Category: Investments

IRS Calls on Coca-Cola to Pay Up

Coca-Cola might owe an additional $3.3 billion in federal income taxes following an audit, says the Internal Revenue Service (IRS). Following a five year audit of the company, the IRS concluded that the company’s strategy of lowering its taxable income through transfer pricing, underestimates the amount the company should’ve been… – Continue reading

Europe wants to get to the core of our Apple issue

The European Commission looks highly likely to make a finding against Ireland in relation to its tax arrangements with Apple, following two similar findings during the week involving Starbucks and Fiat. It is perplexing that the EC doesn’t just come out and make the announcement. The delay is leading to… – Continue reading

Tax Planning for Chinese Investment in U.S. Real Estate

According to recent estimates, Chinese investors represented the largest group of foreign investors in U.S. real estate in the second quarter of 2015 with $1.9 billion in acquisitions. In the last 12 months, Chinese investors acquired $5.9 billion in commercial U.S. real estate, and Asia was second overall to Europe… – Continue reading

India fails to get to root of black money problem

The Indian government’s initial unsuccessful efforts to unearth billions of dollars of undeclared foreign assets – some believed to be hidden in Swiss banks – highlight the complexity of vehicles used to move money illicitly. Earlier in the year, a new law on black money came into effect. It included… – Continue reading

Challenges for family offices in emerging markets

Leading family offices in Latin America and the Caribbean are going through a transitional period, says Steven Cantor, managing partner of Cantor & Webb, a Miami-based law firm, reports the Financial Times. “As the world moves to tax transparency, with a crackdown on undisclosed tax savings in Swiss bank accounts,… – Continue reading

Chevron loses long-running battle with ATO, faces multimillion-dollar tax bill

Multinational oil giant Chevron has been hit with a tax bill of about $300 million after losing a landmark profit-shifting case that could have global implications for the way tax is assessed. The Australian Tax Office’s case in the Federal Court case has been closely watched by the tax and… – Continue reading

Ireland: The taxman’s verdict

Pascal Saint-Amans sups water from a plastic cup, coughing and spluttering. There’s a weariness about him. He’s battling a cold, and is feeling “bloody sick”. The state of his health isn’t terribly surprising given his recent punishing travel schedule. New York last week preceded by Peru, where G20 finance ministers… – Continue reading

Mauritius eyes Africa as pressure mounts on offshore business

Mauritius beats Singapore as the world’s top route for foreign investment to India and is a hub for thousands of firms managing half a trillion dollars in assets. But there are only a sprinkling of office blocks in Ebene Cybercity, the heart of the tiny Indian Ocean island’s financial services… – Continue reading

Tax Justice for Social Justice

By Martina Neuwirth and Thomas Kattnig [This blog article published on July 9, 2015 is translated from the German on the Internet, http://blog.arbeit-wirtschaft.at.] June 23 was the international day of public services. Did you know that? Provision of these services – water, hospitals, schools, culture, energy, streets, public transportation and… – Continue reading

Travelers CEO says U.S. tax policy sends insurers offshore

Congress needs to lower the corporate tax rate from its current 35% to discourage U.S. insurers from moving offshore, according to the head of Travelers Cos. Inc. “Reducing this rate would end a self-defeating policy that distorts corporate behavior, weakens domestic companies and ultimately harms the U.S. economy,” wrote Travelers… – Continue reading

UAE and Mauritania sign agreements on preventing double taxation and boosting investment

NOUAKCHOTT 22nd October 2015 (WAM) — The UAE and Mauritania yesterday signed two agreements preventing double taxation and protecting and promoting investment between the two countries. The agreements were signed by H.H. Sheikh Abdullah bin Zayed Al Nahyan Foreign Minister and Hamadi Ould Baba Ould Hamadi Mauritanian Minister for Foreign… – Continue reading

The Self-Defeating Corporate Income Tax

For many years, policy makers have criticized the strategies that American corporations use to reduce their taxes by shifting income and capital offshore. The impetus behind these strategies is the U.S. corporate income-tax rate — at 35 percent, the highest of any industrialized nation, easily surpassing countries such as the… – Continue reading

Benefits of UAE-Based Offshore Companies

Offshore companies are established for a variety of reasons including a company’s necessity to restructure, create an international business entity as well as protect the assets of the company. The United Arab Emirates (UAE) is home to three authorities that register International or offshore companies. The three UAE authorities that… – Continue reading

Surge in outbound payments hint at expats’ bid to escape American tax authorities

MUMBAI: There is a sudden, inexplicable surge in money that Indians are sending abroad for ” maintenance of close relatives“. Such fund transfers typically add up to $10-20 million a month. But in July 2015, according to the latest available data, total remittance under this head crossed $124 million. Also,… – Continue reading

New tax treaty between the Netherlands and Curaçao enters into force

Executive summary A new bilateral Tax Arrangement between the Netherlands and Curaçao (TANC), which essentially functions as a tax treaty,1 was ratified by the Dutch Parliament and formally published on 9 October 2015. The TANC will apply to income received on or after 1 January 2016. This long-awaited TANC will… – Continue reading

China: Discussion Draft For The Implementation Measures For Special Tax Adjustments —A Brand-New Epoch For Transfer Pricing Administration In China

On 17 September, 2015, China State Administration of Taxation (SAT) released the Discussion Draft for the Implementation Measures for Special Tax Adjustments (“Discussion Draft”), as a complete revamp to the existing trial version of the Implementation Measures, i.e., Circular 2. Circular 2 has been serving as a backbone transfer pricing… – Continue reading

Australia Launches Serious Financial Crime Taskforce

Australia’s new Serious Financial Crime Taskforce (SFCT) is to launch investigations into serious international tax evasion and “phoenix activity” over the next two years. The SFCT has been operational since July 1 and, as of October 14, there are eight matters under investigation. More than 580 tax audits have been… – Continue reading

What Singaporeans need to know when buying UK residential property

The rising wealth of Asia Pacific nations, including Singapore, means more and more people have looked internationally for opportunities to invest in overseas property markets. Recent stock market events have shown the importance of a diversified portfolio capable of riding out the storm when economic conditions put immense pressure on… – Continue reading

Mauritius Wants To Be To Africa What Dubai Is To The Middle East

Concerned about the impact of tax havens, world powers are tightening the noose on multinationals seeking tax advantages. India wants changes to its tax treaty with Mauritius, forcing the island’s new government to re-examine its business model and focus elsewhere. There is debate in the new government, which took office… – Continue reading

IRS updates guidance on US-Canada DTA

The Internal Revenue Service (IRS) has released a revised October 2015 version of its Publication 597, which provides information on the United States-Canada double taxation agreement (DTA), reports Tax News. A number of DTA provisions that most often apply to US citizens or residents who may be liable for Canadian… – Continue reading

Real estate, the golden visa and tax

Golden visa EU citizens may freely register as residents in Portugal. However, non-EU citizens may also obtain residence in Portugal if they obtain a ‘golden visa’ by participating in investment activity and fulfilling certain requirements. Requirements Obtaining a golden visa requires one of the following types of investment: acquisition of… – Continue reading

Is a Canada Revenue Agency landlord avoiding taxes via offshore havens?

The Canada Revenue Agency (CRA) rents office space from a Vancouver-based property developer – a company that exploits offshore tax havens in Liechtenstein, the British Virgin Islands and Channel Islands. Larco Investments Ltd. owns three buildings in Montreal, Calgary and Edmonton where they rent office space to the CRA. Larco… – Continue reading

Foreign investment and tax: what the ATO’s expanded armoury means for foreign investment into Australia

A series of recent developments means that tax is now a key part of the Australian foreign investment regime and the foreign investment rules have significantly more bite. When determining whether a foreign investment proposal is “contrary to the national interest”, the Foreign Investment Review Board (FIRB) actively considers the… – Continue reading

FACTA and the New Frontier in Offshore Reporting Enforcement

FATCA was passed to prevent U.S. citizens from evading tax by focusing primarily on foreign financial institutions with U.S. account holders. The Foreign Account Tax Compliance Act (FATCA) was enacted as part of the 2010 Hiring Incentives to Restore Employment Act, and its provisions became effective as of 7/1/14. FATCA… – Continue reading

ANCA Welcomes Congressman Ted Lieu’s Advocacy for a U.S.-Armenia Double Tax Treaty

LOS ANGELES—The Armenian National Committee of America – Western Region (ANCA-WR) is expressing its appreciation to Congressman Ted Lieu for authoring a letter to U.S. Treasury Secretary Jacob Lew in support of a U.S.-Armenia Double Tax Treaty. The accord, if concluded, would, by limiting the prospect of double taxation, remove… – Continue reading

Putting the Final BEPS Reports into Perspective: from Recommendations to Implementation

The Organization of Economic Cooperation and Development (OECD) released its final reports on the G20/OECD Base Erosion and Profit Shifting (BEPS) Project on Monday October 5th, 2015. The final package of BEPS measures includes new minimum standards on: country-by-country reporting, which for the first time will give tax administrations a… – Continue reading

Dhaka, Thimphu in talks to sign double taxation avoidance deal

Staff Correspondent The National Board of Revenue on Monday started negotiations with Bhutan to sign an agreement on avoidance of double taxation and prevention of tax evasion and capital flight from the country. A five-member delegation led by NBR chairman Md Nojibur Rahman has been carrying out the first round… – Continue reading

Ireland, accused of giving tax breaks to multinationals, plans an even lower rate

Ireland, whose corporate tax rate of 12.5 percent is already one of the lowest in the developed world, said it would cut that rate in half for a new tax category — one covering revenue pegged to companies’ patents and other intellectual property. The Irish government, long criticized by other… – Continue reading

NBR to sign deal with Bhutan to avoid double taxation

Bangladesh is set to sign an agreement with Bhutan to avoid double taxation to boost investments, trade and facilitate information exchange between the two Saarc nations, the National Board of Revenue said in a statement. A team led by NBR Chairman Md Nojibur Rahman is now in Thimpu to take… – Continue reading

Your Taxes: OECD starts the BEPS tax revolution

Israeli importers and exporters, hi-tech and trading groups will all be in the base erosion and profit shifting firing line. On October 5 the Organization for Economic Cooperation and Development published a final comprehensive package of measures aimed at multinational corporations, large and small, that engage in BEPS – base… – Continue reading

Brazil: BEPS: Rule Of Law Can Avoid Mountains And Cloudy Skies For Companies

The tax world followed with great interest today´s launch of the final package of BEPS. Having the BEPS report finalized is indeed a great achievement and, as pointed out by Mr. Angel Gurría, OECD Secretary General, in his Twitter, “Agreement of #BEPS package is a historic day in our effort… – Continue reading

OECD publishes ‘Base Erosion Profit Shifting’ (BEPS) recommendations BEPS will have a broad impact on the region’s businesses, says PwC

PwC welcomes this effort to update international tax system and boost transparency. The tax landscape has been transformed by the globalisation of business and the advent of the digital age. We believe the existing international tax rules need to be modernised to reflect how business is done today, and it… – Continue reading

Blueprint signals thaw in India-Maldives ties

During Sushma Swaraj’s visit, the nations also sign pacts on avoidance of double taxation and tax information exchange New Delhi: India and the Maldives have drawn up a new blueprint for bilateral ties that included closer economic and defence cooperation, pointing to a thaw in the relations following the Maldives’… – Continue reading

IRELAND: KNOWLEDGE DEVELOPMENT BOX; DETAILS EXPECTED IN 2016 BUDGET

Ireland’s budget 2016 will be announced tomorrow, 13 October 2015, and it is expected that additional detail on the research and development (R&D) tax incentive known as the “knowledge development box” would be provided in the budget 2016 statement. The “knowledge development box” is a tax rate for income generated… – Continue reading

Mauritius plans derivatives platform in bid for African business – minister

EBENE, Mauritius, Oct 12 (Reuters) – Mauritius plans to launch a trading platform to hedge African currencies against the U.S. dollar, part of a bid to expand its role as a financial hub for the continent, the financial services minister said. The Indian Ocean island is also in talks to… – Continue reading

Sen. Sherrod Brown pitches plans to tackle offshore tax havens, rebuild nation’s highways

U.S. Sen. Sherrod Brown, appearing Friday at the City Club of Cleveland, said the United States has to again understand that money that targets road and bridge development and other infrastructure improvements is an investment. “Our parents left us with a transportation system and an infrastructure that was the envy… – Continue reading

Conference on Base Erosion & Profit Shifting; Confederation of Indian Industry

EVENT OVERVIEW Globally, countries are campaigning for watertight tax regimes and gradually but definitely towards commercially driven business practices, and BEPS seems to be the way to it. Around 44 countries, including India, have come together to create a code to enable looking at transactions with a borderless lens for… – Continue reading

Central Board of Direct Taxes feels black money recovery difficult

A senior officials say they have no legal jurisdiction over the accounts maintained in foreign countries and governments there can cooperate only in case of established criminal conspiracy While the government has threatened rigorous action against black money hoarders after tepid response to its one-time compliance window, it may have… – Continue reading

Global film scheme gang on trial for £100m tax fraud

A financial adviser and a group of film producers who set up an international scheme are facing a trial for fraud. It is alleged the scheme, which took advantage of the tax relief the UK Government offers the film industry, created the appearance of huge “paper losses”, The Times reported… – Continue reading

Uber and Airbnb confirm they send profit offshore

Uber and Airbnb have revealed in submissions to a federal inquiry that they route profit through companies in the Netherlands and Ireland, where taxes are lower. Uber and Airbnb have told a Senate corporate tax avoidance inquiry that while they comply with Australian tax laws, their Australian operations merely provide… – Continue reading

Russian Federation: Russian 2015 Tax Revolution

For many years international tax planning for Russian inbound and outbound investments, and wealth planning for Russian resident individuals, was rather straightforward. That was primarily due to relatively simple domestic tax rules and a degree of inexperience amongst the Russian tax and other interested authorities in relation to international tax… – Continue reading