When U.S. authorities want to ferret out abusive tax shelters, they send an army of forensic accountants, auditors and lawyers to burrow into suspicious tax returns. Analyzing mountains of filings and tracing money flows through far-flung subsidiaries are notoriously difficult; even if the Internal Revenue Service manages to unravel a… – Continue reading
A former Valparaiso businessman who federal prosecutors say lived in Canada for seven years to avoid an obstruction and perjury trial has been sentenced to not quite two years in prison, after finally admitting that he lied under oath to protect an offshore account worth millions of dollars from creditors…. – Continue reading
KEY POINTS What is the issue? Guernsey will be required to gather data for the calendar year 2016 for reporting under the Common Reporting Standard (CRS) in 2017. What does it mean for me? Practitioners should be aware that due diligence and reporting procedures are set to be amended and… – Continue reading
The number of banks with deferred prosecution agreements with the U.S. government keeps growing. The subject is tax evasion involving American account holders. Today, under FATCA, banks everywhere want to know if you are compliant with the IRS. And the IRS keeps updating its list of foreign banks where offshore… – Continue reading
Just one day after the October 15 deadline for filing personal income tax returns on extension, the Internal Revenue Service issued a strongly-worded warning to non-compliant taxpayers: take action now to fix your problem, or face serious consequences. At the same time, the IRS revealed, for the first time, that… – Continue reading
With more than 54,000 US taxpayers participating in the Offshore Voluntary Disclosure Program (OVDP) since 2009, the Internal Revenue Service (IRS) announced that it has collected more than USD8bn from this initiative to date. The IRS added that more than 30,000 taxpayers have also used the streamlined filing compliance procedures… – Continue reading
Offshore asset protection trusts avoid or diminish a number of creditor exposures that apply to such trusts organized in the U.S. High net worth individuals and persons involved in high liability exposure businesses and professions should consider establishing a “nest egg” offshore trust to provide a protected fund that is… – Continue reading
EY: Four out of 10 Czech businessmen asked for bribe Four out of 10 Czech entrepreneurs have been explicitly asked for a bribe and up to six out of 10 have encountered the possibility of gaining an advantage in their business in exchange for a bribe, according to a survey… – 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
With more than 54,000 taxpayers coming in to participate in offshore disclosure programs since 2009, the Internal Revenue Service is reminding U.S. taxpayers with undisclosed offshore accounts that they should strongly consider existing paths established to come into full compliance with their federal tax obligations. Both the Offshore Voluntary Disclosure… – Continue reading
ONE in every six homes sold in Westminster and Kensington & Chelsea over the last three years for which data is available was bought by a company in an offshore tax haven, the Eye has established. The market for homes is now so skewed by sales to overseas companies that… – Continue reading
Several close associates of Russian President Vladimir Putin may have benefited from Deutsche Bank AG trades that are now coming under the glare of U.S. prosecutors, according to people familiar with the matter. The U.S. Department of Justice is investigating whether Germany’s biggest bank properly vetted as much as $6… – Continue reading
The central government is stepping up its anti-graft drive by cracking down on illegal lending and money-laundering operations in a bid to prevent outbound flows of stolen assets. The Ministry of Public Security says “black banks” and illegal currency exchanges have facilitated the flights of a number of former government… – Continue reading
The following editorial appears in Friday’s Yomiuri Shimbun: International cooperation must be bolstered to close tax loopholes that can be exploited by multinational business corporations. The Group of 20 major economies and the Organization for Economic Cooperation and Development have worked out new international taxation rules to clamp down on… – Continue reading
The Department of Justice announced today that BBVA Suiza S.A. has reached a resolution under the department’s Swiss Bank Program. “Swiss banks such as BBVA Suiza S.A. are providing detailed information regarding their efforts to conceal U.S.-related accounts, and are turning over the names of individuals and entities that facilitated… – Continue reading
Orica has again found itself at odds with the Australian Taxation Office, this time over the circular financing arrangements the explosive maker put in place in 2002 to improve profits for the then struggling group. Orica has disputed the amended tax assessment from the ATO in relation to its “round-robin”… – Continue reading
A resolution was published in Panama’s official gazette in September 2015 replacing and “repealing” an August 2015 resolution, concerning how taxpayers may seek a ruling from the tax authorities as to whether benefits under income tax treaties for the avoidance of double taxation apply to the taxpayer’s specific transaction or… – Continue reading
With Medtronic being one of Ireland’s largest employers, analysts say there is a new incentive for the medical device maker to prioritize its Dublin headquarters for R&D. In the eyes of developed nations, Ireland has become notorious for baiting multinational firms to its land with the offer of friendly tax… – Continue reading
The Internal Revenue Service (IRS) has released a revised October 2015 version of its Publication 597, which provides information on the United States-Canada double taxation agreement (DTA), reports Tax News. A number of DTA provisions that most often apply to US citizens or residents who may be liable for Canadian… – Continue reading
In a summary judgment released on September 16, 2015, the Federal Court of Canada examined and disposed of the non-constitutional arguments in the Hillis and Deegancase[1] generally finding that the automatic data collection and disclosure of taxpayer information to the United States by Canada pursuant to the Canada-U.S. Intergovernmental Agreement… – Continue reading
PR chief, who pocketed more than £11m from his agency last year, attacks tax system for foreign-owned companies Matthew Freud has attacked the pittance Facebook pays in UK tax after footing a bill for almost £3m last year, as he pocketed more than £11m from his PR and marketing agency… – Continue reading
The Canada Revenue Agency (CRA) rents office space from a Vancouver-based property developer – a company that exploits offshore tax havens in Liechtenstein, the British Virgin Islands and Channel Islands. Larco Investments Ltd. owns three buildings in Montreal, Calgary and Edmonton where they rent office space to the CRA. Larco… – Continue reading
The United States has rejected India’s claim that schemes such as Atal Pension Yojana, Rashtriya Swasthya Bima Yojana, Employees Provident Fund Organization and others should be taken into account while determining the size of population covered under social security schemes. In recently resumed talks on Totalization Pact, the US said… – Continue reading
The Treasury Inspector General for Tax Administration has generally praised the US Internal Revenue Service for its implementation of the Foreign Account Tax Compliance Act. To improve US taxpayer compliance in reporting foreign financial assets and offshore accounts, Congress passed FATCA in March 2010. FATCA is intended to ensure that… – Continue reading
In just over two months, thousands of U.S.-based financial institutions will face new requirements for sharing financial information. These businesses should get ahead of the deadline and start preparing for the impact these rules will have on their operations and bottom lines. The Organisation for Economic Co-operation and Development’s new… – Continue reading
Do your individual clients howl about paying too much federal income tax? Just wait until you get an earful from your business clients. Advertisement A new report from the Tax Foundation, a conservative-leaning think tank located in our nation’s capital, found that the United States has the third-highest marginal corporate… – Continue reading
The chief of the generic drug company discussed her “counterintuitive” strategy for creating U.S. jobs. Mylan is one of a handful of U.S. companies that has recently completed a controversial tax inversion, as the generic drug company moved its official base to the Netherlands earlier this year. While the decision… – Continue reading
Individuals and families whose tax plans include trusts should take note of the recent decision of the Supreme Court of Newfoundland and Labrador in Discovery Trust v Minister of National Revenue (“Discovery Trust”)1 – the first case to deal with the issue of the residency of a trust for provincial… – Continue reading
Last week’s OECD release of the final package of measures for a coordinated international approach to the reform of the international tax system, under the OECD/G20 base erosion and profit shifting (BEPS) project, marks the end of the discussion and recommendation phase, and the start of the implementation and practical… – Continue reading
The Guernsey Association of Compliance Officers (GACO) October seminar covered the introduction of the Information Gateway Online Reporter (IGOR), an online portal for the purpose of collecting and exchanging Automatic Exchange of Information. https://igorforum.digimap.gg GACO chairman and Carey Olsen partner Mark Dunster said it is a key objective for the… – Continue reading
The Algeria and the United States signed Tuesday in Algiers an intergovernmental agreement on the sharing of tax information between the two countries and to promote financial transparency and the strengthening of bilateral and international fight against tax evasion. The agreement, first of its kind concluded by the US with… – 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
On 15 September 2015, the Bulgarian Council of Ministers submitted to the Bulgarian Parliament a proposal to implement the US Fair and Accurate Credit Transactions Act (FATCA) through changes in the Bulgarian Social Security Code. The proposed changes will effectively lead to the creation of an automated system for transfer… – Continue reading
To facilitate the exchange of Foreign Account Tax Compliance Act (FATCA) data under the intergovernmental agreements (IGAs) with Australia and the U.K., the U.S. Competent Authority has signed Competent Authority Arrangements (CAAs) with the Competent Authority of each country, announced IRS officials on September 24. The CAAs are the first… – Continue reading
The Organisation for Economic Cooperation and Development (OECD) is behind the new measures to automatically exchange tax information between nations and manage the differences on how tax issues are dealt with. Top ten countries The contractor management specialist CXC Global has identified the ten countries with the most aggressive approach… – Continue reading
LOS ANGELES—The Armenian National Committee of America – Western Region (ANCA-WR) is expressing its appreciation to Congressman Ted Lieu for authoring a letter to U.S. Treasury Secretary Jacob Lew in support of a U.S.-Armenia Double Tax Treaty. The accord, if concluded, would, by limiting the prospect of double taxation, remove… – Continue reading
Thanks to an agreement between the Department of Revenue’s Tax Administration Service (SAT) from September 30, all information regarding Mexicans with bank accounts in the United States and American citizens with bank accounts in Mexico agreement is being mutually sent. During the monthly breakfast Coparmex, the tax lawyer Jorge Alberto… – Continue reading
Oct 14 Germany’s Commerzbank has agreed with Cologne prosecutors to pay 17 million euros ($19.49 million) of fines for tax evasion, Sueddeutsche Zeitung reported on Wednesday, without citing the source of the information. Germany’s second biggest bank by market value is the country’s third lender after Hypovereinsbank and HSH Nordbank… – Continue reading
MUMBAI: The Central Board of Direct Taxes (CBDT) on October 13 signed four unilateral advance pricing agreements (APAs), including India’s second APA with a rollback provision. The nature of the transactions covered under these agreements varied from software development to share price valuation. According to government sources, the total number… – Continue reading
ISLAMABAD: Talent is universal, opportunities are not. A Pakistani is combating tax fraud in America and Russia using the same technology he earlier employed in Pakistan discovering 3.5 million out-of-tax-net rich individuals. Unlike the appreciation of his efforts abroad, the data he compiled in Pakistan has been thrown into the… – Continue reading
Ireland will introduce a new lower tax on intellectual property to keep and win more overseas investment as the government phases out a controversial loophole known as the “Double Irish.”, reports Bloomberg. The new knowledge development box will tax profits from patented innovations such as technological and pharmaceutical developments at… – Continue reading
The use of tax havens is ubiquitous across America’s 500 largest companies. Collectively, they hold $2.1 trillion in offshore cash, according to a recent study by Citizens for Tax Justice and the U.S. PIRG Education Fund. Establishing foreign subsidiaries in places with little or no tax such as Bermuda or… – Continue reading
The Organization of Economic Cooperation and Development (OECD) released its final reports on the G20/OECD Base Erosion and Profit Shifting (BEPS) Project on Monday October 5th, 2015. The final package of BEPS measures includes new minimum standards on: country-by-country reporting, which for the first time will give tax administrations a… – Continue reading
Information on Completing the Form 8802, Application for United States Residency Certification Many U.S. treaty partners require the IRS to certify that the person claiming treaty benefits is a resident of the United States for federal tax purposes. The IRS provides this residency certification on Form 6166, a letter of… – Continue reading
In 2014, seven major tech groups in Spain Declared collective profits of € 48.2 million, on Which They paid € 18.3 million in taxes. These online giants Real Their reduced corporate profits-through complex legal structures and accounting techniques That allowed them to shift part of the profits from Spain to… – Continue reading
Ireland, whose corporate tax rate of 12.5 percent is already one of the lowest in the developed world, said it would cut that rate in half for a new tax category — one covering revenue pegged to companies’ patents and other intellectual property. The Irish government, long criticized by other… – Continue reading
The Internal Revenue Service has made progress on implementing the Foreign Account Tax Compliance Act, including explaining the various requirements to the affected stakeholders, according to a new report. The report, from the Treasury Inspector General for Tax Administration, examined FATCA, which was included as part of the HIRE Act… – Continue reading
Bangladesh is set to sign an agreement with Bhutan to avoid double taxation to boost investments, trade and facilitate information exchange between the two Saarc nations, the National Board of Revenue said in a statement. A team led by NBR Chairman Md Nojibur Rahman is now in Thimpu to take… – Continue reading
Banking jobs in Geneva slipped to the lowest level since the 2008 financial crisis amid regulatory pressures, tax scrutiny and consolidation in the Swiss finance industry, according to lobby group Geneva Financial Center. Employees at banks in the city fell 3 percent to 18,855 in the 12 months through August,… – Continue reading
