On October 1, 2016, the Indiana Office of Fiscal and Management Analysis of the Indiana Legislative Services Agency released a Combined-Reporting Study and a Transfer Pricing Study. These studies, which address corporate income tax issues, were required by legislation passed in 2016. The Combined-Reporting Study discusses the reduction of state… – Continue reading
Accounting firm’s contracts with federal government questioned. A former client of the accounting giant KPMG says a tax dodge that involved wealthy people gifting their money to an offshore jurisdiction was a “facade” designed to hide money from the taxman. The client, who spoke to CBC’s the fifth estate and… – Continue reading
New legislative proposals aim to establish the BVI International Tax Authority (ITA) as a fully fledged independent government institution in the British Virgin Islands with its own legal personality, giving it autonomy over the performance of its functions. The ITA was initially established within the Ministry of Finance to administer… – Continue reading
What is a business expense deduction? A business expense deduction is a deduction allowed for ordinary and necessary expenses paid or incurred in connection with an individual’s trade, business or profession. IRC Section 62(a)(1) operates to assure that all trade or business expenses, deductible as delineated under specific IRC Sections,… – Continue reading
Federal agents raided three Caterpillar buildings near its Illinois headquarters on Thursday, company and law enforcement officials said, in an escalation of an inquiry into the heavy equipment manufacturer’s offshore tax practices. Caterpillar has been dogged by accusations that it slashed its domestic tax bill by shifting corporate profits from… – Continue reading
Nonresident Alien NRA tax withholding is applicable to U.S sourced income paid to foreign person and does not apply to payments made to U.S. persons. Foreign persons include nonresident alien individual, foreign partnerships, foreign corporations, foreign estates, and foreign trusts. The tax generally must be withheld from the payment made… – Continue reading
The Internal Revenue Service (IRS) has reminded certain non-US citizens, such as international students and scholars working or receiving scholarship funds, that they may have special requirements to file a US tax return. The IRS also reminded withholding agents, such as payroll professionals or universities, that accurately filed Forms 1042-S,… – Continue reading
The Government recently issued a resolution to ratify an agreement and a protocol on avoiding double taxation and preventing income tax evasion between Vietnam and the United States of America. The Ministry of Foreign Affairs was asked to complete necessary procedures in accordance with law. Meanwhile, the Ministry of Finance… – Continue reading
The Canadian Government has said that it will review its tax ruling process and voluntary disclosures program as part of its response to recommendations made last year by a parliamentary committee. In October 2016, the Standing Committee on Finance released its report on the Canada Revenue Agency’s (CRA’s) efforts to… – Continue reading
U.S. multinational companies with more than $850 million in annual consolidated gross income now have draft instructions for filing IRS reports on their global tax and profits. The Internal Revenue Service added instructions to the draft Form 8975 and accompanying draft Schedule A it released in December 2016, companies that… – Continue reading
Global banking giant HSBC has disclosed being probed by tax authorities in India and several other countries, including against its Swiss and Dubai units, for allegedly abetting tax evasion of four Indians and their families. Besides, the bank has been approached by the regulatory and law enforcement agencies of various… – Continue reading
Jane Moir says the authorities’ plan to require companies to reveal their controlling owners, in the wake of the Panama Papers scandal, does not go far enough Last year’s Panama Papers revelations put Hong Kong in the crosshairs of global anti-money laundering bodies. The dump of 11.5 million documents from… – Continue reading
The government is pulling out all the stops to end perceptions that New Zealand is a tax haven. With tougher disclosure rules set to come into force from July following the Panama Papers scandal, Inland Revenue (IRD) is promising to pass on the details about those with New Zealand foreign… – Continue reading
Since President George W. Bush signed the Tax Relief and Health Care Act of 2006, the IRS has had a program that rewards Americans who inform the agency on tax dodgers. In its first decade, the program has helped the IRS recover $3.4 billion, and resulted in payouts of $465… – Continue reading
President of Panama Juan Carlos Varela signed into law today the implementation of the Convention on Mutual Administrative Assistance in Tax Matters (MAC), which allows for sharing tax information multilaterally on request with the 107 jurisdictions that are part of the convention and provides a common legal basis for cooperation… – Continue reading
Apple, which was recently slapped with a $14 bn tax bill for its activities in Ireland has now filed a 14-point appeal against the ruling. The EC had filed a case accusing Ireland of giving “state aid” to Apple. The European Commission (EC) charged Apple on various grounds, including tax… – Continue reading
Tax agency calls mandatory fingerprinting ‘a powerful deterrent’ The Canada Revenue Agency’s new policy to fingerprint every person it charges with tax evasion could create travel problems at the U.S. border for some Canadians who haven’t had their day in court The Canada Revenue Agency has begun to record the… – Continue reading
The CRA has the power to make a transfer pricing adjustment to any amount for a taxation year under s. 247(2) in respect of a non-arm’s length cross-border transaction. A taxpayer is also liable to a 10% penalty under s. 247(3), which penalty is determined with reference to the taxpayer’s… – Continue reading
We are all familiar with the use of offshore intellectual property holding companies to capitalize on international tax gradients. These companies are designed to take advantage of strategic local tax rules to reduce tax burdens on royalty streams generated from licensing. Because of these favorable tax treatments, countries like Luxembourg… – Continue reading
If the referendum passes, all public servants and elected officials in Ecuador will be barred from holding wealth in offshore accounts. As Ecuador heads to the polls Sunday to elect a new president and National Assembly, deciding the fate of President Rafael Correa’s 10-year Citizens’ Revolution, the small South American… – Continue reading
SEOUL, Feb. 16 (Yonhap) — The Cayman Islands became the largest investor as a tax haven country in the South Korean market last year, data showed Thursday, amid suspicions that some of the money could be owned by South Koreans disguised as foreign investors in an attempt to avoid taxes…. – Continue reading
For the third consecutive year, the US Internal Revenue Service (IRS) has placed abusive micro-captive insurance tax shelters on its list of top tax scams to watch out for in the 2017 filing season. The IRS explained that the US tax code generally allows businesses to create captive insurance companies… – Continue reading
Bilateral Economic Accord Key to Growing Trade and Investment WASHINGTON—Armenian National Committee of America (ANCA) Chairman Raffi Hamparian recently held a working meeting on Capitol Hill with U.S. Senator Robert Menendez (D-N.J.) on a range of shared priorities, including the negotiation of a new U.S.-Armenia Double Tax Treaty. This bilateral… – Continue reading
EU lawyers are preparing to mount a legal challenge against President Trump’s hugely controversial US border tax proposals in what could be the biggest case in World Trade Organisation history. Mr Trump’s proposed “border adjustment system” would see US imports subjected to tax, while export revenues exempted. The reforms have… – Continue reading
The federal government forgoes as much as $47.8 billion in uncollected taxes every year, according to a new report that Ottawa has yet to release. These billions represent only a fraction of all taxes that go unpaid because they don’t include taxes owed to the provinces and municipalities — all… – Continue reading
A new paper that calls for the introduction of a US carbon tax has been released by a group of former Republican administration members and economic advisers and leading business representatives. Issued under the auspices of the Climate Leadership Council, the paper proposes that the tax might begin at USD40… – Continue reading
On 7 February 2017, the Minister of Finance of Ukraine and the US Ambassador to Ukraine signed a treaty on Ukraine’s performance of the US Foreign Account Tax Compliance Act (FATCA) (the Treaty). According to the Ministry of Finance of Ukraine, the Treaty is based on the Model 1B Intergovernmental… – Continue reading
MARTINSBURG — The Internal Revenue Service has started releasing this year’s top 12 scams targeting consumers known as “The Dirty Dozen.” The annually compiled list features a variety of scams the agency says are common and that taxpayers could encounter anytime, but especially during peak filing season. Phishing schemes lead… – Continue reading
In the latest published data from the US Treasury Department and Federal Reserve Board in respect of November 2016, the value of Treasury Securities held by foreigners was $5.9tn with Japan’s holdings at $1.1tn and China at $1.0tn, followed by Ireland at $275bn. However, some further data show that the… – Continue reading
A CAMPAIGN has been launched in Washington DC to repeal international tax regulations that lobbyists say have cost Jersey and other finance centres billions of pounds. The controversial Foreign Account Tax Compliance Act, which was introduced in 2010 by President Barack Obama, requires all finance firms outside the US to… – Continue reading
The US taxes its citizens and permanent residents on their worldwide income regardless of where they live or how long they’ve lived outside of the US. There is only one other country in the world that operates like the US – Eritrea – an African nation. According to the IRS:… – Continue reading
The Foreign Account Tax Compliance Act (FATCA) United States of America Implementation and Enforcement of the Inter-Governmental Agreement was passed in Parliament without opposition, making it mandatory for Antigua & Barbuda’s banks to provide the banking information of US citizens to the Internal Revenue Service (IRS). The Act requires local… – Continue reading
Madison – Tax-related identity theft is an established concern nationwide, as state and federal tax authorities have wrestled for years with a blight of criminals filing fraudulent tax returns using other people’s personally identifiable information. For a scammer, tax identity theft means quick cash. For a victim, it’s a delayed… – Continue reading
Even though the Internal Revenue Service approves 94 percent of the applications it receives from charities for tax-exempt status filed through the simplified Form 1023-EZ, approximately a quarter of them do not meet the IRS’s own requirements. A recent report by the National Taxpayer Advocate pointed out that Treasury Department… – Continue reading
Swiss voters will vote next week on whether to reform corporate tax and remove the reduced tax rates that Switzerland currently grants to multinational firms. Voters will be asked whether they accept the federal law that was adopted by Switzerland’s national council in June 2016 “with a view to enhancing… – Continue reading
The Conference of State Bank Supervisors (CSBS) and state regulators have developed a self-assessment tool to help banks and financial institutions identify, monitor and communicate Bank Secrecy Act/Anti-Money Laundering (BSA/AML) risk. The BSA/AML Self-Assessment Tool is a spreadsheet intended to reduce uncertainty surrounding BSA/AML compliance and support more transparency within… – Continue reading
A Republican plan to overhaul the U.S. corporate income tax could put the dozens of existing U.S. double-tax treaties in limbo. U.S. companies doing business abroad may no longer be able to rely on the mechanisms in treaties for resolving cross-border tax disputes—overlapping claims on a company’s tax—or they may… – Continue reading
EU member states sent a letter to 92 countries on Wednesday (1 February) informing them that they will be “screened” with a view to inclusion in a future “blacklist” of tax havens. The list of the countries that have been contacted is not public, but EUobserver understands that it is… – Continue reading
The Kuwait Ministry of Finance (MOF) has issued a ministerial resolution announcing that Deloitte & Touche, Al-Wazzan & Co in Kuwait has been certified with the ministry for the provision of Foreign Account Tax Compliance (FATCA) services. FATCA is a US legislation which aims to combat tax evasion by US… – Continue reading
The OECD made its end-November 2016 deadline to release the text of the multilateral treaty to give effect to the BEPS Actions which involve changes to tax treaties, see here. The 49 page treaty text, which is commonly referred to as the multilateral instrument or MLI, and 85 page explanatory… – Continue reading
More than 20 informants have signed contracts with tax agency that could lead to reward money The Canada Revenue Agency’s offshore tax evasion tip line has resulted in signed contracts with more than 20 informants and more than $1 million in tax reassessments and penalties. The tips have also resulted… – Continue reading
The Caribbean Association of Banks (CAB) has expressed concern about the number of countries in the region which have not yet put in place inter-governmental agreements (IGAs) with the United States on the Foreign Account Tax Compliance Act (FATCA). It said it was therefore renewing the call for Caribbean countries… – Continue reading
Legislation reintroduced in both the Senate and the House of Representatives calls for the repeal of the estate tax, or “death tax” as it is commonly known in the United States. Until 2012, estates paid a 35 percent tax above a USD5m cap. The tax was scheduled to revert in… – Continue reading
Deutsche Bank will pay a $425 million fine in relation to a money-laundering scheme that regulators say moved $10 billion out of Russia, the New York State Department of Financial Services said Monday. The department said Deutsche was moving money out of Russia by using a stock “mirror trading” strategy,… – Continue reading
Documents for thousands of Canadian residents transferred under controversial FATCA legislation Banking records of more than 315,000 Canadian residents were turned over to the U.S. Internal Revenue Service last year under a controversial information sharing deal, CBC News has learned. That is double the number transferred in the deal’s first… – Continue reading
The Trump White House favours a “flexible” border adjustment tax targeting countries with which the United States runs big trade deficits, including Mexico, China and Germany, the President’s top trade and industry adviser said. Peter Navarro, a sceptic of free trade, wants the US to entice advanced manufacturing production onshore… – Continue reading
U.S. companies hold cash—lots and lots of cash—overseas to avoid paying the top corporate tax rate of 35% on those foreign earnings. But the rate could be heading down with a change in the federal government’s leadership, and the prospect of more repatriated earnings to work with has finance chiefs… – Continue reading
What GAO Found In 2015, the Organization for Economic Co-Operation and Development (OECD) issued revised guidelines, including 15 actions to help reduce base erosion and profit shifting (BEPS) of multinational enterprises (MNEs). One action focuses on transfer pricing guidance with the intent of aligning MNE profits with the location of… – Continue reading
On January 19, Greece and the United States signed an intergovernmental agreement (IGA) to facilitate compliance with the US Foreign Account Tax Compliance Act (FATCA) by financial institutions (FIs) in Greece. FATCA is intended to ensure that the US Internal Revenue Service (IRS) obtains information on financial accounts held at… – Continue reading
China’s banking regulator issued guidelines on Wednesday calling for the country’s financial institutions to strengthen their control and management of funding for outbound investment. The guidelines are the latest new rules on overseas investment as Beijing moves to clamp down on cross-border capital outflows and halt questionable investments. The China… – Continue reading
