(Reuters) – International banking activity expanded for a second straight quarter between April and June with banks lending more to emerging markets, particularly China, and to investment funds in offshore centers such as the Cayman Islands, data showed on Monday. Foreign lending to offshore centers rose to $2.269 trillion in… – Continue reading
Some 19 British firms are at the center of an investigation into in a mammoth global money-laundering operation. The scheme was allegedly contrived to make $20bn (£12.5bn) worth of ill-gotten gains appear legitimate. The illicit funds are thought to have originated from criminal gangs and corrupt officials across the globe,… – Continue reading
Our Reaction The Irish Minister for Finance delivered his Budget 2015 (the “Budget”) speech this week. There was considerable domestic and international anticipation in advance of the Budget against a backdrop of significant recovery in the Irish economy and also international focus (including, in particular, under the OECD BEPS project)… – Continue reading
Tseng Ming-chung at a press event in Taipei, Oct. 7. (Photo/Yen Chien-lung) Taiwan’s Financial Supervisory Committee (FSC) plans to conduct stress tests to assess the credit risks of China’s banks every quarter, reports our Chinese-language sister paper China Times. FSC chairman Tseng Ming-chung said the quarterly report will be published… – Continue reading
Bank of China Ltd. (3988) raised $6.5 billion selling offshore preference shares in the biggest-ever single tranche U.S. dollar bank capital sale. The country’s fourth-biggest lender by market value priced the securities at 6.75 percent, according to a person familiar with the matter. Citigroup Inc. raised $6 billion selling 8.4… – Continue reading
The private equity owners of video games retailer Game used tax havens in the two years they owned it, accounts have revealed. US buyout group Elliott Advisors snapped up Game Group after it collapsed into administration in 2012. It set up Game Digital in April 2012 in a deal masterminded… – Continue reading
AbbVie Inc. (ABBV) may scrap its planned 32.4-billion-pound ($51.5 billion) deal for Dublin-based drugmaker Shire Plc (SHP), in what would be the biggest casualty of the U.S. crackdown on so-called tax inversions. Shire stock plunged the most in 12 years after North Chicago, Illinois-based AbbVie said its board will meet… – Continue reading
On July 21, 2014, the governments of Canada and the United Kingdom signed the fourth protocol (Protocol) amending the Convention between the Government of Canada and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion… – Continue reading
INTRODUCTION In a recent publication1, the LMA have announced a change of approach to the allocation of FATCA withholding risk in certain of their precedent facility agreements. Previously, the LMA had not adopted a definitive stance in this area, recognising that borrowers and lenders may wish to allocate the risk… – Continue reading
(Reuters) – Italian Prime Minister Matteo Renzi on Monday promised sweeping tax and spending cuts to help boost growth and jobs next year, as the European Commission considers whether to reject his budget plan for reducing debt too slowly. Speaking to a conference of business leaders, Renzi said he would… – Continue reading
Inter vivos and testamentary trusts are used frequently in Canada to implement a variety of estate and tax planning strategies. Over the past few years, however, amendments to Canada’s Income Tax Act (the ITA), and case law have altered the effectiveness of the use of trusts in certain circumstances. In… – Continue reading
Non-dom investors have been hit by a 45% tax if they secure loans against offshore assets to buy a property in Britain. The stealth tax has slowed down the sale of luxury homes in London’s booming property market, according to estate agents. The rule affects investors who are not children… – Continue reading
Transactions within, rather than between, companies now accounts for about a quarter of Australia’s economic output, the Tax Office says. In a sign of the challenges facing the government’s crackdown on corporate tax erosion, the ATO said related-party dealings now amounted to more than a quarter of a billion dollars… – Continue reading
Vodafone has emerged victorious against the Indian taxman in the latest bout of litigation between the two. The important point for the rest of us being what it tells us about those endless claims of tax avoidance and tax evasion by large companies. It’s not just that large amounts of… – Continue reading
Australian tax authorities allege multinational oil giant Chevron used a series of loans and related party payments worth billions of dollars to slash its tax bill by up to $258 million. New documents filed in a long-running dispute in the Federal Court show how Chevron allegedly engaged in a complex… – Continue reading
Oct. 7 — The IRS is working to finalize rules aimed at curbing the ability of foreign investors to skirt the withholding tax on dividends under tax code Section 871(m) by the end of 2014, an Internal Revenue Service official said. The IRS has “a team of people” dedicated to… – Continue reading
Medtronic announced last week that it will go ahead with its Covidien buyout despite a recent notification by the U.S. Department of the Treasury and the Internal Revenue Service discouraging tax-avoiding corporate inversion deals. Per the new guidelines, companies will not be able to avoid paying U.S. taxes when accessing… – Continue reading
Major changes have occurred with respect to foreign tax credit (FTC). The Department of Finance announced in the federal budget of March 4, 2010, a proposed legislation regarding FTC generators (FTCG) and released modified draft legislation on August 27, 2010. These new FTCG rules target the FTC per subsections 126(4.11)-(4.13)… – Continue reading
The Italian tax authorities have been intensifying their focus on transfer prices involving financial intercompany transactions such as loans. Multinational corporations frequently resort to such transactions to optimise and rationalise the financial management of the entire group. In certain cases, the said optimisation tools pertaining to intercompany financial resources may… – Continue reading
Plans to tackle UK tax avoidance by international technology companies could damage UK competitiveness if they are brought in before international measures are finalised, a tax law expert has warned.02 Oct 2014 Corporate tax Tax Tax Disputes and Investigations TMT Advanced Manufacturing & Technology Services UK Europe Heather Self of… – Continue reading
When the Obama administration clamped down last month on companies that reincorporate abroad to escape high U.S. taxes, it did not address a tax-dodging technique known as “earnings stripping,” leaving some to wonder if it is the next target. Earnings stripping is widely practiced and covers a range of financial dealings that… – Continue reading
Almost a third of Australia’s largest companies are paying less than 10¢ in the dollar in corporate tax, a report that exposes a gaping hole in government revenues over the past decade shows. As Australia prepares to host world leaders at the G20 summit in Brisbane in November, where a… – Continue reading
While it’s said that death and taxes are inevitable, enough money and clever maneuvering can apparently help sidestep the latter. Witness the so-called dividend arbitrage, which is raising concerns from regulators thanks to its ability to allow big banks to create $1 billion per year in revenue, according to The… – Continue reading
(Bloomberg) — AbbVie Inc. is examining plans to raise additional financing to complete its takeover of Shire Plc, after U.S. officials imposed new obstacles to so-called tax inversion deals, people with knowledge of the matter said. AbbVie may seek to borrow as much as $7 billion more than it originally… – Continue reading
Canada should not count on building its economy by luring U.S. multinationals over the border with low tax rates in light of an announcement from the U.S. Treasury Department this week. The department outlined new measures to block companies from escaping U.S. taxes by moving earnings outside the country. This… – Continue reading
Back in the eighties and nineties, the Wyly brothers ran, and owned huge stakes in, a weird bunch of public companies, including some craft stores, some software companies, and a reinsurer. These companies were good and made the Wyly brothers a lot of money. An odd biological fact is that… – Continue reading
Corporate financial accounting and taxation are complex subjects. For this reason, many people tune out when issues that involve corporate tax practices rise to the level of public debate. Unfortunately, many legislators shy away from these issues for similar reasons. But while corporate taxation can be mind-bogglingly complex, nontax experts… – Continue reading
Stricter tax inversion rules punish stocks of firms mulling such moves. The Obama administration’s tougher rules on offshore corporate inversions had an immediate effect Tuesday, pushing down the stock prices of companies considering such moves.But the highly technical changes to the tax code di Stricter tax inversion rules punish stocks… – Continue reading
The Obama administration’s new rules intended to stem the tide of inversions, in which U.S. companies reincorporate abroad to dodge taxes at home, won’t be completely effective because they don’t address the high corporate tax rate in the U.S. that compels such behavior, say tax experts and analysts. The rules announced… – Continue reading
WASHINGTON/NEW YORK, Sept 23, (Agencies): Tough new US rules on corporate “inversions” on Tuesday sent a chill through the market for the tax-avoidance deals, both pending and potential, with share prices falling sharply in nearly a dozen companies on both sides of the Atlantic. As investors sold stocks involved in inversions,… – Continue reading
Three years ago, Russia adopted new transfer pricing legislation. The new rules became effective on Jan. 1, 2012. They are in line with international standards (OECD Guidelines on Transfer Pricing), but their concept was, and still is, quite new for the Russian tax authorities. Thus the rules provide for a transition period until 2017: For the years 2012… – Continue reading
The beautiful part is the administration did it without Congress. Jared Bernstein, a former chief economist to Vice President Biden, is a senior fellow at the Center on Budget and Policy Priorities and author of “Crunch: Why Do I Feel So Squeezed?” among other books. Well, would you look at… – Continue reading
(Reuters) – Moving against tax avoidance by corporations, the Obama administration took several actions on Monday to curb “inversion” deals that allow companies to escape high U.S. taxes by reincorporating abroad. The Treasury Department announced new rules, effective immediately, that will reduce the tax benefits available to companies that have… – Continue reading
Lenders spent nine months poring over the books, sizing up management and even checking out the factory floor at China’s Ultrasonic before deciding in August to give the Frankfurt-listed shoemaker an unsecured credit facility of US$60m. The loan was unsecured, in keeping with regulations in China at the time it… – Continue reading
POLITICIANS in the rich world like to splutter about the ever more elaborate dodges that big multinational firms undertake to minimise their tax bills. But doing something about them is trickier. America’s Congress is struggling to agree on ways to stop companies “inverting”—switching domicile to reduce tax bills (see article)…. – Continue reading
Take That pop star and former X Factor judge Gary Barlow has apologised to his fans for his involvement in an illegal tax avoidance scheme. Barlow has posted an open message on Twitter saying he is sorry for any offence he may have caused and stating he has appointed new… – Continue reading
Cyprus transposed the EU Parent-Subsidiary Directive1 into domestic legislation when it updated its tax laws in preparation for EU membership in 2004. The Income Tax Law and the Special Contribution for the Defence of the Republic Law provide a liberal system of double taxation avoidance, which also extends to non-EU countries,… – Continue reading
A CONSERVATIVE MP invested in an alleged tax avoidance scheme currently under investigation by HM Revenue & Customs. Conservative Geoffrey Cox QC – a top lawyer at Thomas More Chambers – is one of 230 who put cash into Pheonix Film Partners, run by Ingenious Media, the Mirror reports. Pheonix… – Continue reading
Withholding on US source income under FATCA started on 1 July 2014. The withholding will apply to gross “proceeds of sale” of securities bearing US source income (which includes repayment of principal on a loan to a US borrower) and, potentially, to “foreign passthru payments” from January 2017. Now that… – Continue reading
NEW DELHI, SEPTEMBER 11: Indian companies looking to raise money abroad through offshore bond issuances to overseas investors are in a bind, thanks to the new company law requirement around private placement of securities. They are now looking up to the Corporate Affairs Ministry (MCA) to provide clarity on whether… – Continue reading
Sen. Charles Schumer (D-N.Y.) released legislation Wednesday seeking to roll back the tax benefits for companies that reincorporate abroad. Schumer’s bill takes aim at a maneuver known as earnings stripping, a process by which U.S. subsidiaries can take tax deductions on interest stemming from loans from a foreign parent. The… – Continue reading
PRESSURE is mounting both within and outside Parliament for the government to introduce dedicated legislation to ban transfer pricing when it is used as a tax-avoidance measure to shift profit offshore. South Africa is estimated to lose tens of billions of rand annually from the abuse of transfer pricing by… – Continue reading
Multinational corporations that use complicated schemes to avoid paying tax in Australia are set to be targeted, with Treasurer Joe Hockey demanding the Commissioner of Taxation “double his efforts”. Mr Hockey has also warned Australians with offshore investments to once again disclose their unreported foreign income to tax authorities before… – Continue reading
Bank of China Ltd., the nation’s fourth-biggest by market value, hired four banks to help arrange its first offshore sale of subordinated securities that will count as capital under the country’s new banking rules. The four include Bank of China’s own investment-banking arm, the people familiar with the matter said, asking… – Continue reading
Tax authorities throughout the world are cracking down on taxpayers – individuals and corporations – that utilize some aggressive tax planning strategies. While most of these schemes are perfectly legal and merely take advantage of loopholes in theinternational tax system, there is a growing concern that they not only threaten… – Continue reading
A new section 1305A of the UK Corporation Tax Act 2009 (CTA 2009) has been introduced by the UK Finance Act 2014 that applies to payments made from March 19, 2014 under avoidance schemes involving the transfer of corporate profits within a group. This new measure applies if: two companies… – Continue reading
A former manager of a credit union was sentenced on Tuesday for bank fraud and tax evasion, announced U.S. Attorney Danny C. Williams, Sr. for the Northern District of Oklahoma and R. Damon Rowe, IRS-Criminal Investigation, Special Agent in Charge, Dallas Field Office. Eva Barroso, 54, Broken Arrow, was sentenced… – Continue reading
Changes to the way that HM Revenue and Customs (HMRC) taxes loans secured by non-domiciled persons (“non doms”) using foreign income and gains will lead to disputes over the true interpretation of the law, the Chartered Institute of Taxation (CIOT) has warned. HMRC has announced that it is to withdraw… – Continue reading
AROUND 16,000 TAX AVOIDERS are to be given the chance to settle their outstanding liabilities with HM Revenue & Customs, the department has confirmed. On average, each of the users of the contractor loan schemes covered by this settlement opportunity owes £11,000 a year in tax. The schemes involve complex… – Continue reading
Canada and the UK on July 21, 2014, signed a protocol to their Double Tax Agreement that amends its withholding tax and information exchange provisions. The Protocol includes an exemption from withholding tax for payments of interest made in respect of loans between persons at arm’s length. The headline withholding… – Continue reading
