Category: North America

Mauritius promises India clean and trusted jurisdiction

NEW DELHI: Often accused of being an offshore financial centre misused for round tripping, Mauritius today assured India that it will “walk the extra mile” to ensure that its reputations as clean and trusted jurisdiction is upheld at all costs. “We will put in all the necessary efforts and walk… – Continue reading

Tianjin tragedy is very much our business

Blast waves: smoke billows from the site of an explosion that reduced a parking lot filled with new cars to charred remains at a warehouse in northeastern China’s Tianjin municipality. Most of Bermuda’s major insurers and reinsurers had significant exposures to this disaster. (Photograph by Ng Han Guan/AP Photo) Tianjin… – Continue reading

Allergan Deal Could Take Pfizer Closer to Split, Move Abroad

Pfizer Inc. may be getting closer to breaking up and moving out. The largest U.S. drugmaker and Allergan Plc are considering combining operations, according to the Wall Street Journal. A deal would give Pfizer a way to move to a low-tax legal address abroad and gain valuable specialty drugs like… – Continue reading

US Justice Department Announces Four Banks Reach Resolutions Under Swiss Bank

The Department of Justice announced today that Luzerner Kantonalbank AG (Luzerner), Habib Bank AG Zurich (HBZ), Banque Heritage S.A. and Hyposwiss Private Bank Genève S.A. (Hyposwiss Geneva) have reached resolutions under the department’s Swiss Bank Program. These banks will collectively pay penalties totaling more than $25 million and continue to… – Continue reading

Barbados endorses OECD’s Global Standard for the Automatic Exchange of Information

Barbados has formally endorsed the AEOI global standard during a signing ceremony held in Barbados on Wednesday. The event was held in conjunction with a meeting of the OECD’s Global Forum on Transparency and Exchange of Information for Tax Purposes that was also hosted in Barbados. “Transparency and the exchange… – Continue reading

Renounce Citizenship: U.S. Government Makes Record $7.5 Million On Mandatory Citizenship Renouncement Fees

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

Kuwait commits to US mandated FATCA law

(MENAFN – Arab Times) The US Foreign Account Tax Compliance Act (FATCA) model has spurred the rise of a global automatic exchange of information, informed Hannah Shipley, Director at Ernst & Young, while speaking about FATCA and its implications during a business panel discussion held at the Kuwait Chamber of… – Continue reading

Jamiaca’s Financial Institutions Facing New Options

KINGSTON, Jamaica – Externally imposed requirements have had unintended and undesired consequences on Jamaica’s financial institutions, says Tasha Manley, Executive in charge of Compliance for Jamaica National Building Society (JNBS). Miss Manley was addressing this year’s annual conference co-hosted by the Jamaica Bankers’ Association (JBA) and the Jamaica Institute of… – Continue reading

OECD Issues Final BEPS Proposal; No Response from Congress Yet

Final recommendations about how multinational companies should be allowed to shift profits among different tax jurisdictions were issued this month, and the U.S. Congress has not yet indicated whether it will consider legislation in response to the proposals. Issued by the Organisation for Economic Cooperation and Development (OECD) on October… – Continue reading

U.S. lawmakers promise to push for long-delayed tax treaties

Republican and Democratic lawmakers vowed on Thursday to push for the ratification of eight tax treaties which have been held up for years because of one Republican senator’s objections, despite support from companies that want consistency in rules for how to do international business. U.S. Senator Rand Paul of Kentucky… – Continue reading

Mexico: Latin American Tax: Special Report

Mexico is experiencing a rough time, economically speaking at the moment, but hopes are high for better times ahead. With new tax laws and a relatively young government, these are interesting times for this country. To find out more about how the recent tax reforms will affect Mexico and the… – Continue reading

South African type controversy in Sri Lanka

(October 28, 2015, Colombo, Sri Lanka Guardian) “I and my family members have no secret accounts in Dubai banks,”said the Rajapaksa ‘Crown Prince’ Namal when the media published reports about a secret account in a Dubai bank of a son of a VVIP. The media reports stated that the Sri… – Continue reading

Australia out of step with global corporate tax rate trends

Australia’s corporate tax rate is higher than the global average, according to KPMG’s 2015 global tax rate survey, SmartCompany reports. While Australia’s corporate tax rate currently sits at 30 per cent, the global average sits at 23.68 per cent. The United States has the highest corporate tax rate at 40… – Continue reading

Transfer pricing makes big splash on global taxes

Multinationals have generated big-time revenues with its subsidiaries spread all over the world, which means huge profits and that’s taxable income. In recent years, a number of conglomerates – Amazon, Apple, Google and Starbucks – have engaged in so-called profit-shifting (profit allocation) via transfer pricing methods to pay minuscule taxes…. – Continue reading

U.S. corporate income tax is self-defeating

For many years, policymakers have criticized the strategies that American corporations use to reduce their taxes by shifting income and capital offshore. The impetus behind these strategies is the U.S. corporate income-tax rate — at 35 percent, the highest of any industrialized nation, easily surpassing countries such as the U.K…. – Continue reading

FATCA, bilateral meeting Pasquale Valentini – John R. Phillips

The Ambassador of the United States of America, John R. Phillips, today in the Republic for the signing of the intergovernmental FATCA, met this morning at Palazzo Begni, the Secretary of State for Foreign Affairs, Pasquale Valentini. A bilateral especially focused on the issues – all current – which has… – Continue reading

Barbados and Slovakia sign tax agreement

A DOUBLE TAXATION agreement was signed between Barbados and the Slovak Republic this afternoon. Minister of International Business Donville Inniss signed on Barbados’ behalf at a ceremony at Hilton Barbados. It is the 37th treaty signed between Barbados and another territory while Barbados became the 74th country to sign an… – Continue reading

Brazilian wealth seeks Cayman deals in complex environment

(CNS Business): The use of Cayman Islands funds as a wealth management tool for high net worth Latin American families was debated last week at the STEP LatAm Conference in Brazil, where kidnapping is a constant worry for the wealthy and demand for outbound investments is fuelled by privacy and… – Continue reading

New IRS regulations for mixed-use projects financed with tax-exempt bonds have practical importance

On October 27, 2015 the U.S. Treasury Department and Internal Revenue Service published final regulations concerning the treatment of “mixed-use” projects financed with tax-exempt bonds. These new regulations have significant and immediate importance for tax planning and tax compliance of tax-exempt bond issuers and borrowers. A copy of the new… – Continue reading

It’s Huffed And It’s Puffed, But HSBC Is Likely To Remain In The UK

After teasing the UK financial community — and the government — with a thinly-veiled threat to decamp from Britain, HSBC has continued to stoke speculation that it’s looking for more hospitable headquarters. Back in April, HSBC announced a review of whether to quit the UK, a somewhat provocative statement, coming,… – Continue reading

AUSTRALIA: TRANSFER PRICING, INTERCOMPANY FINANCING TRANSACTIONS

A decision by the Federal Court of Australia has key implications for transfer pricing of intercompany financing transactions, as well as implication for other broader intercompany arrangements. The case concerns the transfer pricing implications of an intercompany loan agreement between an Australian taxpayer and its U.S. subsidiary (CFC) and whether… – Continue reading

IRS urges Americans living in Canada to come clean after courts allow CRA to share account information with U.S.

The Internal Revenue Service is encouraging all non-compliant U.S. citizens, including those among the 1 million Americans who are resident in Canada, to take advantage of its voluntary disclosure programs initiated in 2009 and 2012. The move comes just a few weeks after Canadian courts refused to issue injunctions prohibiting… – Continue reading

Banks Et Al Brace For More Financial Account Information Reporting

On the heels of extensive preparation for the implementation of FACTA in St. Kitts and Nevis, banks and other financial institutions are now starring down the barrel of additional financial accounts information reporting on a wider scale. The Organization for Economic Co-operation and Development (OECD) has proposed a global version… – Continue reading

Jay Fishman: The U.S. corporate income tax is self-defeating

For many years, policymakers have criticized the strategies that American corporations use to reduce their taxes by shifting income and capital offshore. The impetus behind these strategies is the U.S. corporate income-tax rate — at 35 percent, the highest of any industrialized nation, easily surpassing countries such as the U.K…. – Continue reading

Tax havens become less attractive

THE NUMBER of Slovak companies with ownership registered in a tax haven decreased in the first half of 2015 by 112, to a total of 4,250. The biggest outflows were recorded in Monaco and the British island of Jersey. The declining trend of companies selecting a tax haven for their… – Continue reading

EU Lawmakers Set to Vote on Tax Avoidance in Split Europe

Lawmakers at the European Parliament are set to vote on a controversial series of proposals to harmonize the corporate tax system in Europe in a move that will put them on a collision course with some member states which favor sovereignty over taxation. The EU lawmakers on the TAXE committee… – Continue reading

The Mayor’s Free Land

A company controlled by Mayor of Belgrade Sinisa Mali and his family obtained more than 10 hectares of agricultural land worth anywhere from €123,000 to € 250,000 (US$140,000 to US$290,000) for free from a privatized state company. Problem is, the land wasn’t the company’s to give, but was still owned… – Continue reading

IRS Calls on Coca-Cola to Pay Up

Coca-Cola might owe an additional $3.3 billion in federal income taxes following an audit, says the Internal Revenue Service (IRS). Following a five year audit of the company, the IRS concluded that the company’s strategy of lowering its taxable income through transfer pricing, underestimates the amount the company should’ve been… – Continue reading

INVESTIGATION: How MTN ships billions abroad, paying less tax in Nigeria

MTN has consistently prided itself as the foremost telephone company that is getting Nigerians talking the most. Now the South African company is about to set tongues wagging across networks with revelations that it has routinely been shipping billions of naira overseas to avoid paying its fair share of tax… – Continue reading

Canada: IRS Reports On The Success Of Its Voluntary Disclosure Programs

Since the initiation of the U.S.Internal Revenue Service’s (IRS) Offshore Voluntary Disclosure Program (OVDP) which originally began in 2009 and the Streamlined Filing Compliance Procedures first offered on September 1, 2012, the IRS recently reported that more than 54,000 taxpayers have come forward and the result is more than $8… – Continue reading

Europe wants to get to the core of our Apple issue

The European Commission looks highly likely to make a finding against Ireland in relation to its tax arrangements with Apple, following two similar findings during the week involving Starbucks and Fiat. It is perplexing that the EC doesn’t just come out and make the announcement. The delay is leading to… – Continue reading