The Internal Revenue Service (IRS) has released the 2015 update to Publication 54, which provides guidance on the special tax compliance rules for US citizens and resident aliens who work abroad or receive income from foreign countries. The worldwide income of US citizens or resident aliens is generally subject to… – Continue reading
Fertilizer maker CF Industries and Dutch rival OCI NV, which agreed to merge in August, said they would move the tax residency of the combined company to the Netherlands from the U.K., in a move to satisfy inversion rules put in place by the U.S. Treasury. When the deal was… – Continue reading
When someone dies owning an unreported financial account, the heirs and executors of the estate are faced with a serious problem. First, assuming there is undeclared income earned with respect to the account, such income will generate a tax liability for the decedent with respect to any tax years that… – Continue reading
All insurers to undertake a value search for new accounts opened after Sept 1 and up to Oct 31 by Dec 31 Insurance regulator Irdai has directed all insurers to register and submit information to CBDT for compliance with the obligations under Foreign Account Tax Compliance Act (FATCA) – Common… – Continue reading
The start date for the Common Reporting Standard (CRS) in early adopting countries is approaching fast, with financial institutions required to begin new account on-boarding procedures from 1 January 2016. CRS requires financial institutions in participating jurisdictions to identify account holders who are tax resident in other participating jurisdictions and… – Continue reading
President Obama signed the Protecting Americans from Tax Hikes Act of 2015 (the “Act”) into law on December 18, 2015. The Act extends retroactively certain provisions of the Internal Revenue Code (the “Code”) that had expired at the end of 2014 and makes a number of other changes to the… – Continue reading
A United States UBS bank client has failed in his bid to sue the Swiss authorities for handing his data to the US during a tax evasion row between the two countries. The European Court of Human Rights (ECHR) said the economic interests of Switzerland outweighed his individual privacy. The… – Continue reading
The Cayman Islands Tax Information Authority (TIA), on December 8, 2015 provided the following implementation updates for the Common Reporting Standard (CRS): 1. Updated Self-Certification Forms ( Individual and Entity) for compliance with CRS, U.S. and U.K. FATCA, which should be used by Cayman Islands funds. From January 1 onwards,… – Continue reading
CF Industries (CF – Analyst Report) and Netherlands-based fertilizers and industrial chemicals producer – OCI N.V. – said that they have amended their merger agreement originally announced in Aug 2015. Under the modified agreement, the jurisdiction of incorporation and tax residency of the new combined company has been changed to… – Continue reading
Dec. 21 — The IRS proposed rules requiring large companies to report information including the amount of revenue, profit or loss, capital and accumulated earnings for each country of operation, consistent with OECD recommendations designed to combat base erosion and profit shifting. The proposed rules (REG-109822-15, RIN 1545-BM70) would apply… – Continue reading
American expats could have their passports revoked next month if they fail to comply with their tax and financial obligations. American expats could have their passports revoked next month if they fail to comply with their tax and financial obligations under the Foreign Account Tax Compliance Act, or Fatca, a… – Continue reading
A BALANCING ACT in London, folly and redemption in America’s District of Columbia and sheer hypocrisy in Brussels. And in every case, Barbados and many of its Caribbean neighbours were placed in the negative international spotlight at a time when some of the world’s major financial centres are casting about… – Continue reading
The Treasury Department released a proposal on Monday that would require certain companies to annually report information relating to income and taxes on a country-by-country basis. The proposal would apply to businesses that are the parents of multinational enterprise groups with annual revenue of at least $850 million. The categories… – Continue reading
IRS Criminal Investigation » Agency initiated 3,853 investigations nationally and is nabbing criminals from tax cheats to terrorists despite budget cuts, chief says. Utahn Gerrit Timmerman III claimed his corporation — “The Office of the First Presiding Patriarch (Overseer) and his/her successors, a corporation sole over/for an unincorporated scriptural society,… – Continue reading
IT is ironic that what was almost at the centre of the BEPS project has ended up in not having a concrete agreement and with a vague promise of some review by the year 2020. One may recall that it was the big digital companies and their tax affairs that… – Continue reading
It is possible that the United States expats could have their passports revoked next month if they fail to comply with their tax and financial obligations under the Foreign Account Tax Compliance Act (FATCA). This was revealed by Mr. Jim O’Niell, Vice President of US Financial Advisory & Audit Firm… – Continue reading
American citizens risk losing passports if they do not report foreign income, bank accounts Dubai Americans must comply with tax law changes coming into effect in the new year and report income earned abroad and foreign-held bank accounts over $10,000 (Dh36,700) or else they risk losing their passports, a US… – Continue reading
The Protocol amending the Multilateral Convention on Mutual Administrative Assistance in Tax Matters will lead to substantially more transnational identity theft, crime, industrial espionage, financial fraud, and the suppression of political opponents and religious or ethnic minorities by authoritarian and corrupt governments. It puts Americans’ private financial information at risk…. – Continue reading
The Markets Supervision Directorate of the Central Bank published its programme of themed-inspections for 2016. These inspections reflect a number of supervisory priorities for 2016 and anticipate areas of emerging risk. This programme builds on the successful supervisory work undertaken in 2015 in the areas of Cyber Security, Operational Risk… – Continue reading
While Cayman National maintains its financial stability it says it is unable to declare a dividend as it prepares to pay some CI$5 million as a potential settlement with the US authorities over criminal law breaches related to tax evasion. The financial institution, in its Fourth Quarter report (ending 30… – Continue reading
Swiss private banking group Julius Baer Group Ltd. (JBAXY.PK,JBARF.PK) may have to pay more than it anticipated to settle a case with the U.S. Justice Department over American offshore accounts, according to media report quoting people familiar with the matter. The report indicated that the U.S. prosecutors could ask Julius… – Continue reading
The provisions commonly known as the Foreign Account Tax Compliance Act (FATCA) became law in March 2010. •FATCA targets tax non-compliance by U.S. taxpayers with foreign accounts •FATCA focuses on reporting: •By U.S. taxpayers about certain foreign financial accounts and offshore assets •By foreign financial institutions about financial accounts held… – Continue reading
An Easy Checkoff for Global Competitiveness: The Case for a U.S. Innovation Box – Robert D. Atkinson – November 30, 2015. “Taxing corporate revenues from innovation-based activities less will not only boost U.S. global competitiveness it will help bring back IP-based corporate profits now overseas. “Within the last decade a… – Continue reading
Legal experts say court order for restaurant’s parent company based in British Virgin Islands could lead to resolution of more disputes in city Hong Kong’s top court recently gave the go-ahead for the parent company of the famous Yung Kee roast goose restaurant in Central to be wound up, despite… – Continue reading
NEW YORK – The General Manager of Pakistan’s Habib Bank Ltd., New York branch, said Friday that steps have been taken to address the concerns of U.S. authorities after being hit by an enforcement order that barred the bank from conductingany dollar-clearing transactions or accepting any new accountsfor U.S. dollar… – Continue reading
Caribbean nations have long served as tax havens for the world’s economic elite, with many offering so-called economic citizenship where, for large payments, one can simply buy citizenship in their countries. That can save the 1 percent a pretty penny. Overseas tax evasion costs the U.S. government as much as… – Continue reading
Apple CEO says the company pays ‘every tax dollar we owe’ amid debate in the US over corporations avoiding tax by using offshore units Apple’s chief executive Tim Cook has dismissed as “total political crap” the notion that the technology giant was avoiding taxes. Cook’s remarks, made on CBS’ 60… – Continue reading
Edmond de Rothschild (Suisse) SA agreed to pay $45.4 million to avoid prosecution for helping U.S. clients evade taxes, admitting it aided them in moving cash and using sham offshore entities to hide money from the Internal Revenue Service. Rothschild is the 68th Swiss bank to reach an accord with… – Continue reading
About Botswana Botswana, a former British colony in Southern Africa, is one of the most prominent countries in Africa. The country has a strong economy,uses one of the most advanced banking systems in the continent, and maintains a stable tradition of representative democracy. After becoming independent in 1966, Botswana developed… – Continue reading
As the Government of Jamaica moves on its agenda to prevent revenue leakage through transfer pricing legislation, local companies are still waiting to see what impact the changes will have on their operations. The new law allows for the detailed examination of the accounts of companies with associates and branches… – Continue reading
The Bundesrat (upper house of the German parliament) approved the Law on the Automatic Exchange of Financial Account Information (Finanzkonten-Informationsaustauschgesetz) on 18 December 2015. Financial institutions face new reporting obligations and duties of care under this law. The new legislation requires financial institutions to provide the German Federal Central Tax… – Continue reading
When purchasing a real property overseas, there are situations when it may prove advantageous or even necessary to do so through an offshore corporation, rather than owning the property individually. It is crucial to understand that this can also have significant US tax consequences for US persons. Fortunately, “checking the… – Continue reading
The Department of Justice announced today that Edmond de Rothschild (Suisse) SA and Edmond de Rothschild (Lugano) SA (collectively EdR Switzerland) reached a joint resolution under the department’s Swiss Bank Program. EdR Switzerland will pay a penalty of more than $45 million. The Swiss Bank Program, which was announced on… – Continue reading
MUMBAI|NEW DELHI: Many US-based non-resident Indians are considering selling their property in India – even at a discount – amid confusion and fear that a new information-sharing protocol may bring their assets, bank accounts, mutual funds and capital market investments in India under the scanner of US tax authorities. India… – Continue reading
Group companies, irrespective of the jurisdiction, will have to conform to common standards The Organization for Economic Cooperation and Development (OECD) recently released 15 action-plans to address the issue of “Base Erosion & Profit Shifting” or BEPS, which has led to misalignment between where taxes are paid and where value… – Continue reading
Employees relocating from Canada to the US may face a number of complex tax-related issues. Matt C Altro, president and CEO of Canadian firm MCA Cross Border Advisors, shares his advice for companies and their relocatees on planning for, and coping with, these challenges. Talent mobility is a key issue… – Continue reading
2016 Compliance Update For the past few years, FATCA has dominated the international tax compliance landscape. As that regime continues to be phased-in, a new regime – the Common Reporting Standard (“CRS”) – will begin to be implemented around the world. CRS, sometimes referred to as “Global FATCA,” will expand… – Continue reading
Liability below the mid-point of the range in IPO prospectus TORONTO, Dec. 18, 2015 /CNW/ – Spin Master Corp. (“Spin Master” or the “Company”) (TSX: TOY) announced today that it has reached a settlement agreement with the Canada Revenue Agency (“CRA”), which resolves a previously disclosed transfer pricing matter arising… – Continue reading
Not only is Dec. 31 the deadline for any last-minute, year-end tax planning you may be contemplating, but it may also be the last day to come clean to the tax man if you still have an undisclosed Swiss bank account. If that’s you, consider getting your act together and… – Continue reading
SYDNEY, Dec 17 (Reuters) – Australia on Thursday identified 600 companies which it said paid no tax last financial year, including Halliburton Co and Hilton Worldwide Holdings Inc, as part of a campaign to challenge “overly aggressive” tax arrangements. The Australian Taxation Office published the income and tax rates of… – Continue reading
According to a research report titled “Illegal Financial Flows from Developing Countries: 2004-2013”, recently published by the Washington based research institute Global Financial Integrity (GFI), Bangladesh stands 26th in the list of 149 developing nations, in terms of flight of capital including money laundering (The Daily Star, December 10, 2015)…. – Continue reading
Dreyfus Sons & Co. has operated for two centuries as a private Swiss bank, catering to Jewish clients who wanted to hide assets from the Nazis during the 1930s and World War II. More recently, it helped U.S. clients hide assets from the Internal Revenue Service by concealing their true… – Continue reading
The Cayman Islands (along with the United Kingdom, Ireland, Jersey, Guernsey, the British Virgin Islands and over 70 other countries) has committed to implementing the OECD Common Reporting Standard (“CRS”), which will require investment funds to collect tax identification and tax residency information from all new subscribers and transferees (including… – Continue reading
China has become the 77th party to an OECD agreement enabling the automatic annual exchange of tax-related information. The country signed up to the Multilateral Competent Authority Agreement (MCAA) yesterday, which specifies which information will be exchanged and when, and renewed a co-operation agreement between the OECD and the Chinese… – Continue reading
It has been a tough year for Russian businesses. The latest monthly forecast of the Economist Intelligence Unit (EIU) predicts a contraction in Russian real GDP of 3.8% in 2015 and another 0.5% in 2016. “Structural weaknesses will keep trend GDP growth below 2% a year in the medium term,”… – Continue reading
Australian tax authorities on Thursday took the unprecedented step of publishing the records of hundreds of companies, including Google Inc (GOOGL.O) and Apple Inc APPL.O, which show they paid little or no tax on their in-country earnings. Of more than 1,500 largely foreign-owned companies which reported total earnings over A$100… – Continue reading
Fifty-three jurisdictions have agreed to automatic exchange of tax information beginning in 2017, under the OECD’s Common Reporting Standard. Over 40 others have committed to exchange information by 2018. Another wave of global tax information is about to take place, and financial institutions everywhere are in a race to prepare… – Continue reading
Given that the latest treaty was signed on 15 November 1967, the two countries felt it was appropriate to revise it in full. The new treaty, signed on Tuesday by the Spanish Ambassador to Finland, María Jesús Figa, and the Finnish Minister for Finance, Alexander Stubb, seeks to enable tax… – Continue reading
Over 90 jurisdictions have committed to the OECD’s Common Reporting Standard (CRS), creating comprehensive global automatic information exchange for financial assets and the entities through which such assets may be held. Over 70 jurisdictions have signed the OECD’s Multilateral Competent Authority Agreement, which implements the CRS. The CRS is scheduled… – Continue reading
Draft 2015 Instructions for Form 8966. IRS has published a draft version of the instructions to the 2015 Form 8966 (FATCA Report), which certain foreign financial institutions (FFIs) and others use to report information with respect to U.S. accounts under the Foreign Account Tax Compliance Act (FATCA). The instructions reflect… – Continue reading
