Category: Real Estate

FATCA and Trustees: Part I

Do trustees need to register with the US Internal Revenue Service (the “IRS”) before 1 January 2015?  Does registration need to be made in respect of a trust? These questions need to be given due consideration by Cayman Islands and British Virgin Islands (“BVI”) trustees and the trusts in respect… – Continue reading

1 FATCA and trustees: part I

Maples and Calder Michael Gagie, Richard Grasby, Tim Clipstone, Christopher Capewell, Jon Fowler and Tim Frawley Do trustees need to register with the US Internal Revenue Service (the “IRS”) before 1 January 2015?  Does registration need to be made in respect of a trust? These questions need to be given… – Continue reading

Indian firms to tap more offshore funds to refinance debt, says Fitch

Indian corporates are likely to increasingly access the offshore debt capital markets for their funding requirements once the investment cycle restarts, according to Fitch Ratings. “The growth is likely to be driven by the need to refinance debt and fund capex once the investment cycle restarts and as many corporates… – Continue reading

Impact of FATCA on Bermuda Entities

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

Ireland: Property Investment Structures In Ireland: Irish Investment Opportunities

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

Israeli Swiss Bank Tax Evasion Investigation Widens

A senior figure is suspected of secretly keeping accounts in a Swiss bank that were not reported to the tax authorities in Israel, in an affair called the “Swiss Bank Affair,” sources inform “Globes.” Israel Tax Authority investigators conducted a search of the senior figure’s home. As in the information… – Continue reading

UK: Moving to the UK from France

Some statistics rank London as the fourth largest ‘French’ city by population, and the number of French individuals moving to the UK is growing. This is not surprising – the UK offers a highly favourable tax regime for ‘non-domiciled’ individuals moving to the UK, while entrepreneurs, professionals and high net… – Continue reading

American citizens like Boris must pay more tax, says US ambassador to UK (but Google and Amazon are doing nothing wrong)

Ambassador to London Matthew Barzun says US citizens must pay up Boris Johnson was born in New York so faces a tax bill in America London Mayor has branded the Transatlantic rules ‘outrageous’ Barzun defends US firms like Amazon and Google over tax dodging Insists they are just playing by… – Continue reading

A palace fit for the king of tennis: Roger Federer to move into £6.5million GLASS mansion in Swiss tax haven on banks of Lake Zurich – complete with separate apartment for his parents

Tennis legend Roger Federer is set to move into a 6.5million glass mansion in a Swiss tax-haven Wollerau Three-storey building comes with floor-to-ceiling windows, a swimming pool and view across Lake Zurich Wollerau is one of the lowest tax municipalities in Europe and has attracted other multi-millionaires Tennis ace Roger… – Continue reading

Property Council Pushes for Tax Reform

The Property Council of Australia has joined efforts by the broader business community to lobby the federal government to implement significant tax reforms next year. Members of the Business Coalition for Tax Reform (BCTR) will meet with the Australian Council of Social Service (ACOSS) on December 15 to commence discussions… – Continue reading

Guernsey’s economy shows signs of recovery despite protests

High quality global journalism requires investment. Please share this article with others using the link below, do not cut & paste the article. See our Ts&Cs and Copyright Policy for more detail. Email ftsales.support@ft.com to buy additional rights. http://www.ft.com/cms/s/0/e3cae272-73d4-11e4-82a6-00144feabdc0.html#ixzz3LIqHN5hj A seafront car park in St Peter Port overlooked by Guernsey’s… – Continue reading

UK: Switzerland UK Autumn Statement 2014 Analysis

In yesterday’s Autumn Statement, the UK Chancellor announced several measures that will directly affect non-UK individuals who live or own property in or are considering moving to the UK. Although in many cases the measures will mean that such individuals are liable to pay more tax in the UK than… – Continue reading

AREF welcomes UK’s proposed stamp duty land tax relief

John Cartwright (pictured), Chief Executive of the Association of Real Estate Funds (AREF), comments on the UK government’s objective to introduce stamp duty land tax relief in 2016… We welcome the government’s intention to introduce a stamp duty land tax (SDLT) relief for seeding investment – a much needed removal… – Continue reading

Swiss Bank Referendum Fails, Franc Drops

The Swiss voted down the initiative “Save Our Swiss Gold” on Sunday, November 30, by a margin of three to one, rejecting efforts to shore up the Swiss National Bank’s (SNB) balance sheet. Switzerland, a direct democracy, entertains an average of five such referendums every year, and most of them… – Continue reading

UK: Capital Gains Tax On Non-UK Residents

Late yesterday afternoon the Government published its response to the consultation on extending Capital Gains Tax (CGT) to non-UK resident owners of UK residential property.  This is the latest step in a series of significant changes in the last couple of years to the tax treatment of UK residential property…. – Continue reading

UK: Deloitte Preview of Autumn Statement 2014

Bill Dodwell comments: “Chancellor George Osborne will deliver the final Autumn Statement of this parliament. We expect that most of the announcements will concentrate on the outcomes from proposals launched at earlier Budgets, together with some technical changes. There will also be the first consultation on how the UK should… – Continue reading

UK government finalises new capital gains tax charge for non-resident homeowners

Non-resident UK homeowners that have spent less than 90 days in their UK property in the previous tax year will be liable to pay capital gains tax (CGT) on any gains when they sell that property from next year, the UK government has confirmed.02 Dec 2014 Private wealth tax Tax… – Continue reading

London Mayor Boris Johnson makes ‘brave’ stand against American taxes

The refusal by the Mayor of London to pay his American taxes has been hailed as “noble” and “brave” by the CEO of independent financial advisor, deVere Group. The comments from Nigel Green, founder and chief executive of deVere Group, which operates in 100 countries and has $10 billion under… – Continue reading

France – Tax proposals in pending legislation

Passage by the French assembly on 18 November 2014 of a draft Finance Bill for 2015 (which now will be presented to the Senate) Introduction by the French government on 12 November 2014 of a second draft amended Finance Bill for 2014 In general, the draft Finance Bill for 2015… – Continue reading

Sol Campbell clashes with Labour MP over mansion tax on his £25million house in Chelsea and Northumberland ‘country pile’

Sol Campbell owns £25m house in London and Northumberland mansion He appeared on BBC2’s Daily Politics to explain mansion tax was unfair Ex-England footballer said proposed levy was a ‘tax on aspiration’ He said Labour should instead pursue companies who had avoided tax But MP Owen Smith said people had… – Continue reading

Australia mulls tighter foreign property investment rules

An Australian parliamentary committee on Thursday (Nov 27) recommended strengthening rules on foreign investment in the country’s booming housing market, calling enforcement of the current framework “severely lacking”. SYDNEY: An Australian parliamentary committee on Thursday (Nov 27) recommended strengthening rules on foreign investment in the country’s booming housing market, calling… – Continue reading

Canada: Partnership Interests And Form T1135: Which Party Should File?

Canadian taxpayers with an interest in a partnership that holds specified foreign property (as defined in subsection 233.3(1)) may face uncertainty when assessing their form T1135 (“Foreign Income Verification Statement”) filing obligations. Depending on the partnership’s structure, either (1) the taxpayer may be required to file form T1135 in respect… – Continue reading

Credit Suisse $2.6 Billion Deal Gives Judge Few Options

Credit Suisse AG (CSGN)’s $2.6 billion plea bargain resolving allegations it helped wealthy Americans avoid paying taxes faces a final hurdle from a federal judge who will decide whether to accept it or throw it out. The first global banking unit in more than a decade to plead guilty to… – Continue reading

Fruitless pursuit of black money

People curious to know the amount of “black money” stashed by Indians in foreign banks may be in for yet another disappointment after the Supreme Court monitored Special Investigation Team (SIT), submits its findings. After six months in office, the Narendra Modi Government has not been able to lay its… – Continue reading

The costs of offshore tax avoidance, part 2

In our previous post, we looked at the ways that global corporations minimise their tax burdens by routing income through offshore tax havens and transfer pricing. The ultimate beneficiaries of these shenanigans, of course, are actual people rather than legal entities. Many of these people also take advantage of offshore… – Continue reading

Final regulations – Failure to satisfy gain recognition agreements (GRAs) reporting requirements

November 18:  The Treasury Department and IRS today released for publication in the Federal Register final and temporary regulations (T.D. 9704) concerning the treatment of U.S. and foreign persons that fail to file gain recognition agreements (GRAs) or that fail to satisfy other reporting requirements associated with transfers of property… – Continue reading

No extra NHR tax exemptions in 2015, say Portuguese officials

Proposals to extend capital gains and investment income tax exemptions under Portugal’s Non-Habitual Residents Tax Regime have not been passed, say government officials It seems that the Portuguese government has shelved plans, at least for 2015, to extend capital gains and investment income taxation exemptions. However, officials say they are… – Continue reading

Sears, Pinnacle Entertainment Look At US REITs

Sears Holdings and Pinnacle Entertainment have become the latest US companies to announce that they are considering establishing real estate investment trusts (REITs), to unlock tax advantages that have been considered by some companies as an alternative to a corporate inversion. REITS do not pay corporate tax as long as… – Continue reading

Mogers Drewett: What the new Capital Gains tax regulation means for you

Being a non-UK resident can offer certain tax advantages however new regulation around capital gains tax proposed to take effect next year, may have implications for non-residents when they dispose of a residential property as Kirstie Carr of Mogers Drewett explains. Capital gains tax (CGT) is a tax which applies… – Continue reading

AIG was avoiding taxes when it was owned by the US government

After the US bailed out the insurance conglomerate AIG in 2008, the company’s employees kept to business as usual—which included setting up complex tax structures to avoid taxes in Europe and Japan. In 2008, the company was on the brink of a bankruptcy that would have created huge losses throughout… – Continue reading

Pension board that set up offshore shell companies is separate from government, Tony Clement affirms

CBC probe finds civil servants’ pensions invested via Luxembourg shell companies to avoid foreign tax Cabinet Minister Tony Clement has moved to distance the federal government from a Crown corporation’s decision to set up a complex arrangement of offshore companies as part of a tax “avoidance scheme” on pension investments… – Continue reading

British Virgin Islands: Impact Of FATCA On BVI Entities

This publication provides a brief overview of the expected impact on entities incorporated in the British Virgin Islands (the “BVI”) 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… – Continue reading

International taxes update – November 2014

High Court refuses special leave application in capital gains tax dispute The High Court has refused the special leave application by the taxpayer in a case involving the liability to capital gains tax (CGT) of a ‘limited partnership’ formed in the Cayman Islands. The application for special leave followed the… – Continue reading

Offshore firms: in the zone

London is an increasingly important hub for offshore law firms, which are winning business from City-based financial institutions, and clients in Russia, western Europe and sub-Saharan Africa. Offshore law firms are constantly evolving, it seems. Traditionally, they operated in one offshore territory: whether the British Crown dependencies of Jersey, Guernsey… – Continue reading

Malone gained double tax break in inversion

New York • Shifting the address of his Liberty Global Inc. from Colorado to London last year didn’t just put billionaire John C. Malone in a position to reduce his company’s tax bill. He also took precautions to avoid the capital-gains hit that the so-called inversion would trigger for him… – Continue reading

Where did all the black money come from and how did it get out of India?

Hawala networks are being replaced by sophisticated transfer pricing approaches. The image is easy to envision. Corrupt politicians, crooked corporate honchos and evil criminals stashing away their ill-gotten gains in shady Swiss banks. Thousands of crores of rupees that should be earning India tax revenue wilfully being hidden from authorities… – Continue reading

New Study Sheds Light on How Law Firms and Companies are Managing and Valuing Intangible Assets for Transfer Pricing Purposes

66% of Law Firms Work With at Least Some of Their Tax Clients to Identify and Document All Relevant Intangible Assets for Transfer Pricing NEW YORK, Oct. 30, 2014 (GLOBE NEWSWIRE) — As scrutiny by tax authorities mounts, the identification and documentation of intangible assets, such as patents, trademarks and… – Continue reading

Centre gives black money full list to SC, names to remain secret

HT Correspondent, Hindustan Times  New Delhi, October 29, 2014 First Published: 09:16 IST(29/10/2014) | Last Updated: 10:26 IST(30/10/2014) The government on Wednesday submitted a list of 627 Indians holding accounts in HSBC Bank, Geneva, to the Supreme Court, which directed its special investigating team (SIT) to examine them and take… – Continue reading

Foreign-invested enterprises receive too many tax incentives: survey

VietNamNet Bridge – Recent surveys about the tax policies applied to foreign-invested enterprises (FIEs) show that Vietnamese have become choosier about foreign direct investment (FDI) and FIEs (foreign-invested enterprises). “Do you think that the FIEs in Vietnam are transparent in tax payments?” was one survey question raised by Thoi Bao… – Continue reading

Increasing focus on transfer pricing, says Deloitte

KUCHING: Accounting firm Deloitte Malaysia stressed on the government increasing focus on transfer pricing whereby there is a new requirement for taxpayers to declare if one has prepared all the necessary transfer pricing documentations. In the past, one was only required to disclose related-party transactions but there was no requirement… – Continue reading