The American Institute of CPAs has sent a list of six tax regulations to Treasury Secretary Steven Mnuchin that it wants the Treasury Department to review under an executive order from President Trump calling for reducing overly burdensome tax regulations. Trump signed an executive order last month on identifying such… – Continue reading
Malaysian individuals and entities that have bank accounts overseas will soon see their financial information being shared with other countries and tax authorities in an effort to boost global transparency and tax compliance. This requirement is part of the automatic exchange of financial account information set out by the Organisation… – Continue reading
Australian Treasurer Scott Morrison’s 2017 Budget focused on measures to cool the housing market and crack down on tax avoidance. Morrison handed down the Budget on May 9. He said the the budget would return to a surplus in 2020-21 and remain in surplus over the medium term. The Budget… – Continue reading
The United States continues to be a magnet for immigration, with nearly 8 million new immigrants settling here between 2008 to 2014 — and some of these new immigrants are high-net-worth individuals who are unprepared for the intricacies of the U.S. tax law, according to Seth Entin, a shareholder at… – Continue reading
Foreign ownership of new developments will be restricted, there will be steeper charges applied to purchases, less favourable tax treatment and charges on those with empty properties, in a raft of measures in the federal budget aimed at taking the sting out of the housing market. One measure to be… – Continue reading
This article is the first of a series of articles that looks at tax aspects of the UK company which make it an attractive international business company, or “IBC”. This generic label, and its acronym, are normally associated with the BVI company, and its international competitors. An essential feature of… – Continue reading
Income tax has long been a progressive talking point in Seattle. Washington is one of just seven states without any income tax, and it relies heavily on sales and property taxes to fill the state coffers. As such, Washington earns the dubious honor of having the most regressive tax system… – Continue reading
KARACHI: The Federal Board of Revenue (FBR) has initiated audit of all those taxpayers who have made offshore transactions during the last six years, sources said on Tuesday. “All corporate and individual taxpayers, who have made offshore investments, have been selected for audit to check the tax concealment,” an official… – Continue reading
(Second of two parts) In last week’s article, we discussed the revised procedure to avail of tax treaty benefits for dividend, interest, and royalty payments under Revenue Memorandum Order (RMO) No. 8-2017. Under the amended rules, a tax treaty relief application (TTRA) is no longer required and withholding agents can… – Continue reading
The European Court of Justice (ECJ) has ruled in favor of Austria in its dispute with Germany relating to the taxation of interest from profit-participation certificates received by an Austrian bank from a German bank. The case involved the interpretation and application of Article 11 of the 2000 double tax… – Continue reading
In early April 2017, an important taxation agreement between Monaco and Italy came into force… As a direct result, Monaco now appears on the Italian ‘White List’ of tax compliant jurisdictions. The Agreement creates both opportunities and challenges for companies or individuals that fall within its scope, and is an… – Continue reading
Overview of the Tax As expected, the Government of Ontario has introduced a new non-resident speculation tax (“NRST”) that takes effect on April 21, 2017. The NRST is a 15% tax payable on the purchase of an interest in residential property located in the “Greater Golden Horseshoe” area (which includes… – Continue reading
The Canada Revenue Agency (CRA) will dedicate resources to ensuring that the real estate sector in the Greater Toronto Area (GTA) complies with the tax laws. The commitment of CRA resources was one of the outcomes of a meeting between the federal and Ontarian finance ministers and the Toronto Mayor… – Continue reading
Filing of your income tax return (ITR) is mandatory under the Income Tax Act, 1961 under certain circumstances. For instance, if someone’s income exceeds the maximum amount not chargeable to tax, one is required to file income tax return. Similarly, filing ITR is mandatory for ordinary residents having overseas assets… – Continue reading
SIX Financial Information announced that has launched a new Common Reporting Standard (CRS)/ Automatic Exchange of Information (AEoI) data service, enabling financial institutions to meet the requirements which are being phased in from June 2017. The SIX CRS/AEoI service identifies CRS-reportable client income by flagging relevant corporate actions, simplifying resource-intensive… – Continue reading
MUMBAI: Custodians for foreign portfolio investors and tax consultants are in a deadlock with both parties refusing to take the onus of potential liabilities of their clients in the new tax regime. The custodians, mainly foreign banks, want a certificate from consultants such as the big four firms stating that… – Continue reading
A new report from Transparency International has revealed that more than US$2.7 billion worth of property in Sao Paulo, Brazil’s biggest city, is hidden behind shell companies, many of which have close links to the United Kingdom, which has many offshore tax havens in its overseas dependencies. Using newly released… – Continue reading
A new report from Transparency International has revealed that more than US$2.7 billion worth of property in Sao Paulo, Brazil’s biggest city, is hidden behind shell companies, many of which have close links to the United Kingdom, which has many offshore tax havens in its overseas dependencies. Using newly released… – Continue reading
The Revenue Department on Friday said it has detected evasion of more than Rs 1.37 lakh crore in both direct and indirect taxes and identified over 1,000 shell companies which indulged in bogus transactions worth Rs 13,300 crore in the last three financial years. Warning tax evaders, it said the… – Continue reading
Denton warns people of the long-term implications of stripping down their pension A new double tax treaty (DTA) between the UK and the UAE, which becomes effective April 6, will allow UAE residents to access their UK pension free of UK income tax, according to an expert. David Denton, Head… – Continue reading
The Philippines is currently a signatory to 41 tax treaties that address double taxation situations. MANILA, Philippines – According to Philippine law, nonresidents with income sources in the Philippines are required to file taxes. For these individuals who reside in a different country but receive income from the Philippines, double… – Continue reading
The federal government is considering doubling the tax rate applied to more than $199 billion worth of so-called stapled structures, in a move that experts say could scare off foreign investors. Separate securities, such as a share in a company and a unit in a trust, can be stapled together… – Continue reading
Property buyers will be quizzed about their tax residency under new anti-money-laundering rules being introduced by Westpac and its subsidiaries St George Bank, Bank of Melbourne and BankSA. Mortgage brokers, who act as intermediaries between the banks and buyers, are being told that from this week they must also ask… – Continue reading
Beware of the dreaded inheritance tax and changes to it from April 2017! Approximately 1.3 million Britons now live in Australia and Brexit may only increase this number! Many think that moving to Australia means they no longer need to worry about UK tax, but often they are not fully… – Continue reading
The Caribbean Community is looking at spending nearly quarter of a million dollars on a Washington-based consultant to lobby the Trump administration about the Foreign Accounts Tax Compliance Act. Cayman appears unlikely, however, to be affected by any lobbying – or even FATCA repeal – in the wake of last… – Continue reading
(HP) A new law which was voted last month is set to ensure an exclusive residence permit in Luxembourg to high net worth investors, entrepreneurs and talent from outside the European Union. Due to be published early June, the draft law introduces five new residence permits, putting in place new… – Continue reading
You might have thought you have enough on your plate getting to grips with anti-money laundering rules closely followed by FATCA – but it’s not over yet! Next off the block is the Automatic Exchange of Financial Account Information in Tax Matters (AEOI). The AEOI, which we first provided an… – Continue reading
Last November, the High Court’s decisions in Bywater Investments and Hua Wang Bank (Bywater) confirmed that a number of companies incorporated overseas were nevertheless Australian resident for tax because they “carried on business” and had their “central management and control” (CM&C) in Australia. The facts were extreme: the primary judge… – Continue reading
The Central Board of Direct Taxes (CBDT) has on 24th January 2017 issued final guidelines for determination of “Place of effective management”(POEM). On 27th of January, again CBDT released clarifications on “General Anti Avoidance Regulations” (GAAR). POEM is effective April 01,2016 whereas GAAR is effective from April 01,2017.POEM can be… – Continue reading
The new regulations expand the filing requirements for Form 5472 to include disregarded entities with foreign owners when there are certain reportable transactions. If a non-U.S. person (individual or corporation) owns 100 percent of the stock of a U.S. corporate subsidiary, the subsidiary needs to obtain an employer identification number… – Continue reading
A tax tribunal has ruled against a stamp duty land tax (SDLT) avoidance scheme used by Crest Nicholson, one of the UK’s largest house builders, meaning it will have to pay the £1.3m it owes. HM Revenue & Customs (HMRC) challenged the artificial and complex arrangements made by the FTSE… – Continue reading
From 6 April 2017, non-dom owners of UK property will be liable to inheritance tax (IHT) at 40% on any UK residential property they own. This has always been the case where a non-dom (broadly an individual who is resident in the UK but who has their permanent home abroad)… – Continue reading
The United States Court of Federal Claims has turned down a claim from an Irish citizen that more than USD5m in US tax withheld on gambling winnings should be refunded under the US-Ireland double tax avoidance treaty. The claim was filed by the plaintiff, John P McManus, after USD5.22m in… – Continue reading
These three CGT exclusions have remained unchanged for five years. Over the last few years government has collected a significant amount of tax revenue by not fully adjusting the personal income tax tables for inflationary increases in earnings, thereby increasing the effective tax rate of individuals. A middle-class individual earning… – Continue reading
The parliament transposed the EU regulation, whose aim is to secure comprehensive and effective administrative collaboration between tax administrations via mandatory automatic exchange of information. International corporations will be required to submit reports about their activities in every EU country in which they do business. This stems from the amendment… – Continue reading
The Italian Revenue Agency is stepping up its fight against international tax evasion. The tax authority will focus on undeclared funds and income held abroad by Italian taxpayers who have become resident abroad since January 1, 2010. Controls will be based on selected lists, which will first target the most… – Continue reading
What is a business expense deduction? A business expense deduction is a deduction allowed for ordinary and necessary expenses paid or incurred in connection with an individual’s trade, business or profession. IRC Section 62(a)(1) operates to assure that all trade or business expenses, deductible as delineated under specific IRC Sections,… – Continue reading
The New Zealand Parliament has passed a Bill which, following royal assent, will meaningfully increase disclosure obligations for NZ resident trustees of NZ foreign trusts. The Taxation (Business Tax, Exchange of Information, and Remedial Matters) Bill, was passed by Parliament on 14 February 2017. The Bill contains important provisions relating… – Continue reading
The new Residence Nil Rate Band will allow people to pass on property to their descendants tax free. But some people need to take action now or risk missing out. In April, a major change to inheritance tax (IHT) law comes into effect with the launch of the Residence Nil… – Continue reading
On 22 December 2016 the Luxembourg Parliament passed article 56bis of the Luxembourg Income Tax Law (LITL). This provision gives taxpayers and tax authorities more guidance on how to apply the arm’s-length principle. The new article can be seen as a transposition of OECD BEPS reports (actions 8-9-10) released in… – Continue reading
U.S. multinational companies with more than $850 million in annual consolidated gross income now have draft instructions for filing IRS reports on their global tax and profits. The Internal Revenue Service added instructions to the draft Form 8975 and accompanying draft Schedule A it released in December 2016, companies that… – Continue reading
A bombshell hidden in the detail of the 2017 Budget review relates to the taxation of offshore trusts. It refers to the 2015 Budget review in which it was announced that measures would be introduced to the tax treatment of foreign companies held by interposed trusts. No specific countermeasures were… – Continue reading
The National Assembly of the Republic of Srpska (RS) adopted amendments to the Profit Tax Law on 28 December 2016. The main changes have become effective as of 1 January 2017 and will be briefly presented in this article. With the amendments, the Law clarifies the definition of “taxable person”… – Continue reading
The CRA has the power to make a transfer pricing adjustment to any amount for a taxation year under s. 247(2) in respect of a non-arm’s length cross-border transaction. A taxpayer is also liable to a 10% penalty under s. 247(3), which penalty is determined with reference to the taxpayer’s… – Continue reading
The OECD has recommended that Sweden rebalance its property tax system. In its latest Economic Survey for the country, the OECD said that Sweden’s favorable tax treatment of owner-occupied housing is regressive, benefiting relatively high-income households most and contributing to the high demand for housing. It said it also encourages… – Continue reading
Background Switzerland levies federal withholding tax at the rate of 35% on certain capital income, including dividend distributions of Swiss corporations. The federal withholding tax is fully refundable for Swiss resident recipients, provided that they (i) are beneficially entitled to and (ii) correctly declare respectively account for the taxable income…. – Continue reading
‘Private Banking’ is a term that usually conjures up images of secret banking transactions being carried out on behalf Royal families, the landed gentry and wealthy individuals. That’s how private banking started, but is not a fair reflection of private banking today. Today, it’s not your family tree that matters… – Continue reading
With the arrival of the new year, don’t be surprised if your bank asks for information about yourself and your accounts that you didn’t have to provide before. These questions signal an important development as banks in Hong Kong and around the world prepare to share certain information with tax… – Continue reading
Individuals who will be deemed UK domicile from 6 April 2017 should be considering their options with regard to offshore trusts as a matter of priority. On 5 December 2016, the UK Government published the Reforms to the taxation of non-domiciles: further consultation outcome, which provided clarity on the following… – Continue reading
The OECD made its end-November 2016 deadline to release the text of the multilateral treaty to give effect to the BEPS Actions which involve changes to tax treaties, see here. The 49 page treaty text, which is commonly referred to as the multilateral instrument or MLI, and 85 page explanatory… – Continue reading
