The present French Tax Update will focus on (i) the most salient features of the new double tax treaty signed by the People’s Republic of China (China) and France on November 26, 2013 (New DTT), (ii) the new double tax treaty signed by Singapore and France on January 15, 2015,… – Continue reading
The upmarket leather goods firm employing the Prime Minister’s wife is based in a tax haven. Smythson is owned through a holding company in Luxembourg and linked to a secretive trust in the Channel Island of Guernsey, another well-known tax haven. The store in Central London’s New Bond Street, which… – Continue reading
Speed read On 16 December 2014, Curaçao and the U.S. signed an intergovernmental agreement (“Curaçao-IGA”) setting out the information reporting and withholding requirements applicable to banks and other financial institutions resident in Curaçao (“FI’s”) under the Foreign Account Tax Compliance Act (“FATCA”). By virtue of the Curaçao-IGA, FI’s will be… – Continue reading
With the Senate weighing a bipartisan effort to let companies repatriate offshore cash for five years at a 6.5% rate, Google (NASDAQ:GOOG) CFO Patrick Pichette states on the Q4 CC the passage of such a bill would change how his company spends. He adds ~60% of Google’s cash is offshore,… – Continue reading
Puerto Rico’s Acts 20 & 22, tax incentive laws aimed at luring wealthy American investors to move there and at reviving the Island’s economy, are celebrating their third anniversary this month. While Puerto Rico’s economic situation remains bleak (it currently has more than $73 billion of “junk” status debt, unemployment… – Continue reading
This edition of the Tax-News monthly feature takes in noteworthy events in the international tax arena, including attempts to inject new life into the campaign for comprehensive tax reform in the United States, and developments in the areas of free trade, indirect taxation, BEPS and tax transparency and compliance. US… – Continue reading
IN THIS second installment of the series on Base Erosion and Profit Shifting (BEPS) 2014 deliverables, we will discuss the recommendations of the Organization for Economic Co-operation and Development (OECD) on how to neutralize the effects of Hybrid Mismatch Arrangements. A Hybrid Mismatch Arrangement refers to an arrangement whereby companies,… – Continue reading
A year in review: the far reach of the IRS in Canada – Foreign Account Tax Compliance Act What is FATCA? The Foreign Account Tax Compliance Act1 (“FATCA”) was enacted by the United States Congress in order to deal with non-compliance by US taxpayers using foreign bank accounts. FATCA requires… – Continue reading
Tax and estate planning usually takes place during a client’s lifetime. That said, there are post-mortem planning opportunities that you should discuss with clients. The goal of post-mortem planning is to reduce the overall tax liability for the estate and its beneficiaries. So create a customized plan to deal with… – Continue reading
The US Foreign Account Tax Compliance Act (FATCA) is in the vanguard of a global movement towards the automatic exchange of information on tax matters. The US enacted FATCA in 2010 to tackle the problem of tax evasion by US citizens and residents who under-report or fail to report income… – Continue reading
SINGAPORE (Jan 22): Keppel Corp posted a 6% rise in 4Q earnings to $726 million, or 39.9 cents per share. This was 6% above the $684 million recorded in 4Q13, led by higher pre-tax profit from most of its divisions. For the full year FY14, earnings fell 19% to $1.39… – Continue reading
President Vladimir Putin is pushing harder on Russia’s richest citizens to repatriate offshore assets amid a slump in the ruble and the imposition of sanctions by the US and the European Union, The Business Times said. Under new tax rules signed into law by a presidential decree in November, Russian… – Continue reading
SUCCESSFUL INTERNATIONAL STRUCTURES in most cases begin with choosing the right jurisdiction to host a company that will form part of an international business. Depending on the company’s activities, the choice will depend on the range of double taxation treaties and the availability of tax reliefs followed by a host… – Continue reading
President Obama reopened a fiscal can of worms with his proposal to increase the capital gains tax to 28 percent, a plan Republicans said they would not adopt. The administration has tried to paint it as a mainstream idea, noting that the rate was 28 percent under President Ronald Reagan,… – Continue reading
After almost three years’ negotiations over untaxed Italian assets in Swiss banks, Switzerland and Italy have reached an agreement in principle on future cooperation in tax matters. The agreement between Switzerland and Italy was initialled on 19 December 2014 The two governments are currently preparing the signature of a Protocol… – Continue reading
Kansas Governor Sam Brownback had championed the largest tax cuts in the state’s history, eliminating taxes on non-wage earnings for nearly 200,000 small businesses. Just like all Republicans these days, Brownback had made cutting taxes and shrinking government the centerpieces of his government. Now the great State of Kansas has… – Continue reading
Introduction Malta is increasingly becoming a financial services centre of repute looked at by a number of financial services operators as the ideal platform to set up their private pension schemes. Malta’s success is attributable to the flexible and prudent manner in which the industry is regulated, providing the desired… – Continue reading
Italy and Switzerland have agreed an amendment to their double tax agreement to enhance tax information exchange provisions. It is hoped that the agreement will be signed before the March 2 deadline set by Italy’s new voluntary disclosure program to enable Switzerland’s removal from Italy’s “black list.” After three years… – Continue reading
It explains how recent amendments to the Singapore-UAE Avoidance of Double Taxation Agreement will translate to more savings for UAE tax residents when they fund Singapore companies. Singapore (PRWEB) January 14, 2015 With the recent signing of the protocol to amend and improve the Singapore-UAE Avoidance of Double Taxation Agreement… – Continue reading
SPECIAL REPORT: IS AMERICA LOSING IT’S CORPORATE SECTOR? Corporate inversions have been the dominant tax issue over the last year and have forced a serious evaluation of the U.S. corporate tax system. While there is widespread agreement that the U.S. corporate tax code is out of step with our global… – Continue reading
From Premier International Tax Library With the publication in September of Notice 2014-52, the IRS has made it extremely difficult for any foreign corporation that is not primarily engaged in an active business to acquire a U.S. business in exchange for its stock without risking being transformed into a U.S…. – Continue reading
CRA has launched the Electronic Funds Transfer (EFT) initiative, introduced in the 2013 Budget as one of several new measures to crack down on international tax evasion and aggressive tax avoidance. Read: Top 10 tax changes of 2014 Effective January 1, 2015, certain financial intermediaries, including banks, have to report… – Continue reading
Many factors influence a foreign buyer’s decision to purchase residential real estate in the United States. Generally, most of these decisions tend to be driven by concerns over political and economic uncertainty in the buyer’s home country. Most foreigners do not leave their home country, family, and friends for trivial… – Continue reading
Barbados appears to be moving into full financial information-sharing mode as the world’s most powerful countries put their foot down on tax evasion. It is already known that last November Government signed an Inter Governmental Agreement with the United States (US) to exchange information on their citizens who have thousands… – Continue reading
TWO noteworthy taxation amendments came into effect on the 1st of January 2015. The first tax amendment relates to the deductibility of interest paid to a person who is not liable to tax in South Africa, for example non-residents. The section in question, section 23M of the Income Tax Act,… – Continue reading
Four days out from Christmas, Blind Citizens Australia (BCA), Deaf Australia, Homelessness Australia and Down Syndrome Australia learned they were to be subject to federal government funding cuts. New Social Services Minister Scott Morrison assured concerned parties that frontline services to the disabled would not be cut, just grants to… – Continue reading
The new deoffshorisation legislation that passed with lightning speed through Russia’s Parliament and then hastingly signed by President Putin in the time span of a week and a half, comes into force on January 1, 2015. The new deoffshorisation legislation that passed with lightning speed through Russia’s Parliament and then… – Continue reading
CMS Bureau Francis Lefebvre, a leading French law firm, has noted that the 2015 Finance Act and the Rectificative Finance Act for 2014 were adopted by the French Parliament on December 18. Certain provisions have been reviewed by the Constitutional Court, which issued its ruling on December 29. Both laws… – Continue reading
Summary New FATCA requirements that apply to U.S. and non-U.S. insurance brokers and insurance companies will take effect on January 1, 2015. Those requirements impose new information gathering and reporting rules when U.S. insurance and reinsurance premiums are sent outside the U.S. Background The Foreign Account Tax Compliance Act (FATCA)1… – Continue reading
A withholding tax is a tax that is kept back from an employee’s salary and subsequently paid directly to the government. Withholding taxes are commonly employed by countries throughout the world to help combat tax evasion. Countries in Asia typically divide withholding tax into dividends, interest and royalties payments, with… – Continue reading
CAPE TOWN — South Africa needs to finalise the renegotiation of its tax treaty with Mauritius as soon as possible to prevent the loss of large sums of money through “treaty shopping” the Davis tax committee has urged. The committee released its interim report on ways to prevent base erosion… – Continue reading
Japan has remained a cornerstone of Pakistan’s economy for the past many years. Japanese Companies have invested in all sectors across Pakistan. Be it auto, trading, manufacturing, infrastructure development, packaging, steel manufacturing, indenting, etc a large number of Japanese Companies have a strong presence in Pakistan. Pakistan’s Investment and Corporate… – Continue reading
Gov. Maggie Hassan has done an excellent job working with legislative leaders to craft and oversee the state’s current two-year budget. An array of problems is being effectively managed. This budget will end in balance. But looking ahead to the next two-year budget, we in state government face difficult challenges…. – Continue reading
Gov. Maggie Hassan has done an excellent job working with legislative leaders to craft and oversee the state’s current two-year budget. An array of problems is being effectively managed. This budget will end in balance. But looking ahead to the next two-year budget, we in state government face difficult challenges…. – Continue reading
NEW YORK – There was a time when Indians would relocate to America for the so-called American Dream. Well all that is about to stop now, since, NRI’s are being cautioned to be aware of their decisions as the nightmare of tax is about to plague their lives. We all… – Continue reading
Advance Agreements The so-called tax rulings and advance pricing agreements will be formalised by the introduction of appropriate provisions in the Luxembourg tax laws. By this means, Luxembourg will be able to offer as from 1 January 2015 a unified system providing taxpayers with legal certainty and a consistent and egalitarian… – Continue reading
Heading into the G20 in Brisbane last month, Treasurer Joe Hockey thundered that multinational companies who avoided paying tax were akin to “thieves” whose actions rendered it harder for governments to tackle poverty. Sadly however the government’s actions have failed to match its rhetoric. This week’s crafty back-down on Section… – Continue reading
December 17: The Dutch Ministry of Finance announced that a new regulation for the avoidance of double taxation between the Netherlands and Curaçao is expected to be effective beginning 1 January 2016. The Dutch government bill concerning this regulation is pending consideration by the Lower House. Once approved, the bill… – Continue reading
If we make America the world’s most favored tax haven, money will flow to the USA. Talk of overhauling the tax code is stirring in Washington, but the overwhelming complexity of the task makes it difficult to accomplish, at least in the near term. Here’s a good, clean, quick way… – Continue reading
MUMBAI: The capital market regulator has plugged the loophole that allowed savvy mutual fund investors to lower tax by bonus stripping. The Securities and Exchange Board of India (Sebi) has spelt out that it’s not in favour of fund houses launching new schemes with bonus option in their arbitrage funds…. – Continue reading
Something strange happened in 2014 — Americans became very interested in corporate tax policy. It started in the spring, when U.S.-based pharmaceutical giant Pfizer, which produces blockbuster drugs like Lipitor and Viagra, floated a possible merger with its British-based rival AstraZeneca. Normally a merger of that size would make a… – Continue reading
In prior advisories, we have discussed the new withholding tax law commonly known as “FATCA” (standing for “Foreign Account Tax Compliance Act”). (See “FATCA’s July 1 Effective Date Has Arrived; Last-Minute Guidance Has Been Issued” and “Last Substantial Package of FATCA Regulations Released; Deadlines Approaching”.) To help implement FATCA, the… – Continue reading
When the Chesapeake Bay Foundation, the Johns Hopkins University and other Maryland nonprofits want to maximize the money they can spend in pursuit of their missions, they do what many wealthy individuals and businesses do. They open investment accounts overseas. Many of Maryland’s wealthiest nonprofits — including the University of… – Continue reading
All those Dutch sandwiches, double Irishes and Luxembourg, uh, lunchboxes that US multinational companies use to defer taxes and shift profits abroad are expected to be re-empowered today when the Senate votes to enact a one-year tax extension package. Included in the package is a renewal of two breaks, one… – Continue reading
Florida Center for Investigative Reporting The Walt Disney Co. generates $18.2 billion per year in economic activity in Florida and and is responsible for more than one in every 50 jobs in the Sunshine State, according to a study the company paid for in 2011. But here’s something Disney won’t… – Continue reading
Exports of Ukrainian goods through offshore companies fell by 90 percent in the first nine months of this year, according to the State Fiscal Service, dropping to $334 million. British Virgin Islands, a jurisdiction known for the lack of transparency, remains the most popular offshore destination with Ukrainian companies, attracting… – Continue reading
Summary Corporate tax reform is getting closer, repatriation of foreign profits is a possible outcome. Reform may end the practice of deferment, meaning overseas cash hordes will no longer be part of common corporate practice. Many large U.S. companies will have decisions on how to use funds that are no… – Continue reading
This publication provides a brief overview of the expected impact on entities established in Bermuda of (a) the foreign account tax compliance provisions (“FATCA”) of the Hiring Incentives to Restore Employment Act, 2010 of the United States of America (the “US”); and (b) equivalent rules implemented in relation to United… – Continue reading
In recent times there has been a welcome return to activity in the Irish real estate market. Overseas investors have been circling and private equity groups have started investing heavily in Irish real estate amid confidence that the Irish economy has stabilised and is returning to growth. In this briefing… – Continue reading
Fund wanted to buy distressed debt in media and communications companies Ireland played a key role in international tax and funding structures set up by a $100 million Cayman Islands fund that wanted to buy distressed debt in media and communications companies in 2010. Accountancy firm Ernst & Young (now… – Continue reading
