Celebration, FL One of the basic principles of the 3.8% “net investment income tax” (NIIT) under §14111 is that the tax does not apply to individuals who are classified as “nonresident aliens” for U.S. income tax purposes, as defined in §7701(b).2 What was not clarified in the statute, however, was… – Continue reading
Cash doesn’t flow directly from buyers’ pockets to Microsoft’s headquarters in Redmond, Wash. Instead, the company operates through three regional sales units, centered in Ireland, Singapore and Puerto Rico. These groups control the rights to profit from Microsoft products around the world. By conducting sales from places with small populations… – Continue reading
The Foreign Account Compliance Act (FACTA), while designed to “minimize tax cheats”, is making banking — and life in general — painfully difficult for millions of American expats, according to Mike Michelini, a Hong Kong-based business consultant withglobalfromasia.com. Here is his editorial. Under FACTA, all 8 million or so Americans… – Continue reading
Yahoo has reportedly abandoned its plan to spin off its stake in Alibaba. Yahoo’s proposed spinoff had been driven by tax concerns. In a world without taxes, Yahoo could have simply sold its Alibaba shares and distributed the proceeds to shareholders. Yahoo will now concentrate on other strategic options, including… – Continue reading
LOS ANGELES, Dec. 07, 2015 (GLOBE NEWSWIRE) — If you think the Fixing America’s Surface Transportation Act (FAST), passed by Congress on December 3rd, is only about transportation…think again. According to Dennis Brager, founder of the Brager Tax Law Group, a little noticed provision in this wide sweeping Act may… – Continue reading
MUMBAI: Indian banks and mutual funds have in the past fortnight started warning NRIs who hold an American passport or are working in the US that their accounts could be frozen unless they get a tax-compliant certificate from US authorities, thanks to a treaty signed by New Delhi and Washington…. – Continue reading
Congress tightens the tax abuse of Americans who live and work abroad Doubling down on Americans living and working abroad is a way for the Internal Revenue Service to squeeze the turnip a little harder in pursuit of a little more blood. The Obama administration, which has never met a… – Continue reading
The Common Reporting Standard (CRS) is the standard for automatic exchange of financial account information produced by the Organisation for Economic Cooperation and Development (OECD) which provides for systematic and periodic automatic exchange of information between signatory jurisdictions. At its heart is a requirement for financial institutions, including British Virgin… – Continue reading
The House and Senate held hearings Tuesday on the Organization for Economic Cooperation and Development’s Base Erosion and Profit Shifting action plan, also known as OECD BEPS, for combating tax avoidance by multinational corporations. A number of the lawmakers expressed a skeptical view of the international tax reforms. “The OECD’s… – Continue reading
KUWAIT CITY, Nov 29: “The world of taxation has changed tremendously impacted by FATCA, transfer pricing, Base Erosion and Profit Sharing, and others which require dramatic changes in existing operating models and structures,” remarked Fouad Douglas, PwC Country Senior partner, at a tax seminar organised by the PwC in conjunction… – Continue reading
Last summer, a client received a letter from their bank, a major German bank in which it was asked to indicate “whether you are a US tax or not” and also in the form of an affidavit (“Under penalties of perjury”) in to make English more detailed information about himself… – Continue reading
Turkish Economy Minister Nihat Zeybekci says the country is set to follow in the footsteps of Spain, Portugal and Cyprus and launch its own Golden Visa scheme to grant citizenship to those foreigners who invest from €500,000-€1m in property, reports Property Showrooms. Leading Istanbul agent, Universal21, says the move could… – Continue reading
Proposed measure would allow US to revoke passport if individual has over $50,000 unpaid taxes The 8 million Americans living overseas should “ensure their financial affairs are in order and compliant” before the New Year, or face having their passports revoked, warns a financial advisory organisation. The company – deVere… – Continue reading
The eight million Americans living overseas, including In Hong Kong and the rest of Asia, should “ensure their financial affairs are in order and compliant” before the New Year, or face having their passports revoked, warns the boss of one of the world’s largest independent financial advisory organizations. Nigel Green,… – Continue reading
BearingPoint’s FiTAX catches on while a FATCA critic says that more Americans are renouncing their citizenship because of the controversial tax law. While controversy swirls around the Foreign Account Tax Compliance Act (FATCA), management and technology consultancy BearingPoint reports that between March and August 2015, more than 2,000 financial institutions… – Continue reading
US citizenship, Greencard, can no longer be a way of saving tax for some, as India has agreed to provide information for compliance with the Foreign Account Tax Compliance Act (FATCA), which became law in March 2010. Either US citizens or institutions cannot refrain from paying tax on their investments… – Continue reading
MUMBAI: A US passport doesn’t look like such a priced possession anymore. Some Indians even want to surrender their hard-won green cards. India and the US are set to freely exchange financial information about their citizens, leaving no asset concealed. This could mean US tax officials imposing punitive levies on… – Continue reading
According to the Star Spangled Banner, the United States is the land of the free and the home of the brave. So how come the number of Americans renouncing their citizenship is hitting new heights? More than three thousand people have given up their US nationality so far this year…. – Continue reading
The nine-month old Team Unity administration has been pursuing quiet diplomacy to recalibrate international relationships for the benefit of the people of St. Kitts and Nevis, reports SKN Vibes. So said St. Kitts and Nevis Prime Minister Dr. the Hon. Timothy Harris at last week’s press conference at government headquarters…. – Continue reading
Clare Maurice, Arabella Murphy and Sophie Mazzier, Maurice Turnor Gardner LLP For better or worse, the concept of “fairness” is here to stay in relation to taxation, whether domestic or international. Politicians of all persuasions like to insist that their respective policies will ensure that everyone pays his or her… – Continue reading
An American expatriate says a taxation issue in his homeland is having adverse effects on millions like him who simply want to work, save, and live their lives without being hammered by the government. OneNewsNow reported earlier that the tax burden in the U.S. has become so great that many… – Continue reading
The chief executive of one of the world’s largest independent financial advisory organizations unambiguously condemned the Foreign Account Tax Compliance Act in a recent series of comments. deVere Group CEO Nigel Green likened the act, which went into effect in July 2014, to a “masterclass in fiscal imperialism and the… – Continue reading
Two decades after Ken Dart renounced his U.S. citizenship and took his tax attorney with him to the Caribbean, the billionaire bond investor and local kingpin is reinventing himself as the Cayman Islands’ biggest real estate owner. In a rare glimpse into Dart’s holdings, Mark VanDevelde, chief executive of the… – Continue reading
They say the only two givens in life are death and taxes. And, while you still can’t live forever, an increasingly large number of Americans are skipping out on their fiscal obligations by dumping their citizenship. A whopping 1,426 Americans chose to expatriate in the third quarter of this year,… – Continue reading
ABSTRACT This paper provides analysis of one of the foundational elements of the Foreign Account Tax Compliance Act (FATCA) and various intergovernmental agreements (IGAs): an unambiguous place of U.S. birth and the ability to cure (Cure) this element, thereby rendering the account nonreportable. The IGAs generally allow the individual to… – Continue reading
On August 4 and 5, 2015, the FC heard oral arguments in a lawsuit—commenced on August 11, 2014 by two Canada-US citizens—that challenges the law implementing the Canada- US intergovernmental agreement (IGA) relating to FATCA (Virginia Hillis et al. v. The Attorney General of Canada et al., court file no…. – Continue reading
Secretary general of he Union of Arabs and Sam Fattouh for an international approach to the globalization of law “Vta” American FATCA, any tax compliance with the Law on Foreign Americans accounts, to become international law under labeled GATCA “Gta” (Global Account Tax Compliance Act), any tax compliance law global… – Continue reading
Vancouver real estate is a Mainland Chinese buyers’ market, study says Groundbreaking study shows 70 per cent of detached homes sold in a six-month period on Vancouver’s west side went to Mainland Chinese buyers; many of them housewives or students with little income. The dominant influence of Chinese investors in… – Continue reading
HONG KONG (CNNMoney) A record 1,426 Americans gave up their citizenship in the third quarter, according to new government data. That puts the number of Americans who have renounced their citizenship at a whopping 3,221 so far this year. In 2014, a record 3,415 Americans gave up their passports, according… – Continue reading
Applying to renounce U.S. citizenship costs $2,350, up from the $450 it cost just last year. The U.S. government made more than $7.5 million from the record number of people who decided to officially renounce their citizenship in the first nine months of 2015. Simply applying to renounce U.S. citizenship… – Continue reading
A record number of Americans are renouncing their U.S. citizenship in 2015, new figures released by the federal government show. Since 1996, the IRS has published a list of citizens renouncing their citizenship every three months. The most recent IRS report, released Monday, reveals that 1,426 Americans ditched their citizenship… – Continue reading
With effect from November 1, mutual fund investors will have to make additional declaration pertaining to foreign account tax compliance act (FATCA) and common reporting standards (CRS) for all new accounts opened, failing which their applications will get rejected. Under FATCA and CRS, Indian financial institutions will be required to… – Continue reading
A record 1,426 US taxpayers gave up their passports or their green cards in the third quarter of 2015, according to Treasury Department statistics published in the Federal Register. The previous record was in the first quarter of this year, which saw a total of 1,335. The second quarter saw… – Continue reading
Come November 1, mutual fund investors will have to provide details and declaration pertaining to Foreign Account Tax Compliance Act (FATCA) and common reporting standards (CRS) for all new accounts opened, failing which fund houses are likely to reject their applications. While some fund houses have already started this process… – Continue reading
Expansion activities of companies lead to relocation of their employees to different territories, even outside the country. It goes without saying that transfer in job from one location to another comes with a baggage of issues, including the taxability of income from employment. The tax matter needs particular attention if… – Continue reading
The Cayman Islands Tax Information Authority (International Tax Compliance) (Common Reporting Standard) Regulations, 2015 (the “CRS Regulations”) were issued on 16 October 2015. Cayman Islands Government Industry Advisory – CRS Regulations Are in Effect The CRS Regulations, which are the first part of two in the roll-out of the Cayman… – Continue reading
Prime Minister of St. Kitts and Nevis, Dr. the Hon. Timothy Harris, was the featured speaker at the Financial Services Regulatory Commission – St. Kitts Branch’s (FSRC) 2nd annual Anti-Money Laundering/Countering the Financing of Terrorism (AML/CFT) seminar at the St. Kitts Marriott Resort on Wednesday, October 21, reports SKN Vibes…. – Continue reading
From 1 October 2015, all parties to transactions which include a transfer of land or an interest in land have to complete a “tax statement” as part of the registration process. We summarise how the new rules apply to trusts. New requirements in brief The tax statement is a one… – Continue reading
President Andrzej Duda signed last Friday a bill whose aim is to implement FATCA legislation – said the office of President. The law is designed to prevent US taxpayers hiding income abroad. The Act creates a legal basis that will allow implementation of the provisions under the international agreement ws…. – Continue reading
A little over a week ago the British parliamentarian, Sir Eric Pickles – a cabinet member until May of this year and a former Chairman of the Conservative Party – told the London Guardian that the British Prime Minister, David Cameron, was determined to have the BVI and the Cayman… – Continue reading
FATCA was passed to prevent U.S. citizens from evading tax by focusing primarily on foreign financial institutions with U.S. account holders. The Foreign Account Tax Compliance Act (FATCA) was enacted as part of the 2010 Hiring Incentives to Restore Employment Act, and its provisions became effective as of 7/1/14. FATCA… – Continue reading
Tax experts from the United States, United Kingdom, Canada, Brazil and Israel spoke at a two-day conference at Michigan Law about the challenges of the Foreign Account Tax Compliance Act (FATCA) and a multitude of other issues at the intersection of the law of taxation and citizenship. Panel discussions at… – Continue reading
In brief On 18 September 2015, Treasury released exposure draft legislation in relation to the implementation of the Organisation for Economic Co-operation and Development’s (OECD) Common Reporting Standard (CRS) for the automatic exchange of financial account information. The CRS is intended to reduce international tax evasion and represents the next… – Continue reading
It is estimated that only around 1% of the world’s population have two or more passports, making dual citizenship an exclusive privilege JOHANNESBURG – “No man is an island” is the theme of this year’s upcoming Investment Agenda, being held in Johannesburg on the 20th of October. Leading investors, asset… – Continue reading
Introduction The Foreign Account Tax Compliance Act (FATCA) requires non-US financial institutions, including investment entities, to report US account holders to the Internal Revenue Service (IRS). This reporting is causing US taxpayers living abroad to consider whether they have been adequately filing annually their income and information returns in the… – Continue reading
In addition to Justice Martineau’s denial of injunctive relief and dismissal of the request for summary judgment in Hillis and Deegan v. The Attorney General of Canada, as discussed in our previous post, U.S. citizens residing in Canada received more disappointing news on September 29, 2015, when Judge Thomas M…. – Continue reading
WASHINGTON, D.C. — United States authorities have begun the exchange of information with Mexico on all Mexicans with bank accounts or investments in the U.S. who have obtained more than $10 USD in annual interest. With the implementation of the Foreign Account Tax Compliance Act (FATCA), Mexico plans to deliver… – Continue reading
MUMBAI: The promoter of a Delhi-based, mid-sized, listed company has a Rs 700-crore problem. The cash is in various overseas accounts but the businessman has no plans of declare it before the black money deadline of September 30. Instead, he plans to invest it in the Indian capital markets by… – Continue reading
The IRS has let Americans living abroad wrongly claim tax credits on their foreign income, according to a new report from the agency’s watchdog. The Department of Treasury’s inspector general for tax administration said the IRS allowed taxpayers to wrongly claim around $95 million between 2010 and 2012 in foreign… – Continue reading
A long-awaited legal challenge against the US Foreign Account Tax Compliance Act (FATCA) was rejected in the courts. The Federal Court of Canada rejected an attempt from Virginia Hillis and Gwendolyn Deegan claiming that FATCA infringed the Canadian Charter of Rights and Freedoms and their right to enjoy security of… – Continue reading
