Stock award is a popular method of rewarding talented and industrious employees. However, employees who render services across different jurisdictions may trigger a taxable presence in two or more jurisdictions. Such employees at times need to deal with the issue of double taxation on such benefits. A normal stock incentive… – Continue reading
Swiss citizens voted against a referendum to dramatically slash immigration, in what had been described as an effort to protect the environment from a wave of resource-consuming new arrivals. Early results by polling agency gfs.bern, published by public broadcaster RTS, showed that 74 percent of Swiss voters turned down the… – Continue reading
WEALTHY foreigners who have sought tax exile in Switzerland could be tempted to find a new home elsewhere — many in Britain — if Swiss voters back a referendum today abolishing their special status. Polls suggest the move could be approved by a narrow margin, leaving the 5,600 beneficiaries of… – Continue reading
More than 23,000 foreign and offshore companies have developed profitable activity in Greece over the last thirty years. Data released by the Greek newspaper “TA NEA” show that most foreign and offshore companies acquired a Greek taxpayer identification number (TIM) and legal representatives in Greece between the 1980s and 2011…. – Continue reading
Pascal Soriot has said that controversial inversion tax deals, branded ‘unpatriotic’ by President Obama, are still taking place despite attempts to curb the practice AstraZeneca’s chief has said inversion deals used by US companies to escape high taxes at home are not over despite a major clampdown on the practice…. – Continue reading
November 28: Nigeria’s Federal Inland Revenue Service previously indicated that it would no longer accept tax returns filed by non-resident companies on a “deemed profit basis,” but that non-resident companies must file their tax returns on an “actual profit basis.” These returns are to include audited financial statements as well… – Continue reading
Passage by the French assembly on 18 November 2014 of a draft Finance Bill for 2015 (which now will be presented to the Senate) Introduction by the French government on 12 November 2014 of a second draft amended Finance Bill for 2014 In general, the draft Finance Bill for 2015… – Continue reading
Refund Management Services (http://www.RefundManagement.com), the number one choice for Canada’s biggest winners for U.S. gaming and casino tax refunds, is issuing its congratulations to the World Series of Poker (WSOP) Main Event champion and weighing in on international gaming tax exemption laws. The WSOP is held annually in Las Vegas,… – Continue reading
THE Institute of Certified Public Accountants of Cyprus (ICPAC) said that action is needed to mitigate the impact on the local financial services sector from a recent Russian law cracking down on Russian offshore business. Speaking at a press conference in Nicosia, ICPAC chairman Yiannis Charilaou said however that the… – Continue reading
Love him or hate him, you have to say that Boris Johnson makes a very good point about FATCA. Having been hit with a US tax bill due to his unwanted dual citizenship, Johnson – who is as British as they come in all fairness – says he will not… – Continue reading
An Australian parliamentary committee on Thursday (Nov 27) recommended strengthening rules on foreign investment in the country’s booming housing market, calling enforcement of the current framework “severely lacking”. SYDNEY: An Australian parliamentary committee on Thursday (Nov 27) recommended strengthening rules on foreign investment in the country’s booming housing market, calling… – Continue reading
Strategies: Economists suggest removing easy avoidance VANCOUVER — Never mind that business-friendly tax policies – reforms like the dramatic reductions in federal and provincial corporate taxes over the past decade or so – enhance international competitiveness. This doesn’t impress the electorate when the benefits go mostly to the relative handful… – Continue reading
Canadian taxpayers with an interest in a partnership that holds specified foreign property (as defined in subsection 233.3(1)) may face uncertainty when assessing their form T1135 (“Foreign Income Verification Statement”) filing obligations. Depending on the partnership’s structure, either (1) the taxpayer may be required to file form T1135 in respect… – Continue reading
Should London’s Mayor Boris Johnson pay U.S. taxes and file FBARs? Born in New York, the iconic London mayor never gave up his U.S. citizenship. But rather than quietly paying U.S. taxes, Mr. Johnson in an NPR interview called it ‘outrageous’ to tax U.S. citizens on their global income. Mayor… – Continue reading
The Estonian government has become the first country in the world to offer e-residency to non-citizens. Successful applicants will be issued a digital ID card with a computer-readable chip which, in combination with authentication PIN codes, will allow them to access a number of the country’s e-services and conduct business… – Continue reading
UK resident non-domiciliaries (RNDs), who have offshore bank accounts and interests in non-UK structures, are currently not required to provide any information about those accounts/structures to HMRC, provided that they claim the remittance basis of taxation in the UK, those accounts do not hold assets which produce UK source income… – Continue reading
On November 21, 2014, as part of its Action Plan on Base Erosion and Profit Shifting (BEPS), the OECD released a discussion draft on “Follow-up work on BEPS Action 6: Preventing Treaty Abuse” (the Discussion Draft) for comments. The Discussion Draft deals with a number of issues relating to tax… – Continue reading
Boris Johnson has a point about his U.S. tax bill, but he should still cough up. The London mayor objects to the fact that his dual UK and U.S. citizenship means he has been issued with an American tax bill, and he says he won’t pay. Though many U.S. expats… – Continue reading
When FATCA was signed by Barack Obama in 2010, many commentators were quick to argue that such ‘breathtakingly extra-territorial’ provisions would never come to fruition. Fast-forward only a few years and those five letters, FATCA, have become etched in the minds of exasperated US taxpayers (many of whom are queuing… – Continue reading
Action 6 of the BEPS Action Plan identified treaty abuse as one of the most important sources of BEPS concern. The report offers alternative model provisions for the prevention of treaty abuse given constitutional and other restrictions that may apply to some treaty countries. Notwithstanding, each alternative shares a common… – Continue reading
Action Item 5 of the BEPS Action Plan commits the Forum on Harmful Tax Practices (“FHTP”) to: “revamp the work on harmful tax practices with a priority on improving transparency, including compulsory spontaneous exchange on rulings related to preferential regimes, and on requiring substantial activity for any preferential regime. It… – Continue reading
In our previous post, we looked at the ways that global corporations minimise their tax burdens by routing income through offshore tax havens and transfer pricing. The ultimate beneficiaries of these shenanigans, of course, are actual people rather than legal entities. Many of these people also take advantage of offshore… – Continue reading
Should London’s Mayor pay U.S. taxes? How about filing FBARs and other forms that make it easy for the IRS to track his bank accounts? London’s Mayor Boris Johnson is English, but being born in New York means he’s American too. Turns out he never gave up his U.S. citizenship,… – Continue reading
Tax agency asking for thousands 9 years later after suddenly changing their tax status It was Benjamin Franklin who said, “in this world nothing can be said to be certain, except death and taxes.” But in the case of Calgary residents Elise and Edwin Britton, an $18,000 tax bill from… – Continue reading
IN July 2014, the Federal Inland Revenue Service (FIRS) sent letters to some tax consultants requesting their non-resident clients operating in Nigeria to file complete tax returns effective from 2014 tax year. In practice, non-resident companies file their tax returns on the deemed profit basis. Following an initial period of… – Continue reading
IRS announces relief for accounts opened recently by non-residents aliens Jeffrey S. Freeman, J.D., LL.M notice on October 16, 2014 (Notice 2014-59, 2014-44 IRB) the IRS announced changes to the temporary regulations issued earlier this year under the Foreign Account Tax Compliance Act (FATCA). The changes provide relief from withholding… – Continue reading
Oxfam is urging world leaders at the G20 to crack down on tax havens, saying poorer countries are losing $100 billion a year through tax avoidance. It’s expected that an announcement will be made this week on a strategy for countries that are not members of the G20 or OECD… – Continue reading
MOSCOW, November 10. /TASS/. Russia is speeding towards the adoption of anti-offshore legislation. The State Duma (lower house of parliament) on Tuesday will hold the first reading of amendments to the Tax Code obliging both individuals and legal entities to notify the authorities of their foreign properties and profits. This… – Continue reading
The Financial Transaction Tax (FTT) ensures that we have learnt the lessons from the banking crisis. Unless we accelerate the work on improving the rules so that they are adequate to an environment of globalisation, we will destroy the support for the European integration and that will be the end… – Continue reading
The recent decision of the U.S.Tax Court, in Gerd Topsnik, (2014) makes it clear that an “informal” surrender of a Green Card, while recognized under immigration laws is not recognized for tax purposes. As stated in Checkpoint, ” The Tax Court held that because the taxpayer did not formally abandon… – Continue reading
With the imminent dawn on tighter tax and social security controls Spanish and other cross border workers are being urged to make sure they know their rights and obligations. The Chronicle commissioned a briefing report from Hassans (see page 4) which sets out key issues. It was reported earlier this… – Continue reading
Moving overseas, or returning to Australia after a stint abroad, is not just a lifestyle or career decision. It also has far-reaching financial implications that are invariably overlooked until years later. While these often involve what to do with retirement money overseas or the tax implications of selling assets owned… – Continue reading
Financial institutions based in certain British Overseas Territories (BOTs) and Crown Dependencies (CDs) will be subject to stricter reporting requirements covering accounts held with them by UK resident non-UK domiciled taxpayers from 2016 if specific “carve outs” are not negotiated, an expert has said.31 Oct 2014 Private wealth tax Tax… – Continue reading
Wright Medical Group Inc. (WMGI), a U.S. maker of bone implants, will merge with Tornier NV, creating a new company valued at $3.3 billion in the latest proposed tax inversion since tighter rules were announced last month. The legal address for the new company, to be called Wright Medical Group… – Continue reading
73 per cent of Americans who live outside the U.S. are tempted to give up their U.S. passports in response to the introduction of FATCA (Foreign Account Tax Compliance Act), reveals a new survey by one of the world’s largest independent financial advisory organizations. The findings come as Federal Register… – Continue reading
The number of Americans renouncing U.S. citizenship increased 39 percent in the three months through September after rules that make it harder to hide assets from tax authorities came into force. People giving up their nationality at U.S. embassies increased to 776 in the third quarter, from 560 in the… – Continue reading
Significant numbers of people are continuing to renounce their U.S. citizenship or end their long-term U.S. residency. There are 776 names on the Treasury Department list published Friday for the third quarter of 2014. That’s the third highest quarterly figure ever, according to Andrew Mitchel, an international tax lawyer in… – Continue reading
Lump sum taxation, the tailor-made measure tax regime designed to attract wealthy foreigners to Switzerland, is facing a crucial test as voters head to the polls on November 30 to decide whether or not to abolish the system for good. Proponents of the initiative say lump sum taxation is unfair… – Continue reading
The Organization for Economic Cooperation and Development’s (OECD) plan for base erosion and profit shifting (BEPS) is already affecting corporations, according to speakers participating in a Captive Insurance Companies Association (CICA) transfer pricing webinar. Polling results during the webinar revealed attendees’ opinions were in line with tax industry surveys indicating… – Continue reading
Ireland’s hard-pressed taxpayers are set for the first easing of austerity in seven years when tax cuts are announced in tomorrow’s payback budget. October 14 2014 will go down as a watershed in a painstaking economic recovery, four years since a banking collapse bankrupted the State and less than a… – Continue reading
It is time for an inquiry into HMRC’s competence, policy, decision-making processes and duty to provide transparency Thomas Paine’s observation that what first was plunder later assumed the name of revenue is well-understood by those who have chosen to make their living abroad. Individuals move for various reasons: career development,… – Continue reading
OPINION: How often do you hear governments say ‘we’re not sure if it will work, but we’ll give it a shot’? Not a lot, Chalkie would say. Lack of evidence that a policy will produce the desired effect is generally its death knell, particularly if said government was not keen… – Continue reading
The non-legislative measures put forward by the Treasury Department on September 22, to deter multinationals from using corporate inversions to move their tax residence abroad and move away from the high United States tax rate, have so far produced a mixed bag of results. The measures are aimed at preventing… – Continue reading
(CS) As part of a European tour organised by Republicans Overseas, US Senator Mike Lee on Tuesday visited Luxembourg to rally support for the repeal of the Foreign Account Tax Compliance Act, more commonly known as FATCA. Luxembourg and the US signed FATCA as an inter-governmental agreement in March this… – Continue reading
In view of the frenzy in the profession over compliance with the new FATCA rules, it seems appropriate to take an overview of how FATCA applies to a major source of inbound investment by foreign individuals – “FIRPTA” investments in U.S. real property. This commentary considers the extent to which… – Continue reading
For Europeans looking for a slice of the good life, Spain has long been the most popular destination. At the time of the last census in Spain, almost 12% of the country’s population was born overseas, up from less than 1% only a few decades earlier. These days Spain is… – Continue reading
Poland’s Finance Ministry is trying to make sure that a new regulation against corporate income tax avoidance comes into force before the end of the year. In cooperation with the ministry, a group of MPs has submitted an amendment to the recently approved regulation, which cuts short its vacatio legis… – Continue reading
By Jung Min-ho Seung Eun-ho Chairman of Korindo Group Prosecutors are investigating allegations that the head of Korindo Group, a Jakarta-based conglomerate, and his sons have evaded taxes. The Seoul Central District Prosecutors’ Office said Monday that the group’s Chairman Seung Eun-ho and his two sons are suspected of evading… – Continue reading
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
FATCA, or the Foreign Account Tax Compliance Act, has been in effect for several months. The global tax law is aimed at rooting out Americans living outside of the United States who are not paying their U.S. taxes. But many expatriate Americans in Canada are fighting back. There are more… – Continue reading
