Legislation aimed at finding American tax evaders would give up personal information of Canadians with ties to the U.S. OTTAWA—If one wants another clear-eyed illustration of the power imbalance between Washington and the federal Conservatives, one need look no further than a tax deal signed between the two countries last… – Continue reading
When it comes to being an expat, as far as the UK taxman is concerned, absence does not make the heart grow fonder. A tax specialist gives tips on avoiding problems. There is no avoiding the fact that moving overseas or returning to the UK creates some tax issues, and… – Continue reading
Increasing numbers of the wealthy global elite are saying goodbye to their home country and taking up residence elsewhere in an effort to preserve their riches. Popular destination countries like Cyprus, Spain and Australia have programs that offer a path to citizenship or permanent residency — for those who can… – Continue reading
Mauritius to provide automatic tax info exchange for India Ramgoolam, who was here to attend BJP leader Narendra Modi’s swearing-in as Prime Minister yesterday, also said that Mauritius would not allow anybody to abuse or misuse its jurisdiction for any illicit activities. Seeking to allay apprehensions about Mauritius being used… – Continue reading
Russian lawmakers and banks are still squabbling about how to join the Foreign Account Tax Compliance Act (FATCA) network after the US closed the door on talks following Moscow’s role in the Ukraine crisis. In recent weeks, Finance Minister Anatoly Aksakov pledged to Russian banks that a new law allowing… – Continue reading
Azerbaijan and the U.S. Internal Revenue Service (IRS) agreed to conclude an intergovernmental agreement on implementation of the Foreign Account Tax Compliance Act (FATCA) by Azerbaijani banks, the Ministry of Taxes of Azerbaijan said on May 21. Starting from July 1, 2014 the banks in all countries should join the… – Continue reading
India has asked Switzerland to speed up the ratification of the Organization for Economic Cooperation and Development (OECD) convention on automatic exchange of tax information. ”I would urge you and your (Swiss) government to ratify the multilateral convention on mutual administrative assistance in tax matters as early as possible,” outgoing… – Continue reading
AsiaOne Business News released an article on the expectation of Singapore to dislodge Switzerland as the world’s wealth management capital (Business AsiaOne, 5/12/14) last week. AsiaBiz Services, Singapore’s leading company formation consultancy, affirmed that the main reasons for the country’s acquisition of its enormous share of global offshore wealth are attributed to… – Continue reading
WASHINGTON (Reuters) – Taking aim against corporate tax avoidance, Democrats in the U.S. Congress called on Tuesday for curbs on U.S. multinationals that shift tax domiciles abroad in deals known as “inversions.” While still rare, these deals are becoming more common, with two recently attempted transactions by Pfizer Inc and… – Continue reading
Moving abroad to start a new job can be one of the most exciting yet stressful experiences of your life — but it can also end up saving you a bundle in federal income tax. This is because U.S. expatriates frequently take advantage of the foreign earned income exclusion to… – Continue reading
Following the recent offer by U.S drugmaker Pfizer to acquire British pharmaceutical firm AstraZeneca, congressional Democrats are proposing new limits on the ability of U.S.-based firms to establish foreign residence and thus cut their U.S. corporate tax bill. Even before this latest flap, the Obama Administration proposed curbs on this… – Continue reading
Internal Revenue Commissioner Kim Henares has again defied a Supreme Court ruling on the self-executory nature of tax treaties by issuing a circular prescribing additional requirements before privileges granted under a tax treaty may be enjoyed. Henares issued Revenue Memorandum Circular No. 37-2014, announcing the coming into force of the… – Continue reading
Uncle Sam is poised to poke his pointy nose into the financial affairs of millions of Canadians who have no connection to his country, and – no matter how distasteful you find this – pushing back will only make it worse. This is the gloomy – but credible – conclusion… – Continue reading
On April 9, 2014, the Finance Ministry issued guidelines on the application of agreements on the avoidance of double taxation (DTAs), which requires tax agents and tax authorities to conduct an assessment of whether foreign recipients of income in Russia have the right to apply a tax exemption in Russia… – Continue reading
Liechtenstein said Friday that it has signed a anti-tax fraud pact with Washington that requires banks in the principality to provide information about accounts held abroad by US taxpayers to US authorities. Under the agreement, Liechtenstein would implement the Foreign Account Tax Compliance Act (FATCA), which came into effect on… – Continue reading
NASSAU, Bahamas — The government has been urged to implement an investor-citizenship program that would effectively allow high-net-worth individuals (HNWIs) to trade investment in The Bahamas for citizenship rights as a means of spurring growth in the economy. Sean McWeeney QC, a partner with law firm Graham Thompson and Co., is advocating… – Continue reading
The Supreme Court of India in a recent ruling (Commissioner of Wealth Tax, Rajkot v. Estate of Late HMM Vikramsinhji of Gondal (Civil Appeal No. 2312 of 2007) has held that the Indian resident beneficiaries of an offshore discretionary trust shall not be subject to tax on the trust’s income… – Continue reading
The Chartered Institute of Taxation (CIOT) has voiced concern over the proposed withdrawal of the principal residence election for all taxpayers. The authority has responded to HM Revenue and Customs’ (HMRC) plans to extend capital gains tax (CGT) to non-residents in certain circumstances, and fears the proposal could have a significant… – Continue reading
A decision from the U.S. to recognize those with agreements “in substance” changes the number of countries with IGAs from 22 to 48. Jeffrey S. Freeman, J.D., LL.M If you notice money missing from your bank account you start asking questions and find a way to get that money back…. – Continue reading
ZAMBIA is reviewing its tax treaty with the Netherlands and Ireland to allow the incorporation of anti-abuse clauses where necessary, a senior government official said.The move, according to tax justice advocates, marks a turning point for Zambia, which has been a key victim to tax avoidance by multinational corporations that… – Continue reading
More than three quarters of American expats and green card holders who have taken out a supplementary overseas pension contract are able to mitigate the effects of the Foreign Account Tax Compliance Act, it is claimed. The FATCA created controversy when it was announced, as it appeared that people would… – Continue reading
BASSETERRE, St. Kitts, May 21st 2014 (CUOPM) – The St. Kitts and Nevis Federal Cabinet has paved the way for the signing of Tax Information Exchange Agreements (TIEAs) with Ireland and South Africa. Cabinet has approved the draft agreements between officials of the respective countries. “Those negotiation exercises have since… – Continue reading
Efforts to sign new DTAs and update existing DTAs in the first five months of the year will promote tax transparency and facilitate investments, sustaining Singapore’s position as a preferred destination for doing business, says SingaporeCompanyIncorporation.sgSingapore, in a bid to further strengthen its Avoidance of Double Taxation Agreements (DTA) network, has seen new… – Continue reading
The Inland Revenue Department of the Republic of Cyprus is expected to sign the Model 1 InterGovernmental Agreement (“IGA”) with the US Treasury in accordance with the provisions of the Foreign Account Tax Compliance Act (FATCA). FATCA is a US tax legislation that was enacted in March 2010 in order… – Continue reading
On October 13, 2009, the government of Georgia and the government of the State of Kuwait have signed an Agreement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital. The treaty entered into force on April 14, 2013,… – Continue reading
In an effort to tighten rules on corporate tax avoidance through “inversions,” U.S. Senator Tim Kaine joined a group of 13 Senators today to introduce The Stop Corporate Inversions Act of 2014, legislation to address the practice of reincorporating offshore to avoid paying U.S. taxes. The bill is designed to prevent… – Continue reading
If you have clients who own Greek bonds (government or corporate), they may have immediate tax-filing concerns. A PwC notice explains that investors not resident in Greece who realized gains between February 29, 2012 and December 31, 2013 owe the Greek government 20% in taxes. It’s due June 25, and… – Continue reading
With the recent passing of the 5 May 2014 registration deadline to be included in the first IRS GIIN list on 2 June 2014, and the 3 June 2014 registration deadline for the 1 July 2014 GIIN list imminent, this update outlines the practical implications for CLO issuers incorporated in… – Continue reading
With any opportunity that seems too good to be true, there is often a fatal flaw. That is the case with The Partnership to Build America Act, introduced by U.S. Rep. John Delaney, D-Md., and U.S. Sen. Michael Bennet, D-Colo. The bill offers a way for multinational corporations to bring… – Continue reading
MILAN — Fiat Chrysler Automobiles’ new London headquarters will have a staff of about 50 people, most of whom will have a finance background, said two people familiar with the details of the automaker’s plan to shift its tax residency to the UK. Fiat Chrysler CEO Sergio Marchionne and Fiat… – Continue reading
On May 9, 2014, the U.S. Treasury announced that Hong Kong had agreed in substance on a Model 2 FATCA IGA. Under the IGA, Hong Kong financial institutions will report information on financial accounts held by U.S. persons directly to the Internal Revenue Service. Hong Kong is only the seventh country… – Continue reading
Liechtenstein said Friday that it has signed a anti-tax fraud pact with Washington that requires banks in the principality to provide information about accounts held abroad by US taxpayers to US authorities. Under the agreement, Liechtenstein would implement the Foreign Account Tax Compliance Act (FATCA), which came into effect on… – Continue reading
The Financial Services Authority (OJK) has proposed that the government demand reciprocal cooperation with the US regarding the latter’s request to apply its Foreign Account Tax Compliance Act (FATCA) in the country. FATCA is a law that the US has unilaterally imposed on the rest of the world to prevent… – Continue reading
CARACAS, May 17, 2014 – (WAFA) – President Mamhoud Abbas signed Saturday energy and double taxation avoidance agreements with his Venezuelan counterpart Nicolas Maduro at Miraflores presidential palace in Caracas. Abbas started Friday a three-day official visit to the Caracas, where he was received by Maduro. They exchanged views on the peace process as well… – Continue reading
Residential property owners need to be aware of some proposed changes, which will have a significant impact on their CGT liabilities. Final period exemption reduced If a property has, at any point, qualified as an individual’s main residence then the final 36 months would have been covered by relief from… – Continue reading
The new Mexican Income Tax Law (“MITL”) that entered into force on January 1 modified the so-called procedural provisions concerning the application by multinational companies of benefits set forth under tax treaties negotiated and executed by Mexico. Accordingly, foreign residents claiming tax treaty benefits (either for a tax exemption or… – Continue reading
NEW DELHI, MAY 14: With tax authorities pressing with over Rs 21,000 crore in unpaid dues, Finnish telecom major Nokia has invoked the Bilateral Investment Promotion and Protection Agreement (BIPA) India has with Finland to resolve the dispute. Nokia late last month wrote to Prime Minister invoking dispute settlement clause… – Continue reading
Corporate Tax Avoidance: Last week the news that Apple is considering buying Beats Electronics, a maker of expensive headphones that was founded by record mogul Jimmy Iovine and rap artist Dr Dre, for $3.2bn, got a lot of media attention. Dr Dre must have pissed-off Apple when he bragged on… – Continue reading
On 28 April 2014, the Australian Government signed an agreement (the intergovernmental agreement) with their U.S. counterparts that will greatly assist Australian financial institutions that must comply with the requirements of the Foreign Account Tax Compliance Act (FATCA) legislation, enacted by the U.S. Government. The FATCA regime is, at its core,… – Continue reading
Hong Kong and the United States have concluded their discussions on the implementation of the Foreign Account Tax Compliance Act, with Hong Kong expected to sign a model 2 intergovernmental agreement later this year. Under the model 2 agreement, financial institutions in Hong Kong will need to register and conclude… – Continue reading
Despite a push to obtain agreements with foreign governments through April, the US Treasury’s own website notes the large number of outstanding Intergovernmental Agreements yet to be implemented fully around the Foreign Account Tax Compliance Act (Fatca). So-called IGAs are critical for the success of the US Foreign Account Tax… – Continue reading
Azerbaijan and Saudi Arabia plan to sign an agreement on the avoidance of double taxation, as well as tax evasion, the ambassador of Saudi Arabia Musaid bin Ibrahim bin Abdullah Al-Salim told a press conference. The ambassador said the agreement is expected to be signed during the Azerbaijani foreign minister… – Continue reading
The head of Canada’s investment industry association is urging the federal government not to defer legislation that will facilitate handing tax information of U.S. citizens living in Canada to authorities in the United States. Ian Russell, chief executive of the Investment Industry Association of Canada, made his pitch to the… – Continue reading
Puerto Rico’s tax incentive acts are tailor-made for traders, investors, investment managers and financial institutions. Enacted in 2012, Puerto Rico’s Act 22 allows investors and traders with bona fide residence in Puerto Rico to exclude 100% of all short-term and long-term capital gains from the sale of personal property accrued… – Continue reading
Hong Kong and the United States have substantially concluded discussions on an inter-governmental agreement (IGA) to simplify Hong Kong financial institutions’ compliance with the Foreign Account Tax Compliance Act. The Financial Services and the Treasury Bureau (FSTB) said that the IGA “will reduce Hong Kong financial institutions’ reporting burden and… – Continue reading
Taiwan’s Financial Supervisory Commission (FSC) has confirmed that it expects to conclude an intergovernmental agreement (IGA) with the United States regarding the Foreign Account Tax Compliance Act (FATCA) by the end of June this year. FATCA, enacted by the US Congress in 2010 and due to take effect on July… – Continue reading
Up to December 31, 2013, Mexico did not tax dividend payments. However, the Mexican Income Tax Law (“MITL”) that entered into force on January 1, 2014 established a new 10 percent withholding tax on the gross amount of dividend payments made by legal entities resident in Mexico for tax purposes… – Continue reading
Kevin E. Thorn, Managing Partner of the Thorn Law Group discusses the recent negotiations between the U.S. Department of Justice and Swiss bank Credit Suisse and the effect that any potential settlement may have on the rest of the banking community and the U.S. Taxpayers who still may have undisclosed… – Continue reading
On December 17, 2013, the Protocol Amending the Convention between Japan and the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital Gains (the “Protocol”) was executed in London. The… – Continue reading
Swisspartners Group, a Zurich-based money-manager, resolved a U.S. criminal tax probe by paying $4.4 million for helping American clients use secret accounts to evade taxes. In return, the government agreed not to prosecute the firm, citing its “extraordinary cooperation.” The agreement resulted from Swisspartners’ voluntary production of the files for… – Continue reading
