Several recent high profile deals have directed media and public attention to the topic of “tax inversion,” whereby a company moves its headquarters overseas (usually in an M&A deal) in order to reduce its tax burden. According to the Wall Street Journal (citing Thomson Reuters) there have been 22 such… – Continue reading
CFOs of multinationals need to prepare by assessing how much their companies engage in profit shifting to cut their taxes. Do you have responsibility, whether direct or dotted line, for the tax function in your company? Does your company have, or plan to have, operations outside the United States? If… – Continue reading
Microsoft is the most recent member of the get-your-money-out-of-the-country club. The technology giant is facing scrutiny amid findings that it is housing nearly $92 billion offshore in an effort to avoid as much as $29 billion in US taxes. Annual filings with the Securities and Exchange Commission exposed that the… – Continue reading
Technology companies frequently possess an international tax footprint before expanding their domestic tax footprint. That may soon change as the Organisation for Economic Cooperation and Development (OECD) and its G20 member countries undertake an ambitious agenda to fundamentally alter the international taxation system. The OECD released its Action Plan Addressing… – Continue reading
The Australian Taxation Office (ATO) has launched an investigation regarding the income and property that members of the Greek Diaspora have in Greece. Greek-Australians have a deadline until December 2014 to voluntarily declare all their homeland assets in order to avoid being considered as tax evaders and paying the full… – Continue reading
Tax investigators pursuing instances of blackmoney stashed abroad by Indians have finally been able to circumvent the Swiss secrecy code by asking over 100 such account holders to submit on their own details of personal balances in these banks, brought under the tax net recently, for lesser penal action for… – Continue reading
THE National Tax Policy (NTP) has identified double taxation as one of the major hindrances to the growth of the Nigerian economy. Double taxation has become an issue paramount to investors and top executives of multinationals as income is generally taxable both in source and residence countries. In order to… – Continue reading
On June 25, 2014, the IRS finally issued the instructions to the new version of Form W-8BEN-E, an 8-page withholding certificate to be completed by foreign entities. Previously, foreign individuals and most foreign entities would provide a one-page Form W-8BEN to withholding agents to certify the foreign entity’s entity classification… – Continue reading
MONTREAL • Eugene Melnyk, the billionaire owner of the Ottawa Senators and founder of drug maker Biovail Corp., is waging war against the company that now controls his one-time business. Mr. Melnyk alleges that Valeant Pharmaceuticals International Inc. is masquerading as a Canadian company to make use of this country’s… – Continue reading
The Delhi High Court upholds the non-taxability of gains from sale of shares of overseas entities by the Copal Group to the Moody’s Group. Interpretation of the indirect transfer tax provisions in a restrictive manner. 50% threshold for substantiality based on guidance by OECD/ UN material and Shome Committee Report… – Continue reading
TAX avoidance is always a hot topic, never more so than with the recent stream of famous individuals involved in the Liberty scheme. The fact that some of these 1,600 stars risk bankruptcy highlights just how serious these cases can be, and the financial and reputational value at stake. The media… – Continue reading
Legislation which will establish and govern Scotland’s first tax collection system in 300 years has been passed by the Scottish Legislation which will establish and govern Scotland’s first tax collection system in 300 years has been passed by the Scottish Parliament.21 Aug 2014 The Revenue Scotland and Tax Powers Bill… – Continue reading
Tax reform is squarely on the agenda for the G20 Brisbane summit in November. The current international tax regime is broken and it’s going to take significant effort on a global scale to fix it. In a recently released CEDA Report on securing the G20’s future, I recommended the role… – Continue reading
Those committing tax evasion could face stricter consequences due to the change in government tax legislation, according to a top city accountant. Des Veney, Director of Haines Watts Chartered Accountants on Victoria Street, believes that as a result of the stern regulation, which came into effect earlier this month, UK… – Continue reading
Contractors can have their say on the taxman moving to criminalise people who fail to declare offshore income and gains, even if he cannot prove their intent was to defraud him. Under the ‘strict liability’ offence, convictions could hit a person whose taxable offshore income and gains were not correctly… – Continue reading
The Foreign Account Tax Compliance Act (FATCA) was enacted in 2010 by the US to target non-compliance by US taxpayers using foreign accounts. FATCA essentially requires foreign financial institutions to report information about financial accounts held by US taxpayers, or by foreign entities in which such taxpayers hold a substantial… – Continue reading
Manila (AFP) – Philippine world boxing champion Manny Pacquiao has won a Supreme Court reprieve in his battle to avoid paying tens of millions of dollars in extra taxes, authorities said Thursday. Pacquiao will not have to post a cash bond of 3.3 billion pesos ($75.2 million) and the government… – Continue reading
If I say that Spain is a country in love with bureaucracy, your response might be: “Really…I don’t believe you for a minute?!” Sarcasm is rarely better suited to a statement than here. Yes, unfortunately a good proportion (not all) of the 2.7 million Spanish civil servants need to move… – Continue reading
A new section 1305A of the UK Corporation Tax Act 2009 (CTA 2009) has been introduced by the UK Finance Act 2014 that applies to payments made from March 19, 2014 under avoidance schemes involving the transfer of corporate profits within a group. This new measure applies if: two companies… – Continue reading
Despite the political and media pressure on offshore financial centers, new incorporations of offshore companies worldwide continue to grow. A new report on offshore company incorporations by law and fiduciary firm Appleby shows that new company registrations increased in most offshore jurisdictions in the second half of 2013. “As the… – Continue reading
The government will strengthen taxation standards for foreigners as part of efforts to stem tax evasion. The Ministry of Strategy and Finance said Sunday that it will submit a revised tax law to the National Assembly next month. The National Tax Service taxes foreigners residing in Korea based on the… – Continue reading
Legislation which will establish Scotland’s first tax collection system for 300 years will be approved today by Holyrood. MSPs are expected to pass a bill from the Scottish Government which will set up Revenue Scotland – the new body which will collect two newly-devolved taxes. Finance Secretary John Swinney said… – Continue reading
Switzerland is cooperating with French tax authorities over an investigation of alleged tax fraud involving former French footballer Marcel Desailly. The notice of Swiss cooperation was published on Tuesday in the Federal Gazette. Desailly, captain of the French football team from 2000 to 2004, allegedly holds or has held assets… – Continue reading
Most expats forget about their tax status once they have left Britain and assume they pay taxes in the country where they live. To some extent this is true – but HM Revenue & Customs regularly challenges the validity of non-residence claims and the long-arm of the tax man can… – Continue reading
LONDON: Scottish explorer Cairn Energy plc today said it is working with the newly elected government to resolve a tax dispute that has stalled sale of its 10 per cent stake in Cairn India Ltd. “Cairn continues to seek resolution of the tax issue in India and will take all… – Continue reading
U.S.-China Agreement Requires Financial Institutions to Increase Transparency and Enhance Reporting Wolters Kluwer Financial Services recommends that financial institutions in China should take steps toward enhancing their data and reporting capabilities on financial accounts held by U.S. taxpayers in China as part of the Foreign Account Tax Compliance Act. This recommendation… – Continue reading
The Isle of Man’s Agreement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and on Capital with Luxembourg is now in force. The agreement was signed on April 8, 2013 in London between Eddie Teare MHK, the Isle of Man’s… – Continue reading
(MENAFN – Kuwait News Agency (KUNA)) A double-taxation avoidance agreement between Japan and Oman is expected to enter into force next month, the Japanese Foreign Ministry announced Monday.Japan notified Oman on Sunday of the completion of its internal ratification procedures for the treaty on the avoidance of double taxation and… – Continue reading
Two women have challenged the constitutionality of a Canada-U.S. agreement to share the tax information of U.S. citizens resident in Canada, with the IRS. But an expert in U.S. tax law says that these individuals, most of whom consider themselves Canadians, could be worse off if the lawsuit succeeds. “If… – Continue reading
Minister of Finance Bob Richards confirmed this week that under the Bermuda-UK FATCA Intergovernmental Agreement [IGA] model 2, Bermuda and the UK have agreed the inclusion of a Limited Capacity Exempt Beneficial Owner Category in Annex II of the IGA. The effect of this amendment will mean that there will… – Continue reading
On July 21, 2014 the OECD released the full version of a new global standard for the exchange of financial information in tax matters “OECD\Standard for Automatic Exchange of Financial Account Information in Tax Matters” The new standard which will be presented for formal adoption by the OECD Members in… – Continue reading
Northern Ireland looks set to be handed the power to slash corporation tax in a move with the potential to significantly boost our stuttering economy. In a development which could transform international investment, senior sources in London and Belfast predict that an announcement will be made no later than October… – Continue reading
To some, US companies switching their tax residency to gain a tax advantage are economic “traitors.” To others, they are victims of a United States tax code that effectively punishes them for investing at home and encourages them to look for opportunities overseas. In this Tax-News Topical Focus, we try… – Continue reading
On 20th of June, the double tax treaty (DTT) between Cyprus and Norway was published in the official Government Gazette. Double taxation avoidance between the two countries is regulated by the 1951 DTT in place between Norway and the UK extended in 1955 to include several British colonies, including Cyprus. The… – Continue reading
On 20th of June, the double tax treaty (DTT) between Cyprus and Norway was published in the official Government Gazette. Double taxation avoidance between the two countries is regulated by the 1951 DTT in place between Norway and the UK extended in 1955 to include several British colonies, including Cyprus…. – Continue reading
USA Today published a story last week entitled “20 big profitable companies paid no taxes.” Using data provided by S&P Capital IQ, the newspaper identified 20 firms that paid no federal taxes in the second quarter of this year despite reporting $4.4 billion in second quarter profits. Collectively, these 20… – Continue reading
With new laws in place, recovery from Swiss banks can be little easier provided the government shows sincerity in taking action against tax dodgers Finance Minister Senator Ishaq Dar in recent days has expressed the government’s firm conviction to bring back untaxed money of “US$ 200 billion” stashed in… – Continue reading
The sharemarket has settled into a consolidation phase at between 5400 and 5600 index points, mirroring changes in overseas markets. While analysts are confident the current reporting period will not produce unexpected changes to their forecasts, international political instability makes further upward movement in prices unlikely. Compared with overseas markets… – Continue reading
August 1 — Monaco and the Czech Republic signed a tax information exchange agreement, the Monaco government announced. The agreement was signed on July 31 by Monaco’s Government Counsellor for External Relations and Cooperation José Badia and the Czech Republic Ambassador to Monaco Marie Chatardova. The agreement is in line with… – Continue reading
In its October 4, 2013 decision, no. 351065, Mr. Clive Worms, the French Administrative Supreme Court reiterated that, under domestic tax law, an indemnity received by a French tax resident in compensation of his cancelled stock options qualifies as a compensation for work. On the day the options were granted, the… – Continue reading
Summary HMRC have announced that the new capital gains tax (“CGT”) charge on non-residents disposing of UK residential property, due to come into effect in April 2015, will not extend to institutional investors and companies with diverse ownership. Background In the Autumn Statement last year, the Chancellor announced the new… – Continue reading
While the IRS is trying to find Lois Lerner’s emails and revising its rules governing inversions — the practice of multinational corporations (MNCs) moving their headquarters to avoid paying taxes — it has also endorsed a maneuver that will cut taxes for major telecom companies by billions of dollars. In… – Continue reading
HM Revenue & Customs (HMRC) has announced changes to the terms of the Liechtenstein Disclosure Facility (LDF), restricting the most favourable treatment to new tax irregularities with a “significant” offshore connection. Tax Disputes and Investigations Tax Private wealth tax Reg Day, a tax expert at Pinsent Masons, the law firm… – Continue reading
Property owners and pensioners who face losing their personal tax allowances can take steps now to protect themselves, say experts Expats facing the possibility of losing their personal allowance under a tax raid proposed by George Osborne should not panic but look carefully at where their UK sources of income… – Continue reading
August 5 — Honduras signed an agreement with Ecuador on mutual administrative assistance and cooperation and the exchange of tax information, the Honduran Ministry of Foreign Affairs and International Cooperation announced on July 31. The agreement was signed in the Honduran capital Tegucigalpa by Miriam Estela Guzman, the head of the… – Continue reading
Just as financial institutions started to come to grips with the fact that the Foreign Account Tax Compliance Act (FATCA) went into effect last month in the U.S., the Organization for Economic Cooperation and Development (OECD) unwrapped a new global version. The OECD proposal is called the Global Standard for… – Continue reading
KUALA LUMPUR: All local financial institutions will be required to declare their American customers to the United States Internal Revenue Service (IRS) under a new agreement to catch its tax evaders who hide their money overseas. Malaysia will be entering into an inter-governmental agreement with the US in line with… – Continue reading
August 8th, 2014 (InsideCostaRica.com) Costa Rica will delay plans to raise taxes until 2017 as the government of President Luis Guillermo Solis focuses on cracking down on tax evaders to narrow the country’s widening fiscal deficit instead. Solis, on the campaign trail prior to his May election, vowed to not… – Continue reading
Changes to the way that HM Revenue and Customs (HMRC) taxes loans secured by non-domiciled persons (“non doms”) using foreign income and gains will lead to disputes over the true interpretation of the law, the Chartered Institute of Taxation (CIOT) has warned. HMRC has announced that it is to withdraw… – Continue reading
A lawsuit has been filed by several Canadian citizens against the Canadian Attorney General in Federal Court in Canada. The legal claim challenges the constitutionality of the agreement the Canadian government struck with the United States. The controversial deal between nations was inked under FATCA—the Foreign Account Tax Compliance Act…. – Continue reading
