Category: Forms

Switzerland: Tax Briefing – Switzerland Takes Next Steps Towards Automatic Exchange Of Information In Tax Matters (AIA)

1. Introduction On 14 January 2015, the Swiss Federal Council opened consultations on two draft laws on the international exchange of information in tax matters. One of them deals with the OECD/Council of Europe administrative assistance convention signed by Switzerland on 15 October 2013. The other consultation deals with Switzerland’s… – Continue reading

AM 2015-01—does previously taxed income “tier up” to a domestic corporate shareholder?

Introduction In a recent chief counsel memorandum (AM 2015-01), the IRS addressed a long uncertain tax question: when a US corporate shareholder includes an amount in income under subpart F, does the subpart F inclusion increase the corporate shareholder’s “earnings and profits” immediately or only when the earnings are actually… – Continue reading

QROPS for US Residents – FATCA & IRS Compliant

For British pension holders in the US, transferring into a Qualifying Recognised Overseas Pension Scheme (QROPS) is now commonplace. These pension solutions are widely accessible to all US residents or nationals who have accrued pensions from their time working in the UK, and are an invaluable aspect of financial planning… – Continue reading

No Agreement On BEPS Foreign Company Income Definition

Law360, New York (April 06, 2015, 3:10 PM ET) — A draft report released Friday by the Organization for Economic Cooperation and Development on strengthening controlled foreign-company rules to crack down on tax evasion said there are substantial disagreements among member states about how to best define CFC income. The… – Continue reading

Australia: US Citizens and Green Card Holders – the long arm of the IRS

You may be forgiven for thinking that once you no longer live in the United States, that your ongoing US tax obligations may be relatively simple or even non-existent, particularly if you have never held a US Passport or lived in the US. However the definition of US citizen is… – Continue reading

$32 Trillion Stashed in Offshore Bank Accounts – Asset Protection Planners Examine the Facts

More and more Americans are opening offshore bank accounts. This article provides statistical details about why this is so, that offshore banking can be safe and legal and which banking jurisdictions are safest. Apr. 3, 2015 / PRZen / VALENCIA, Calif. — Offshore banking is growing in leaps and bounds… – Continue reading

Vietnam – FATCA reporting guidance

April 2: Guidance from the State Bank of Vietnam provides financial institutions and branches an automatic 90-day extension of time in which to file their FATCA reporting forms. Therefore, financial institutions have until 30 June 2015 to file their FATCA reports to the U.S. tax agency (IRS). KPMG observation Pending… – Continue reading

Global Tax Transparency Goes Live in 2016

Cross border tax fraud and tax evasion by High Net Wealth Individuals (HNWI) are serious problems for many jurisdictions. For many years exchange of information between countries has been solely upon request. In practise this procedure is not efficiently working as it requires foreseeable relevance, thus ‘fishing’ for information is… – Continue reading

Big business took $25 billion in tax relief in 2014, Tax Office figures show

Australia’s biggest 900 companies claimed tax deductions and exemptions worth a total $25 billion last year – enough to wipe out two-thirds of the current federal budget deficit at a stroke. As Treasurer Joe Hockey prompted a national “conversation” about tax reform, including the prospect of a higher and broader… – Continue reading

EP takes stance on tax transparency, burdens, avoidance and evasion

Tackling tax evasion should be a top EU priority. EU countries and the European Commission should play a leading role in discussing how to fight tax fraud and aggressive tax planning in the OECD and other relevant fora, says Parliament in its resolution on tax, voted on Wednesday. The resolution,… – Continue reading

Taxpayers Australia tackle ‘tiny’ Facebook

In a recent Senate Estimates hearing, Greens Senator Christine Milne probed ASIC representatives to explain why they consider Facebook Australia a ‘small’ company, especially considering the parent organisation is worth a staggering $US33.3 billion. Facebook Australia is a ‘small’ company by its own determination and it is registered as such… – Continue reading

IRS Releases Long-Awaited Instructions to FATCA Form

Foreign entities use this to document their status On June 25, 2014, the Internal Revenue Service released long-awaited instructions to Form W-8BEN-E, used by foreign entities to document their status under both chapter 3 and chapter 4 (the Foreign Account Tax Compliance Act (FATCA)) of the Internal Revenue Code. The… – Continue reading

The 92 forms newly specified by the Registrar of Companies for use after the commencement of the new Companies Ordinance (Chapter 622) on 3 March 2014 have been uploaded onto the dedicated thematic section New Companies Ordinance. A CD-ROM containing a full set of the new forms and hard copies of… – Continue reading