Category: North America

Valeant’s latest tax-cutting tactic, courtesy of Luxembourg

Valeant is famous for wringing cost savings out of its buyouts, and its tax-advantaged Canadian domicile helps on that front. Now, it’s leveraging another address to pare down Salix’s tax bill by more than $560 million. But how? According to documents seen by The Wall Street Journal, the strategy used… – Continue reading

‘30% of foreign investors from tax havens’

About 30 percent of foreign investors in Korea are from overseas tax havens, a lawmaker said Tuesday. Citing data from the Financial Services Commission and the Korea Customs Service, Rep. Park Kwang-on of the main opposition New Politics Alliance for Democracy (NPAD) said that the number of corporate or individual… – Continue reading

Taxation issues concerning high networth individuals

What constitutes an HNI is a tricky question? In general parlance, HNIs are understood to be the individuals with ultra-high networth with deep pockets having surplus investible funds. As per the Credit Suisse global wealth report, currently India is home to around 1,500 ultra-high networth individuals with wealth of at… – Continue reading

High tax rate may deter global talent, warns Irish Tax Institute

Marginal rate ninth highest in 34 OECD countries, pre-budget submission claims Ireland risks deterring high- calibre foreign executives from moving here because of its relatively high tax rates, the Irish Tax Institute has warned. In a pre-budget submission, the institute said Ireland’s marginal tax rate of 52 per cent was… – Continue reading

“Tax haven” list could damage reputation of Caribbean countries

BY DAVID JESSOP— The Caribbean has just 18 congressional working days from Sunday, September 20 to try to have the U.S. Congress address an act naming 17 Caribbean nations as “tax havens”. If passed without amendment, it could have the effect of reputationally damaging the countries concerned with unpredictable trade,… – Continue reading

NPS Votes 2015: Elizabeth May urges the Canadian government to stop transfer of Canadians’ private banking information to US

(OTTAWA) – Elizabeth May, Leader of the Green Party of Canada (Saanich-Gulf Islands), issued a letter to Stephen Harper, urging him to extend the IRS deadline for Foreign Accounts Tax Compliance Act (FATCA). “The private banking information of hundreds of thousands of Canadian citizens and permanent residents is set to… – Continue reading

D.C.’S Bahamas Blacklist Branded ‘Inconsequential’

A former financial services minister yesterday branded as “inconsequential” concerns over the District of Columbia’s (DC) pending ‘tax haven’ blacklisting of the Bahamas and 16 other Caribbean nations. Ryan Pinder, now a senior executive at Deltec Bank & Trust, was responding to concerns raised by Opposition finance spokesman, K Peter… – Continue reading

Untapped funds can help pay for Sustainable Development Goals

Development Goals (SDGs) but poorer countries should exercise caution when borrowing money, Gail Hurley, a development finance expert with the UN Development Program (UNDP), told Xinhua. “There’s a lot more finance available now—public and private, domestic and international — (but) a lot of it is loan finance, so we do… – Continue reading

FATCA Update: Treasury Relaxes September 30 Deadline for Model 1 IGA Jurisdictions to Exchange Tax Information

With less than two weeks remaining until many countries are required to exchange tax information with the U.S. pursuant to the Foreign Account Tax Compliance Act (FATCA), the U.S. has agreed to provide partner jurisdictions with more time to implement information exchange systems. Today, the Treasury Department and the Internal… – Continue reading

What NRI investors need to take note of in the latest IRS Notice

There are many Non-Resident Indians (NRIs) from the US that are fearful of being involuntary discovered through the impending Foreign Account Tax Compliance Act (FATCA) disclosures of their Indian accounts by their foreign banks. The US Internal Revenue Service has issued a notice extending the time under which certain transitional… – Continue reading

Your taxes: Info exchange inner workings

The OECD Common Reporting Standard (CRS) and FATCA in the United States are long-winded. So the OECD published on August 7 a much shorter and lighter guide: the “Common Reporting Standard Implementation Handbook” (the CRS Handbook). The CRS and FATCA represent a sweeping change toward automatic information exchange and away… – Continue reading

U.S. Tax Reform update: amid looming budget showdown, drafting of U.S. International Tax Reform Legislation continues

With the August recess now well in the rearview mirror, Congress is already deep into grappling with the imminent expiration of the U.S. Government’s funding authority on September 30. Amid the debates over the “Continuing Resolution” and related funding issues, the Iran deal, and other high-profile issues, the work on… – Continue reading

New global tax crackdown could impact asset owners

A new wave of global tax compliance regulation is a game changer in the way asset owners and investment management companies report activities. Globalization of financial markets has made it increasingly simple to make, hold and manage investments outside an asset owner’s own tax domicile. A standard on automatic exchange… – Continue reading

EXCLUSIVE | Cabinet ministers met publicly with KPMG while firm’s tax ‘sham’ under CRA probe

Accounting firm joined revenue minister at speech while fighting court order Top Conservative cabinet ministers met publicly with senior staff from KPMG’s tax division, and one went so far as to promote the firm, even as the Canada Revenue Agency was alleging the company set up an offshore tax “sham”… – Continue reading

Luxembourg: Luxembourg Leads On FATCA Transparency

The Grand Duchy of Luxembourg is ranked third in the world for the number of financial institutions per-country that have now signed up to report under the Foreign Account Tax Compliance Act (FATCA). IRS figures report 8,525 Luxembourg firms have registered with the FATCA portal, and the total is surpassed… – Continue reading

Davis homes in on offshore tax evasion

High-net-worth, tax-evading South Africans will soon have nowhere to hide, because in future income tax returns will specifically ask them to declare if they have offshore trusts, or directly or indirectly control an offshore trust, Judge Dennis Davis, the convener of the Davis Tax Committee, says. If the South African… – Continue reading

Commentary: The View from Europe: Little time left to act on US tax bill

The Caribbean has just 18 congressional working days from Sunday September 20 to try to have the US Congress or the District of Colombia address an act naming 17 Caribbean nations as “tax havens”. If passed without amendment it could have the effect of reputationally damaging the countries concerned with… – Continue reading

AFTER 5-YEAR-LONG TAX AUDIT, COCA-COLA OWES THE IRS AN EXTRA $3.3 BLN

On Friday, Coca-Cola Co. said that it may owe the IRS an extra $3.3 billion in federal income taxes. According to the company, the Internal Revenue Service found after a five-year-long audit that the soft drink giant may owe the federal government $3.3 billion along with interest for the 2007… – Continue reading

The NZ registered financial service provider that tells potential clients of NZ bankrupts ‘who still live in mansions & drive Ferraris owned by their trusts’

A small office shared with three other companies deep in the bowels of the Outsource IT Tower on Auckland’s Khyber Pass Road opposite a reservoir isn’t necessarily where you’d expect to find the global headquarters of a financial service provider that claims to be following in the footsteps of three… – Continue reading

Corning Inc. overseas profits become campaign issue

CORNING — Corning Inc.’s handling of profits it earns overseas has quickly become an issue in the 2016 presidential campaign. The Fortune 500 company’s refusal to bring back to the U.S. more than $12.4 billion in overseas profits first drew criticism from U.S. Sen. Bernie Sanders, an independent from Vermont…. – Continue reading

Automatic Exchange of Financial Account Information (including US FATCA)

HMRC has today published new draft guidance notes to cover the automatic exchange of financial account information under the International Tax Compliance Regulations 2015 (SI 2015 No. 878) (the Regulations), which were made in the spring. The main document is a new draft HMRC guidance manual covering the Regulations. The… – Continue reading

Mexico Legislating On CbC Reporting Requirement

The 2016 Mexican Economic Package includes a proposal for country-by-country (CbC) reporting of tax information by certain multinational corporations. The Package, which was submitted to Congress by the Government on September 8, 2015, seeks to bring Mexican transfer pricing documentation rules into line with the Organisation for Economic Co-operation and… – Continue reading

U.S. tax-evasion probe expands to Belize

U.S. authorities have targeted Belize-based banks in a new expansion of their hunt for Americans suspected of evading taxes by hiding income and assets in offshore accounts. A federal court in Miami on Wednesday approved special “John Doe” legal summonses seeking information about U.S. taxpayers who may hold undeclared accounts… – Continue reading

Dr. Douglas: FATCA Of Great Importance To St. Kitts And Nevis

“I want to commend the government for bringing this bill to parliament,” said Opposition Leader Hon. Dr. Denzil Douglas said today of the government tabled Foreign Account Tax Compliance Act (USA) (Implementation and Enforcement) Bill 2015. During his presentation on the bill’s debate in the National Assembly today (Sept 15),… – Continue reading

American Dream Relocates to Bermuda, Says Fishman, Blaming Taxes

Jay Fishman, who built New York-based Travelers Cos. into one of the world’s biggest insurers, lamented that disparities in tax rates are pushing established rivals and industry newcomers outside the U.S. Over the past 15 years or so, “we’ve counted 10, 12, maybe even 15 Bermuda-based startups that ultimately became… – Continue reading

Chevron tax filings challenged by US tax authorities, report says

Chevron’s tax filings face repeated challenges from the United States and other global tax authorities, according to a new union-backed report that calls on world governments to crack down on the energy giant’s alleged profit-shifting tactics. The world’s largest trade union body, the International Trade Union Confederation (ITUC), has called… – Continue reading

Worldwide: Structured Finance: FATCA And The OECD Common Reporting Standard

More than 90 jurisdictions, including all 34 member countries of the Organisation for Economic Co-operation and Development (“OECD”) and the G20 members, have committed to implement the Common Reporting Standard for automatic exchange of tax information (“CRS”). Building on the model created by FATCA, the CRS creates a global standard… – Continue reading

British Expats Face FATCA Account Closures

Banks are threatening to close accounts of British expats living in the USA if they fail to complete piles of paperwork to comply with the Foreign Account Tax Compliance Act (FATCA). Millions of US expats worldwide are already caught by the law which requires foreign financial institutions to supply details… – Continue reading

HK Report Suggests Tax Incentives For Booking Centers

Hong Kong’s Financial Services Development Council (FSDC) has released a report setting out recommendations on policies, including tax measures, to enhance the city’s role as a regional and global financial booking center. Financial institutions utilize such centers to enter into contracts for financial products, undertake primary obligations for delivery or… – Continue reading

“United States: New Jersey Tax Court Finds Royalty Company Must File And Pay Even Though Related Entity Paid Tax On Same Income “

In a decision released August 14, the Tax Court of New Jersey ruled that an intangible holding company with no physical presence was required to file a New Jersey corporation business tax (CBT) return and pay the related tax due based on its income.1 No relief was available to the… – Continue reading

Court ruling allows transfer of Canadian tax info to U.S. to begin under FATCA

A federal court judge dismissed an attempt to put an early stop to a controversial program in which the Canadian government agreed to share financial information of an estimated one million “U.S. persons” living in Canada with the Internal Revenue Service. Particularly troubling to some opponents is that the agreement… – Continue reading

Airbnb v. Uber: Sharing economy gets a mixed reception in Costa Rica

The night that Uber started offering its ride-hailing service in Costa Rica, vandals – reportedly taxi drivers – smashed the windows of one of the company’s cars in protest. Traffic police impounded two Uber vehicles earlier that same night. Airbnb, however, another staple of the so-called “sharing economy,” has been… – Continue reading

Malta – the optimum choice for private equity

Malta provides an outstanding opportunity for private equity and venture capital managers. It has a flexible LP structure, an extensive network of double tax treaties, a favourable local tax regime and experienced service providers who can provide a cost-effective solution,” comments Felicity Cole (pictured), Head of the Funds Department at… – Continue reading

MALAYSIA: GUIDANCE FOR FATCA COMPLIANCE

The Inland Revenue Board of Malaysia in September 2015 issued guidance concerning the requirements for compliance with an intergovernmental agreement (IGA) to implement the FATCA regime. The FATCA guidance notes provide guidelines and practical information for Malaysian-based financial institutions, businesses, their advisers, and officials dealing with application of the FATCA… – Continue reading

Allegations surround Wilson Security’s link to HK bribes scandal and tax haven

Exclusive: company faces renewed questions over its fitness as security contractor at Australian detention centres on Manus Island and Nauru Wilson Security faces renewed questions about its fitness as security contractor in Australia’s offshore detention centres in light of its corporate links to a tax haven, a corruption scandal that… – Continue reading