Category: Corporates

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

HONDURAS MAKES CARLOS SLIM PAY ITS TAX

The multinational companies in Latin America demand security, efficient services, infrastructure and good educational standards, but they are not very willing to contribute themselves by paying their fair share of tax. Honduras is a case in point, and is one of the most unequal countries on the continent. The government,… – Continue reading

Proposal to make arbitration mandatory under MAP dropped

India opposed the proposal saying it impinges on the sovereign rights of developing countries in taxation New Delhi: An international proposal to make arbitration mandatory and binding under mutual agreement procedures (MAP) in tax treaties has been dropped after India strongly opposed it. Last year, the Organisation for Economic Co-operation… – 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

Confusion over Modi’s I-Day speech: DTAA info behind Rs 6,500 cr disclosure on black money

Many have, mistakenly, confused the prime minister (PM)’s recent remark that Rs 6,500 crore had been disclosed by holders of hitherto unaccounted money with disclosures under the compliance window in the recent law on the subject. However, this money has nothing to do with the latter’s three-month window. These came… – 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

Bank pays €22 mn for Luxembourg tax evasion activities

(CS) German financial institution HSH Nordbank reportedly reached a 22-million-euro settlement with prosecutors in Cologne over setting up offshore companies through Luxembourg to hide client assets from tax authorities. Newspaper “Süddeutsche Zeitung” and broadcasters NDR and WDR first reported on the deal on Tuesday. Allegedly, HSH Nordbank approached the prosecutor’s… – Continue reading

SA taxpayers have nowhere to hide

South Africans with undisclosed offshore accounts may feel exposed after their offshore Swiss bank account information found its way into the public domain this year. The theft of information relating to some 30 000 HSBC accounts – the biggest banking leak in history – actually took place five years ago… – Continue reading

The critical importance of the Cayman Islands to the U.S. economy

In May of 2012, and soon before Facebook’s IPO, Eduardo Saverin renounced his U.S. citizenship. Saverin was a co-founder of the social-networking site, and the consensus was that he gave up his citizenship to avoid U.S. taxes that would be levied after the offering. Saverin was widely denounced for his… – Continue reading

Singapore bankers rattled by Asian moves to chase hidden wealth

Singapore-based wealth managers, already under pressure from a global move towards tax information sharing, face a more immediate threat as Asian countries including Indonesia and India look to chase undeclared money in the low-tax city state. A global crackdown on tax evasion launched during the 2008 financial crisis has already… – Continue reading

Aircraft overhaul expenses continue to be “fees for technical services” but not taxable absent source in India

In DIT vs. M/s. Lufthansa Cargo India: TS- 299-HC-2015, the Delhi High Court held that payment made by assessee (an Indian company) to German company for carrying out overhaul repairs to aircrafts was fees for technical services (“FTS”) under section 9(1)(vii) of the Income Tax Act, 1961 (“the IT Act”)… – Continue reading

Private equity braced for global tax changes

The private equity industry has long been known for its ability to take advantage of tax rules. But international changes are set to have an impact on their businesses. After a string of multinationals such as Apple, Google and Starbucks came under fire for paying minimal tax on their British… – 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

US Tax Law Worries for Chinese Families and Companies

The U.S. and China enjoy increasingly strong connections. Yet virtually no Chinese family or business relishes dealing with the Internal Revenue Service (IRS). American tax laws are famously complex, and dealing with the IRS can be like quicksand. Of course, whether they like it or not, U.S. citizens and green… – Continue reading

The tax planner’s tightrope: morality and politics now in play

Introduction In 1934 distinguished US jurist Judge Learned Hand famously opined that “one may so arrange his affairs so that his taxes shall be as low as possible; he is not bound to choose that pattern which will best pay the Treasury; there is not even a patriotic duty to… – 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

Latest Inversion Attempt Illustrates U.S. Can’t Compete with a 0 % Corporate Tax Rate

Yet another American company has announced its intention to carry out a corporate inversion, a fancy term for buying a smaller company, completing some paper work and, for tax purposes, declaring its new headquarters are in a foreign nation. This time it’s Terex, a Connecticut-based heavy equipment and crane manufacturer,… – Continue reading

Companies hold cash offshore until tax reform; Jeff Flake the unorthodox Republican; and Oregon presses for fire funds

U.S. COMPANIES HOLDING CASH ABROAD WAITING FOR TAX REFORM. The high U.S. tax rate continues to encourage companies to stash cash and profits offshore while executives wait for tax reform. The Street has an interview with computing giant Cisco’s CFO Kelly Kramer on the company’s plans for more the more… – Continue reading

Tax authorities urged to be more vigilant over the super-rich

Revenue authorities need to be “vigilant” in monitoring the super-rich, according to research that called on many of them to improve their scrutiny of their richest taxpayers, reports the Financial Times. The study by the Paris-based OECD is a further sign of the pressure on tax departments to squeeze more… – 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

Growing trend: Islamic finance goes offshore

The rise of Islamic finance and sukuk issuances have brought with it a growing phenomenon: Shariah banking is increasingly taking advantage of offshore banking jurisdictions, and this for a number of reasons, reports the Gulf Times. Many offshore centres around the world meanwhile offer a wide range of features allowing… – 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

Tax return preparers sentenced for hiding offshore account

WASHINGTON, D.C. (WDAM) –This is a news release from the U.S. Department of Justice. Two tax return preparers with offices located in California, Maryland and New York were sentenced today in Los Angeles for facilitating an offshore tax fraud scheme, announced Acting Assistant Attorney General Caroline D. Ciraolo of the… – Continue reading

China policy lenders to issue 15 bln yuan in bonds offshore

[BEIJING] China’s top economic planning agency approved two policy lenders – China Development Bank Corp (CDB) and Agricultural Development Bank of China – to issue renminbi-denominated bonds offshore, the National Development and Reform Commission (NDRC) said on Tuesday. CDB, the country’s biggest policy lender and responsible for funding large infrastructure… – Continue reading

Civil society groups in Kenya push for laws to criminalise tax evasion

NAIROBI: The civil society in Kenya wants Parliament to join them in the push to end tax evasion through enactment of laws that enhance compliance from international trade. This, they argue, will boost revenue collection by the State. They say tougher laws will criminalise tax avoidance and spell harsher penalties… – Continue reading

Revenues surge as global crackdown on tax evasion gathers pace

Hundreds of millions of tax dollars are flooding into exchequers across the world, as governments offer evaders a last chance to own up to undeclared accounts, reports the Financial Times. Taxpayers with funds stashed offshore are coming forward voluntarily in their tens of thousands ahead of new transparency rules that… – Continue reading

Businesses seek cross-border tax clarity, but would they really pay more?

Would businesses really be willing to pay more tax if they had more certainty on what is acceptable for cross-border tax planning? According to a recent Grant Thornton International Business Report, three quarters of business leaders would in fact be ready to pony up more taxes in exchange for greater… – Continue reading

Tax rate on intellectual property profits would be cut to approximately 10% and appreciated intellectual property could be repatriated free of current tax under bipartisan innovation box proposal

On July 29, 2015, Charles Boustany (R-LA) and Richard Neal (D-MA) released a bipartisan discussion draft of proposed Internal Revenue Code (the “Code”) amendments that would cut the United States income tax rate on corporate profits generated from patents and certain other intellectual property to approximately 10% (the “Tax Rate… – Continue reading

…but Larger Jurisdictions are Determined to Destroy Offshore Sector in Smaller Countries

While CIBC FirstCaribbean and Heritage Bank are working to formalize the sale of assets, another offshore institution operating from Belize is yet to secure a correspondent bank. As we’ve reported previously, Bank of America has severed ties with Atlantic International Bank Limited as part of an ongoing de-risking exercise. The… – Continue reading