

How is Google Inc (GOOGL) Paying Service Tax and Facebook Inc (FB) Not Paying Any Taxes in India: Delhi High Court

Google Inc (NASDAQ:GOOGL) and Facebook Inc (NASDAQ:FB) are conducting their business operations in India. Former BJP leader, Govindacharya has filed a case, raising concerns against the usage of e-mail  services by offshore providers for official purposes by government officials. His Public Interest Litigation (PIL) also mentioned the tax evasion by… – Continue reading

Big business ‘shirks’ fair share of tax load

Almost a third of Australia’s largest companies are paying less than 10¢ in the dollar in corporate tax, a report that exposes a gaping hole in government revenues over the past decade shows. As Australia prepares to host world leaders at the G20 summit in Brisbane in November, where a… – Continue reading

Osborne plans crackdown on tech groups with new anti-avoidance rules

High quality global journalism requires investment. Please share this article with others using the link below, do not cut & paste the article. See our Ts&Cs and Copyright Policy for more detail. Email ftsales.support@ft.com to buy additional rights. http://www.ft.com/cms/s/0/f0564d62-4803-11e4-b5ad-00144feab7de.html#ixzz3EsBYd5vW Technology companies “that go to extraordinary lengths” to cut their tax… – Continue reading

Osborne vows crackdown on tax-avoiding tech firms

(Reuters) – British finance minister George Osborne said on Monday he was examining changes to clamp down on tax avoidance by multinationals which the government says are depriving Britain’s public coffers of hundreds of millions of pounds each year. “Some technology companies go to extraordinary lengths to pay little or… – Continue reading

New tax-dodge rules prompt AbbVie to seek more Shire financing: sources

(Bloomberg) — AbbVie Inc. is examining plans to raise additional financing to complete its takeover of Shire Plc, after U.S. officials imposed new obstacles to so-called tax inversion deals, people with knowledge of the matter said. AbbVie may seek to borrow as much as $7 billion more than it originally… – Continue reading

Another view: Low tax rates no way to build economy

Canada should not count on building its economy by luring U.S. multinationals over the border with low tax rates in light of an announcement from the U.S. Treasury Department this week. The department outlined new measures to block companies from escaping U.S. taxes by moving earnings outside the country. This… – Continue reading

Germany may close foreign ‘patent box’ tax loophole: report

German Finance Minister Wolfgang Schaeuble is working on closing a tax loophole whereby German firms use so-called “patent box” tax breaks available abroad on profits generated from patented research to minimize tax bills, according to a magazine report. Business weekly Wirtschaftwoche said a potential new restriction on the practice, similar to one in… – Continue reading

Government seeks banking information on 97 cases from Mauritius in one year

PORT LOUIS: Mauritius has provided details on majority of information requests received from Indian authorities in the last one year, according to a government official. India has concerns that Mauritius, which is one of the top sources of foreign direct investments into the country, is being used for round-tripping of… – Continue reading

CPD: Personal tax

The latest edition of Newsbrief counts as 1 hour of structured CPD and covers the regulatory and marketplace changes that took place during August 2014. Visit the Money Marketing CPD Centre to answer 10 multiple choice questions and complete this CPD activity. Just click into your CPD Plan and you’ll… – Continue reading

UK government reveals new tax evasion scheme for multinationals

Global corporations based in the UK will now have to report where they make their profits and pay their taxes to HMRC, the UK government has announced. The new country-by-country reporting template was released this week by the OECD and the UK is the first of 44 countries to officially sign… – Continue reading

The Obama administration’s tougher rules on offshore corporate inversions had…

Stricter tax inversion rules punish stocks of firms mulling such moves. The Obama administration’s tougher rules on offshore corporate inversions had an immediate effect Tuesday, pushing down the stock prices of companies considering such moves.But the highly technical changes to the tax code di Stricter tax inversion rules punish stocks… – Continue reading

‘I was terrified we’d lose all our money’: banks tell US customers they won’t work with Americans

Thousands of Americans abroad are giving up their citizenship as the implementation of a complex new tax law causes banks to shut down accounts for US expatriates Angry Canadians are rare. But Patricia Moon qualifies. Until 2012, Moon was actually an American – albeit one who had lived in Canada… – Continue reading

Brazil: Cross-Border Payments For The Use Of Offshore Data Centers – Taxation In Brazil

Interpretative Act (Ato Declaratório Interpretativo) No. 7, of August 15, 2014, issued by the Brazilian Internal Revenue Service (Receita Federal do Brasil – RFB), hereinafter referred to simply as IA 7/2014, deals with the taxation of cross-border payments for the use of data centers located abroad (i.e. based outside Brazil), known… – Continue reading

Obama Treasury’s Corporate Inversion Regulations Simply Won’t Work

The Treasury Department today came out with a series of arcane new tax regulations in the hopes of stemming corporate inversions. Inversions happen when U.S. companies merge with a foreign company while usually retaining U.S. operations. Their purpose is to avoid punitive U.S. double taxation on income earned overseas. The… – Continue reading

British Virgin Islands: BVI US And UK FATCA Implementation – Entity Classification And Registration

On 30 June 2014, the British Virgin Islands (“BVI“) government signed a Model 1B (i.e. non-reciprocal) intergovernmental agreement with the United States (the “US IGA“).  The US IGA provides a framework for the implementation of the US Foreign Account Tax Compliance Act (“FATCA“) in the BVI.  The BVI government had,… – Continue reading

B2B: Transfer Pricing

Three years ago, Russia adopted new transfer pricing legislation. The new rules became effective on  Jan. 1, 2012. They are in line with international standards (OECD Guidelines on Transfer Pricing), but their concept was, and still is, quite new for the Russian tax authorities. Thus the rules provide for a transition period until 2017: For the years 2012… – Continue reading

B2B: Bilateral Advance Pricing Agreements Are a Useful Tool for Attracting Foreign Investors

In recent years, Russian tax legislation has adopted many modern international tax concepts and practices. Most notably, transfer pricing rules, consolidated groups of taxpayers, easy electronic communications between taxpayers and tax authorities have all become part of standard working practice. However, there is always room for improvement. The current global economic and political situation dictates that new initiatives… – Continue reading

Key Tax Considerations of Sending Employees Overseas

The issue of international assignees was, for a long time, limited to a small number of companies – meaning only those that operated on an international scale. But in recent years, global expansion has shifted into focus for the larger business community. As a result, the challenges and best practices… – Continue reading

UK Tax Evasion Widens on HMRC Cuts and Lack of Avoidance Law

A lack of anti-avoidance tax law and cuts to public services are contributing to the UK’s yawning tax gap. New research by Tax Research LLP, on behalf of the Public and Commercial Services Union, shows that the tax gap – defined as “the difference between the tax that should be paid in the UK if the taxsystem worked as parliament and… – Continue reading

The Obama administration just took action to curb corporate inversions. It’s the right move against tax avoiders.

The beautiful part is the administration did it without Congress. Jared Bernstein, a former chief economist to Vice President Biden, is a senior fellow at the Center on Budget and Policy Priorities and author of “Crunch: Why Do I Feel So Squeezed?” among other books. Well, would you look at… – Continue reading

Global watchdogs take on the corporate tax dodgers

As the finance ministers and central bank governors from the world’s 20 largest economies gather in a convention centre in the Australian city of Cairns this weekend, anti-capitalist protesters will likely accuse them of doing the bidding of the globe’s all-powerful multinational corporations. But the Group of 20’s financial chieftains… – Continue reading

International Tax Alert: OECD Releases BEPS Papers

Yesterday saw the release of the first set of deliverables under the OECD’s project on base erosion and profit shifting (BEPS).  These constitute the “building blocks” for an internationally agreed and co-ordinated response to government and media concerns in recent years about the perceived way in which shortcomings in relevant… – Continue reading

‘Deoffshorisation’ of the Russian Economy: Updated version of the Draft Law on Controlled Foreign Company legislation and other measures

The Russian Ministry of Finance has published an updated version of the draft controlled foreign company rules (hereinafter – “CFC”) on the 2nd of September (hereinafter – ‘the new Draft’). The previous drafts were covered in detail in our press releases of 24 March and 5 June. The new Draft… – Continue reading