Category: Statutory

Property sales spike sparks money laundering fears

Suspicions rising that ‘hot money’ is being washed through Vancouver real estate As affluent Chinese buyers – spurred by relaxed regulations and a lower Canadian dollar – flood into British Columbia’s real estate market, warnings are rising that some cash deals may contravene federal money laundering rules. A 2015 report… – Continue reading

Rand Paul’s Record Shows He’s a Champion for Tax Cheats and the Wealthy

No member of Congress has been more active in the cause of protecting tax cheaters and tax avoidance by our nation’s wealthiest individuals and corporations than Sen.(now presidential candidate) Rand Paul. While Paul is a standard bearer of anti-tax conservatives through his advocacy of radical policies such as the flat… – Continue reading

Australian Foundation Investment Company gives tax grab warning over dividends

MANY retirees could be forced on to age pensions if they lose tax credits on dividends, Australia’s biggest listed investment company has warned. Australian Foundation Investment Company general manager Geoff Driver says retirees would have less income if the dividend imputation system were scrapped. Higher demand for age pensions would… – Continue reading

News Corp CEO Julian Clarke rejects tax avoidance claim

Allegations that News Corp engaged in an aggressive tax avoidance scheme have been strongly rejected by the company. News Corp Australia chief executive Julian Clarke said in a statement: “This claim is based on a fundamental misunderstanding of the nature of these transactions, US and Australian tax treaties and applicable… – Continue reading

Seychelles Sets Out Transfer Pricing Regime

The Seychelles Revenue Commission has issued, for comment, Public Ruling 2015-3, which explains the authority’s rules and procedures to enforce the arm’s length principle in respect of related-party transactions under Section 54 of the Business Tax Act, 2009. The Ruling states that in applying the arm’s length principle, the Commissioner… – 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

Azerbaijan can become economic bridgehead for Arab countries

A serious need emerges, amid the global political and economic crisis, for the dialogue among religions, cultures, different political forces, and an important role in this process is in recent years played by Azerbaijan. In this regard, the Azerbaijani President Ilham Aliyev’s visit to Saudi Arabia is significant. It is… – Continue reading

New Russian CFC Rules Will Impact Inbound U.S. Tax Planning

According to recent estimates, the number of wealthy Russians investing in the United States ballooned in 2014 as a result of political turmoil and a disintegrating ruble causing Russians to seek a safe haven for their wealth abroad. The amount of private net capital flowing out of Russia hit $120… – Continue reading

Rupert Murdoch’s US empire siphons $4.5b from Australian business virtually tax-free

Rupert Murdoch’s media empire in the US has siphoned off $4.5 billion of cash and shares from his Australian media businesses in the past two years, virtually tax free. According to calculations by University of NSW accounting academic, Jeffrey Knapp, over the past 10 years, Mr Murdoch’s companies here have… – Continue reading

Valeant Finally Bags Salix for $11 Billion

After much of a clout about who will acquire Salix Pharmaceuticals (SLXP), Canadian Drug maker Valeant Pharmaceuticals International Ltd (VRX) completed the purchase for $11 billion last Wednesday. Salix Pharmaceuticals works in gastro instrumental drugs and it will provide Valeant with new therapeutic business. This is Valeant’s biggest buy so… – Continue reading

OECD discussion draft considers Controlled Foreign Corporation Rules

On April 3, 2015, as part of its Action Plan on Base Erosion and Profit Shifting (BEPS), the OECD released a discussion draft entitled “BEPS Action 3: Strengthening CFC Rules” (the Draft) for comments. The Draft stresses the importance of CFC rules in countering base erosion and profit shifting, and… – Continue reading

Tax Pros Wary After IRS Hires Quinn Emanuel Litigators

Law360, New York (April 06, 2015, 4:47 PM ET) — Microsoft Corp. recently brought to light the IRS’ hiring of litigators from Quinn Emanuel Urquhart & Sullivan LLP to assist with examining the tech company’s transfer pricing activities, and some tax professionals say the agency’s unprecedented move is troubling. In… – Continue reading

Africa loses $528.9 billion to illicit transfers in a decade

It has been revealed that illicit financial transfers are draining Africa of massive resources needed to uplift its majority poor from the claws of poverty and provide both productive and social infrastructure for development. The African Civil Society Circle, a group of nine civil society organizations and think tanks from… – Continue reading

Developments in the Luxembourg Financial Sector

The Luxembourg supervisory authority, the Commission de Surveillance du Secteur Financier (CSSF), has recently issued FAQs regarding the immobilisation of bearer shares and units, as well as a press release to remind Luxembourg alternative investment fund managers (AIFMs) and non-EU AIFMs that market alternative investment funds (AIFs) in Luxembourg under… – Continue reading

100 foreign funds get tax demands; total bill may hit $10 bn

New Delhi/Mumbai: In the biggest-ever tax demand slapped on them, nearly 100 foreign funds have been asked to cough up an estimated USD 5-6 billion for ‘untaxed gains’ made by them in the Indian markets over the past years. The number of affected investors can rise substantially as assessments are… – 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

UFIA Bill could impact Make in India policy: Sonu Iyer

Interview with Partner and National Leader, Human Capital Services, EY India The Undisclosed Foreign Income and Assets (Imposition of Tax) Bill, 2015, popularly called the “anti-black money bill” has been in the news for its stringent and sweeping provisions. Sonu Iyer, partner and national leader, human capital services, EY India,… – 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

Rich Tory donor embroiled in ‘tax avoidance’ storm hands Harriett Baldwin £2,000 in re-election bid

A BRITISH philanthropist at the centre of a national tax avoidance storm has donated £2,000 towards a Worcestershire MP’s bid for re-election, it has emerged. Lord Fink, a multi-millionaire former hedge fund manager embroiled in a row Ed Miliband, has handed the cash to West Worcestershire Conservative Harriett Baldwin. The… – Continue reading

European Competition Law Newsletter – April 2015

EU’s Highest Court Rules on Information Exchange On 19 March 2015, the European Court of Justice (ECJ) handed down a significant judgment on the application of EU competition law to information exchange between competitors. The case was an appeal from the European Commission’s 2008 decision to fine banana importers Dole,… – Continue reading

Pensions, Taxes & Fatca: Finance Tips for British (& Other) Expats in the U.S.

We asked Vincenzo Villamena, a New York-based international tax adviser and certified public accountant with Online Taxman, and his British-expat client Ed Zitron of San Francisco, to share personal finance tips for expats, particularly those hailing from the U.K. Here are their top tips: 1. Mind your pensions & QROPS!… – 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

China ‘Through-Train’ Ends Double Taxation For Equity Investors

The Shanghai-Hong Kong Stock Exchange Connected is working out its kinks and investors are taking notice. Hong Kong and Beijing signed a tax treaty on Thursday that ends double taxation for equity traders, which was one of the sticking points for local brokers hoping to buy into China’s massive mainland… – Continue reading

China unveils plans on building Silk Road Economic Belt, 21st-Century Maritime Silk Road

The Bangladesh-China-India-Myanmar (BCIM) economic corridor and China’s proposed ‘Silk Road Economic Belt and 21st-Century Maritime Silk Road’ are “closely” related, Beijing says as it has unveiled action plans on this joint ‘Belt and Road Initiative’. Chinese President Xi Jinping during his visits to Central Asia and Southeast Asia in 2013… – Continue reading

Charting the Limits of Acceptable Tax Planning in Singapore

In 2015, Singapore celebrates its 50th year of independence and also mourns the passing of its first Prime Minister Lee Kuan Yew who steered Singapore’s success for many critical years. From its origins as a British trading post in 1819, Singapore has grown into one of the busiest ports and… – 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

United States: Uncle Sam Wants You (To Pay Tax): Income Tax Pitfalls For Americans Living Abroad

I. Introduction In an effort to crack down on individuals obtaining U.S. citizenship illegally, the U.S. Department of Justice recently raided several “maternity tourism” operations in Southern California.1 These companies cater to wealthy foreigners seeking to give the gift of U.S. citizenship to their children. Since at least 1868, the… – Continue reading

Mainland and HKSAR sign Fourth Protocol to Arrangement for Avoidance of Double Taxation

Hong Kong (HKSAR) – The Secretary for Financial Services and the Treasury, Professor K C Chan, signed the Fourth Protocol to the Arrangement for the Avoidance of Double Taxation and Prevention of Fiscal Evasion with respect to Taxes on Income with the Mainland (the Fourth Protocol) with the Deputy Commissioner… – 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

Hong Kong Tax Breaks To Support Financial Center

Hong Kong’s Secretary for Financial Services and the Treasury, K C Chan, has described the various tax policies that the Government intends to pursue in the coming year. As part of his testimony before the Legislative Council (LegCo) Finance Committee special meeting on the 2015-16 Budget, Chan stressed that the… – Continue reading

Around the World, America’s Taxman Cometh by way of the Foreign Account Tax Compliance Act (FATCA)

As Tax Day approaches, homeland Americans scurry to file their annual tax filing obligations. But for an estimated 7.6 million Americans working and living overseas, they have an obligation to not only pay taxes in their respective countries where they live; they need to pay the piper in homeland America… – Continue reading

Bitcoin A ‘Threat’ To Australia’s Tax Collection System; ATO To Clamp Down On Tax Avoidance Of Multinationals

A recently released discussion paper has found that Australia finds Bitcoin as becoming a threat to the country’s tax system. The paper said new technology and globalisation are among the main factors pushing multinational practices to engage in tax avoidance. According to the paper, news ways transacting such as Bitcoin… – Continue reading

Customs detects 6,660 cases involving tax evasion of Rs 15.82 billion in 2 years

ISLAMABAD: The Pakistan Customs detected 6,660 cases of seizures, mis-declaration or under/over invoicing involving an amount of customs duty and other taxes of Rs 15.825 billion in the last two fiscal years; 2013-14 and 2012-13. “In this connection, 110 FIRs were lodged whereas 179 persons have been arrested; resultantly, an… – Continue reading

Cash-flush corporations at center of income-tax debate

U.S. multinationals represent the healthiest segment of the economy, with higher profits and more than $1 trillion of cash on hand. This has kept corporate tax reform alive as a political issue. ON Semiconductor had a solid 2014, boosting net income by 36 percent to $196 million on revenue of… – Continue reading

Regional co-operation on investment – What does it involve?

CO-OPERATION on investment within the SADC region is an integral part of achieving the overarching objectives of the SADC Treaty. Investment, be it foreign direct investment, cross-border investment or domestic investment is needed to enhance the productive capacity in the region, which is a pre-requisite for increasing trade across borders… – Continue reading

Tax decree and circular guiding the implementation of the new Tax Law effective from 1 January 2015

In order to guide the implementation of the Tax Law on amending key tax laws which was effective from January 20151, the following guidance regulations have been issued: Decree 12/2015/ND-CP dated 12 February 2015 of the Government (“Decree 12”); and Circular 26/2015/TT-BTC dated 27 February 2015 of the Ministry of… – Continue reading

UK tax rules on disguised investment management fees: final legislation published

The UK’s Finance Bill was published on 24 March 2015. It was subsequently enacted on 26 March 2015 without further amendment and became the Finance Act 2015. The “disguised investment management fee” provisions contained in this Act, summarised below, will be effective from 6 April 2015. These rules apply to… – Continue reading