The BMF has application letter sent to the chief financial authorities of the countries associated with the between the Federal Republic of Germany and the United States of America concluded by 31.5.2013 FATCA Agreement. Background Background of extensive, comprehensive 71 pages, application letter from the Federal Ministry of Finance on… – Continue reading
Rep. Mark Pocan, D-Wis., has introduced two pieces of legislation to combat corporate tax inversions and tax deferral. The Corporate Fair Share Tax Act and the Putting America First Corporate Act would prevent corporations from using “tax inversions” to reduce a company’s U.S. tax burden and hide profits overseas. Corporate… – Continue reading
Tax-driven “inversion” deals that let companies flee the U.S. tax system by relocating abroad, if only on paper, would be curbed under legislation introduced in Congress, as Pfizer Inc (PFE.N) pursues such a deal with rival Allergan Plc (AGN.N). Wisconsin Democratic Representative Mark Pocan’s bills likely have little chance of… – Continue reading
In a time of fiscal austerity, it is breathtaking to learn that Congress has allowed Fortune 500 companies to avoid an estimated $620 billion in federal taxes on earnings they are holding offshore. While the inaction by lawmakers on this issue may create the impression that there is nothing to… – Continue reading
Economist and policy consultant, Avernash Persaud is urging government to remove concessions for foreign investors, a similar advice proffered by the International Monetary Fund (IMF). Persaud said government should instead focus its attention on infrastructure development. Persaud, who has assisted in policy development in countries like Singapore, said investors will… – 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
NEW YORK, Nov. 9, 2015 /PRNewswire/ — Business executives cited an increased compliance burden as their biggest concern with the Organization for Economic Cooperation and Development’s Base Erosion and Profit Shifting initiative (37.7 percent), according to an October Deloitte poll. Other concerns included double taxation of income (17 percent) and… – Continue reading
FRANKFURT (The Street) — Europe’s allure as a tax haven for U.S. multinationals may be coming to an end. That’s because European Union regulators are closing up tax loopholes that U.S. companies have been enjoying for years. The first two to feel the heat are Starbucks (SBUX – Get Report)… – Continue reading
The opaque governance structure of sports federations makes them less accessible to independent oversight and therefore more prone to corruption, the deputy managing director at Transparency International, a global anti-corruption movement, told Sputnik. ST. PETERSBURG (Sputnik) – Earlier this year, separate investigations by US and Swiss prosecutors uncovered deep-rooted corruption… – Continue reading
The Financial Stability Board (FSB) has today published a Report to the G20 on actions taken to assess and address the decline in correspondent banking. This report provides an update on work by the FSB in partnership with other organisations to examine the extent and causes of banks’ withdrawal from… – Continue reading
Recent CRA comments at the May 2014 IFA international tax seminar1 and a subsequently released CRA technical interpretation2 highlight anomalies in the application of subsections 92(4) and (5) of the Income Tax Act (Canada) (the “Act“).3 These provisions address the situation where shares of a foreign affiliate are held by… – Continue reading
A blacklist of tax havens by the U.S District of Columbia, which featured the Channel Islands, has been repealed. The Bailiwicks were listed as part of a plan to highlight international jurisdictions the U.S. considers to be used by people trying to avoid paying tax. The Chief Minister was opposed… – Continue reading
No member state of the Caribbean Community (CARICOM) ranks among the top 20 jurisdictions worldwide for financial secrecy. The United States of America (at number 3), Germany (8), Japan (12) and Britain (15), all rate as bigger tax havens than any CARICOM jurisdiction, according to the Tax Justice Network (TJN),… – Continue reading
The recent corporation tax controversy highlighted by US presidential hopefuls Hillary Clinton and Donald Trump is not damaging Ireland’s reputation as a place to do business, said the former chief executive of Apple, John Sculley. According to Mr Sculley, the controversy is simply part of US election fever. Known as… – Continue reading
The Redmond tech company and the Internal Revenue Service tangled in court Friday over the government’s audit of Microsoft’s software sales through offshore subsidiaries. Microsoft and the Internal Revenue Service sparred in court Friday over the agency’s power to investigate taxpayers. Microsoft, seeking a court order to overturn a portion… – Continue reading
On September 18, 2015, the Internal Revenue Service (IRS) released Notice 2015-66 announcing its intention to amend certain of the regulations under Chapter 4 of the Code (the “FATCA regulations”), to extend the period of time that certain of the Foreign Account Tax Compliance Act (FATCA) transitional rules will apply,… – Continue reading
ST. JOHN’S, Antigua, Friday November 6, 2015 – No member state of the Caribbean Community (CARICOM) ranks among the top 20 jurisdictions worldwide for financial secrecy. The United States of America (at number 3), Germany (8), Japan (12) and Britain (15), all rate as bigger tax havens than any CARICOM… – Continue reading
Paul Singer has a good track record as a money manager. In 1995, he bought $20 million worth of Peruvian debt at a discounted price of $11.4 million, then forced Peru’s government, through lawsuits, to eventually pay nearly five times his initial investment — some $58 million. In 2002 and… – Continue reading
Exclusive More than 100 victims of notorious conman Peter Foster have moved to freeze funds held in offshore tax havens after more than $10 million was siphoned from his online gambling company Sports Trading Club. Fairfax Media can reveal Foster and at least eight associates have been served with freezing… – Continue reading
With local financial institutions bracing for the impact of the Foreign Account Tax Compliance Act (FATCA) and Common Reporting Standard (CRS) reporting requirements, a recent partnership between a tax law firm and financial information services firm could well increase the ease of reporting for U.S. citizens living in The Bahamas…. – Continue reading
The BVI has announced amendments to its Anti-Money Laundering (AML) regime in order to ensure continued compliance with developing international standards on transparency and AML regimes. Amendments to the legislation have recently been published (Code of Practice and Regulations) and the proposed changes are to take effect on 1 January… – Continue reading
(Seychelles News Agency) – Seychelles’ efforts to comply with the widely-recognised Organisation for Economic Co-operation and Development (OECD)’s regulations on the sharing of tax information has led the island nation’s jurisdiction to be rated ‘largely compliant’. This follows a re-assessment of the island nation’s ‘practical implementation’ of its legal and… – Continue reading
On September 7, 2015, the local tax court of Cologne (the “Court”) issued an injunction against the German Federal Central Tax Office (“FCTO”) to prevent the FCTO from conducting a coordinated exchange of information with the E6 countries Canada, Great Britain, France, Australia and Japan, which aimed at gathering intelligence… – Continue reading
In Canada, taxes are levied at the federal, provincial and municipal levels of government. At the federal level, the government generates most of its revenue by way of income taxes and excise taxes imposed on the distribution and consumption of goods and services in Canada. The provinces and territories also… – Continue reading
Germany’s Federal Ministry of Finance on 3 November 2015 released final guidance notes for implementation of the FATCA regime. An intergovernmental agreement (IGA) signed by Germany and the United States follows the Model 1 IGA. Accordingly, financial institutions in Germany are required to report information concerning assets held by U.S…. – 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
Technology company made the largest profit in its history in year to end of September Apple’s latest annual report indicates a substantial increase in the amount of tax it may be paying in Ireland. The latest annual report from Apple, filed last week in the United States, indicates a substantial… – Continue reading
The UK government has a ‘Janus-faced’ approach to tax, a new report suggests: promising an increasingly intolerant approach to evasion and avoidance while being an aggressive participant in global tax competition and tolerating the UK tax havens which facilitate financial crime across the world. The report, Fifty Shades of Tax… – Continue reading
A former finance minister yesterday slammed as “patently false” suggestions by a prominent tax advocacy group that the Bahamas is “disregarding the rules” and flouting global information exchange and transparency standards. James Smith, also an ex-Central Bank governor, hit out at the Tax Justice Network after its 2015 Financial Secrecy… – Continue reading
Barbados and Slovakia signed a double tax agreement on October 28, 2015, to boost investment and trade prospects. The DTA allocates taxing rights to the two territories, to ensure that cross-border income is not taxed twice. It further stipulates that cross-border income from dividends will be subject to a withholding… – Continue reading
Sixteen peer review reports were released at the recent plenary meeting of the OECD Global Forum on Transparency and Exchange of Information for Tax Purposes on October 29-30, 2015. The release of the reports follows reviews of those territories’ legislation for the exchange of tax information and their frameworks for… – Continue reading
The timely and effective implementation of the automatic exchange of tax information was a key theme during the Oct. 29-30 meeting of the Global Forum on Transparency and Exchange of Information for Tax Purposes held in Bridgetown, Barbados. The meeting, which brought together delegates from the Global Forum’s 128 member… – Continue reading
PanARMENIAN.Net – The negotiation of a U.S.-Armenia Double Tax Treaty will be on the agenda of the upcoming U.S.-Armenia Economic Task Force meeting, an annual bilateral gathering taking place in Washington, DC on November 19. The Armenian National Committee of America (ANCA) welcomed the initiative, suggesting that the Administration support… – Continue reading
The time of gaming the international tax system is over for big business, following the endorsement of the OECD’s Base Erosion and Profit Shifting (BEPS) project Corporations have to realise that “playtime is over, now you have to come back to school and play with the new instruments”, said Pascal… – Continue reading
One year after the announced closing off of the Double Irish tax arrangement, U.S. multinationals once again turned their attention to Dublin as Ireland announced details of the Knowledge Development Box, or KDB. This new component to its corporate tax regime will allow companies to pay a reduced corporate tax… – Continue reading
The Bahamas will likely suffer a 25 per cent contraction in the number of financial services industry players, a senior international private banking executive said yesterday, as institutions merge to acquire scale and maintain profitability. Ricard Tubau, Andbank’s global chief executiv, said that not only is the financial services industry… – Continue reading
On Wednesday, a federal jury found an Anchorage plastic surgeon guilty of wire fraud and tax evasion after he hid assets worth millions of dollars during his divorce. The trial against Michael Brandner, 67, lasted eight days and resulted in convictions on four counts of wire fraud and three counts… – 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
After being in effect for only a week, the Council of the District of Columbia (Council) unanimously enacted legislation today that will repeal the list of tax haven jurisdictions specifically enumerated in the D.C. Code. The legislation, titled the Fiscal Year 2016 Second Budget Support Clarification Emergency Amendment Act of… – 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
Hong Kong is the world’s second least transparent financial center, making it vulnerable to tax evasion, money laundering and other wrongdoing. It is topped only by Switzerland in a global survey by Tax Justice Network, a coalition of researchers and activists focused on tax avoidance issues. The United States ranks… – Continue reading
They say the only certain things in life are death and taxes, but a large number of non-U.S. citizens may have found a way to avoid at least one of those. Under U.S. tax law, the estates of foreign holders of U.S. assets, such as stocks, real estate and valuables,… – Continue reading
Non-resident Indians (NRIs) have one more investment option to choose from. The Reserve Bank of India (RBI) has allowed NRIs to invest in the National Pension System (NPS), under Foreign Exchange Management Act. NPS will allow NRIs to invest in a mix of equities and debt and save for their… – Continue reading
Speed read Europe’s highest court has turned the US into a privacy pariah, and the fallout could have a major impact on New Zealand businesses. Tech companies and cloud computing providers, big and small alike, are staring down the barrel of increasingly uncertain privacy compliance challenges, as are their customers…. – Continue reading
Dutch Finance Minister Jeroen Dijsselbloem said the Netherlands wants to make as much progress as possible in clamping down on tax avoidance by multinational corporations during its EU presidency, after criticism from the European Commission, reports Reuters. The Dutch tax system has enabled some corporations to pay almost no taxation… – Continue reading
The US has overtaken Singapore, Luxembourg and the Cayman Islands as an attractive haven for super-rich individuals and businesses looking to shelter assets behind a veil of secrecy, according to a study by the Tax Justice Network (TJN), reports The Guardian. The US is ranked third, behind Switzerland and Hong… – Continue reading
Payments made to Luxembourg, Cyprus, and the Seychelles during the current tax period are no longer required to be reported, according to the findings of a 29-30 October 2015 meeting of the Global Forum on Transparency and Exchange of Information for Tax Purposes. The conclusion of the October 2015 meeting… – Continue reading
Billionaire JP McManus sought to pay just €200,000 in tax on gambling earnings of €15.8m. The disclosure was made in filings to a US court, where the horse owner and philanthropist is seeking the refund of $5.2m (€4.7m) in taxes taken from his winnings by the US government. Authorities there… – Continue reading
Pharmaceutical giant Shire, which is headquartered in Ireland for tax purposes, has agreed to buy US rare disease specialist Dyax Corp for about $5.9bn (€5.35bn), and potentially up to $6.5bn, while still pursuing a five- times larger unsolicited bid for biopharma firm Baxalta Inc. The Dyax deal, the latest in… – Continue reading
The Department of Justice announced today that Banque Bonhôte & Cie SA (Banque Bonhôte) has reached a resolution under the department’s Swiss Bank Program. The Swiss Bank Program, which was announced on Aug. 29, 2013, provides a path for Swiss banks to resolve potential criminal liabilities in the United States…. – Continue reading
