Category: K-P

AFTER 5-YEAR-LONG TAX AUDIT, COCA-COLA OWES THE IRS AN EXTRA $3.3 BLN

On Friday, Coca-Cola Co. said that it may owe the IRS an extra $3.3 billion in federal income taxes. According to the company, the Internal Revenue Service found after a five-year-long audit that the soft drink giant may owe the federal government $3.3 billion along with interest for the 2007… – Continue reading

Jean-Claude Juncker denies link to Luxembourg tax deals

European Commission president Jean-Claude Juncker has denied involvement in sweetheart deals that allowed hundreds of multinationals to slash their tax bills by locating to Luxembourg, despite being prime minister of the country for almost 20 years, reports the Financial Times. Facing questions from a committee of EU lawmakers set up… – Continue reading

American Dream Relocates to Bermuda, Says Fishman, Blaming Taxes

Jay Fishman, who built New York-based Travelers Cos. into one of the world’s biggest insurers, lamented that disparities in tax rates are pushing established rivals and industry newcomers outside the U.S. Over the past 15 years or so, “we’ve counted 10, 12, maybe even 15 Bermuda-based startups that ultimately became… – Continue reading

Chevron tax filings challenged by US tax authorities, report says

Chevron’s tax filings face repeated challenges from the United States and other global tax authorities, according to a new union-backed report that calls on world governments to crack down on the energy giant’s alleged profit-shifting tactics. The world’s largest trade union body, the International Trade Union Confederation (ITUC), has called… – Continue reading

Nigeria’s Richest Woman Says Onshore Oil Taxation Too High

Nigeria’s 85 percent tax on onshore crude oil production is dissuading local investors from taking over assets from international oil companies, said Folorunso Alakija, an energy tycoon and the nation’s richest woman. Famfa Oil Ltd., founded in 1991 by Alakija, 64, has sought to acquire stakes in onshore oil fields,… – Continue reading

Facebook lobbyists face ban ban from European Parliament

EU committee set up to investigate aggressive tax planning concludes its report in weeks Lobbyists representing internet company Facebook could be banned from entering the European Parliament following a request by the parliament’s special committee on tax to revoke access to multinationals who refused to cooperate with the committee’s inquiries…. – Continue reading

Tax avoidance crackdown: 1000 multinationals face tax squeeze under new rules

‘I’m not going to buy into that’ Joe Hockey refuses to feed speculation that he could be replaced as Treasurer by Scott Morrison under the new Prime Minister Malcolm Turnbull. Malcolm Turnbull’s first full day as PM: Live coverage Joe Hockey signals he’s ready to serve on Malcolm Turnbull’s frontbench… – Continue reading

Accountants defend their tax record

As Big Four accountancy firm PwC publishes its annual report Madeline Ratcliffe talks to chairman Ian Powell. PWC, ONE of the world’s largest financial services companies, will today report their full year profits increased by six per cent, to £818m, reflecting a policy of growth and investment over the last… – Continue reading

NNPC’s new oil swap deal not transparent — Group

A civil society group focused on transparency in the oil and gas sector has criticized the interim Offshore Processing Agreement, OPA, between the Nigerian National Petroleum Corporation, NNPC, and three multinational trading companies to boost the supply of refined petroleum products in the country. The Africa Network for Environment and… – Continue reading

Apple China Ordered To Pay $10 Million Fine For Tax Evasion

Apple’s CEO Tim Cook announced on Wednesday, Sept.9, that the famed brand’s revenue significantly increased in China by up to 75 percent in the past year. However, the country’s finance authorities cut the celebration short. China’s Ministry of Finance demanded Apple to pay 452 million yuan, a price equivalent to… – Continue reading

Moscovici resolute on common corporate tax base

EU commissioner urges member states to ensure fair share of tax is paid EU economics commissioner Pierre Moscovici reiterated his commitment to re-launch the Common Consolidated Corporate Tax Base yesterday, urging all EU member states to ensure that companies pay their fair share of tax. Speaking following a meeting of… – Continue reading

PwC makes acquisition for high speed FATCA and CRS reports

PwC has acquired software company Ellis Financial Systems in a bid to more rapidly meet new tax information reporting required under such regimes as the Foreign Account Tax Compliance Act (FATCA). It has been re-named PwC Tax Information Reporting, and will operate from London. The acquisition represents one of many… – Continue reading

Another FC Barcelona Star Could Face Tax Evasion Charges Despite Paying Up

Superstar-laden FC Barcelona might be among the top teams in the Spanish Liga BBVA this season but the team is making news – again – for a more undesirable reason: tax investigations. As Lionel Messi awaits trial on tax evasion charges, another Barcelona star may be joining him. Spanish news… – Continue reading

KPMG offshore ‘sham’ deceived tax authorities, CRA alleges

A wealthy Victoria, B.C., family paid virtually no tax over a span of eight years – and even obtained federal and provincial tax credits – while being involved in an offshore tax “sham” developed by one of the country’s most respected accounting firms, the Canada Revenue Agency alleges. The Canada… – Continue reading

Undisclosed foreign bank accounts: CBDT issues guidelines for compounding of offences

NEW DELHI: The Central Board of Direct Taxes (CBDT) has issued guidelines for compounding of offences under Income Tax Act, 1961/Wealth Tax Act, 1957, in cases of persons holding undisclosed foreign bank accounts/assets. The CBDT on Friday issued directions to all field formations, including principal chief commissioners, chief commissioners and… – Continue reading

Black money law: Beneficiaries in overseas discretionary trusts may face enquiry

MUMBAI: Indian tax authorities will ignore conventions to pierce trust structures used by most people to stash black money abroad. Persons who are named as beneficiaries in overseas discretionary trusts are likely to face enquiry even if they do not receive any money from such trusts. The taxman will look… – Continue reading

Fortune 500 Corporations Are Likely Avoiding $600 Billion in Corporate Tax Using Offshore Tax Havens

As Labor Day weekend approaches, a tanned and rested Congress is poised to return to Washington to hash out corporate tax changes. Much of the debate over corporate tax reform in Washington sensibly focuses on how to encourage Fortune 500 corporations to repatriate and pay U.S. taxes on the $2.1… – Continue reading

Mexico used a ‘strong-arm’ tactic to coax multinational corporations into paying more taxes

Mexico’s government withheld hundreds of millions of dollars in tax refunds owed to Procter & Gamble, Unilever, and Colgate combined as it sought to coax them and other multinationals to pay more income tax locally, according to people close to the talks. After luring foreign companies with corporate tax breaks… – Continue reading

Transfer pricing audits: flipping the tested party

Introduction Transfer pricing methods and tested parties Troubling trend Tools for taxpayers Introduction In some recent transfer pricing audits the Internal Revenue Service (IRS) has ‘flipped the tested party’ after examining transactions between related US and foreign companies. Typically, this practice results in the attribution of a larger portion of… – Continue reading

Transfer pricing: Encouraging developments on APA and MAP

A recent Central Board of Direct Taxes (‘CBDT’) press release of August 6, 2015 announced signing of 2 unilateral APAs, including one with a rollback provision, and this has raised hopes of many MNCs, that hope to witness expeditious and reasonable closures. n July 2012, with a view to providing… – Continue reading

Barclays Pressing Swiss Private Bankers to Double Client Assets

The new head of Barclays Plc’s Swiss unit is pushing private bankers in Geneva and Zurich to double client assets in four years as international competitors exit the world’s largest hub for offshore wealth. James Buchanan-Michaelson, who joined from Coutts International in June, aims to increase Swiss assets, including loans,… – Continue reading

Country-By-Country Reporting: The Transfer Pricing Game-Changer

This month’s feature examines proposals for new tax information reporting requirements for large multinational businesses as part of wider and ongoing changes to the international tax system – proposals which have been described by international tax experts as the most significant development in the field of transfer pricing since TP… – Continue reading

Will Etsy’s Brazen Tax Avoidance Cost the Company Its “B Corporation” Status?

The online craft website Etsy is facing new scrutiny for its recent decision to shift some of its intellectual property into a secretive Irish subsidiary. As Bloomberg reported last week, the company’s Irish subsidiary has been made into an “unlimited liability corporation,” a form that exists primarily to avoid disclosure… – Continue reading

CHINA: MANAGING IP TAX CHALLENGES IN BEPS ENVIRONMENT

Multinational enterprises (MNEs) producing or selling their products in China have had to contend with the commercial, legal, and tax challenges of managing how their intellectual property (IP) is used in relation to their Chinese operations. Regulatory approvals for joint ventures operating in China have often required that IP rights… – Continue reading

Canada Life’s offshore bond market share hits 29% on L&G deal

Canada Life’s acquisition of Legal & General International has resulted in a combined 29% share of the offshore bond market into the UK. Managing director of Canada Life International, Sean Christian, revealed the figure in an interview with international Adviser while discussing the details of the deal and the opportunities… – Continue reading

Use of Estonia in U.S. International Tax Planning

According to recent estimates, Estonia, which is situated halfway between Stockholm and St. Petersburg, currently has more than 350 start-up technology companies – one for every 3,700 citizens – and the government expects this number to reach 1,000 by the year 2020. This makes Estonia the number one start-up technology… – Continue reading

Switzerland: Innovation tax breaks “key to attracting companies”

Industry lobby groups are calling on lawmakers to bolster business innovation as they debate corporate tax reforms aimed at retaining Switzerland’s status as a location for multinationals, reports Swiss Info. Parliament is currently looking at a government recommendation to replace Switzerland’s current, and controversial, cantonal corporate tax system – that… – Continue reading

US: Explanation of competent authority revenue procedure

The IRS on 12 August 2015 released Rev. Proc. 2015-40 with respect to requesting competent authority (CA) assistance, and it is generally effective for CA requests filed on or after 30 October 2015. Rev. Proc. 2015-40 updates and supersedes Rev. Proc. 2006-54. The IRS concurrently released Rev. Proc. 2015-41 as… – Continue reading

Proposals for GST and offshore online purchases

PwC’s views on the Government’s discussion document seeking feedback on proposals for GST and offshore online purchases Following on from the much anticipated Government’s discussion document seeking feedback on proposals for the collection of GST on online purchases of services and intangibles this morning, we are pleased to share our… – Continue reading

Is FATCA chasing a leprechaun and his pot of gold?

FATCA was enacted into law by section 501(a) of the Hiring Incentives to Restore Employments (HIRE) Act 2010 as a revenue offset to help pay for the continuation of unemployment benefits for workers laid off during the 2008-2010 financial crisis. In July 2008, the U.S. Senate Permanent Subcommittee on Investigations… – Continue reading

What we know will be in the Senate inquiry’s interim report on multinational tax avoidance

The Senate inquiry into multinational tax avoidance will table an interim report today detailing some of its findings after holding five public hearings and receiving more than 100 submissions from some of the world’s largest companies including Apple, Microsoft, BHP, Rio Tinto and Google. The final report is due to… – Continue reading

Labor’s senate inquiry wants a ‘name and shame’ register for tax dodgers

New transparency requirements could see tax-dodging companies being listed on a ‘name and shame’ register, a Senate committee has proposed. The Australian Tax Office would also be forced to disclose all tax avoidance settlements which exceed a proposed $100 million threshold, Fairfax has reported. In addition, companies based in Australia… – Continue reading

Etsy Taps Secret Irish Tax Haven and Brags About Transparency at Home

Artisan goods marketplace Etsy Inc., which promised to be a beacon for transparency as a public company, recently implemented a strategy that shrouds its offshore tax-cutting arrangements in secrecy. Because of a change in how its Irish subsidiary is registered, Etsy no longer needs to publicly disclose basic financial information… – Continue reading

Worldwide: Governments Continue To Welcome Wealthy Foreigners

With the UK announcing new tax rules for foreigners living in the country, the government has been careful not to damage the country’s appeal to wealthy foreigners. The “non-dom” tax status “plays an important role in allowing those from abroad to contribute to our economy”, says George Osborne, the UK’s… – Continue reading

Islamic banking ‘a possible option’ for BMIO as reorganization plan is implemented

(Seychelles News Agency) – Onshore banking activities, including the possibility of introducing Sharia-compliant banking are being considered for the Seychelles-registered Bank of Muscat International Offshore (BMIO). The Al Salam Bank of Bahrain, which now owns 50 percent shares in the Seychelles-registered Bank is engaging with the Seychelles authorities on the… – Continue reading

The Rules: Forcing companies to disclose tax strategy risks confidentiality issues

A “legislative requirement” for large businesses to publish their tax strategy could create commercial confidentiality risks IN an age where large corporates continue to engage in tax avoidance or aggressive tax planning, compelling businesses to disclose their tax strategies is, at heart, a good idea. There is a risk, however,… – Continue reading