Category: North America

Private bank M&A inevitable amid pressures: analyst

Consolidation in Europe’s private-banking industry is inevitable as pressure from clients and regulators increases costs, McKinsey & Co said in a study published yesterday. Pressures on profit margins could force private banks to cut costs and review the number of booking centers they operate, the New York-based consultancy said. The… – Continue reading

Meg Whitman: HP will offshore 60% of the jobs in its ‘essential’ business unit

Hewlett-Packard will offshore 60% of its workers at its consulting unit, HP Enterprise Services, CEO Meg Whitman told investors Tuesday during the company’s annual analyst meeting. In 2013, 36% of ES workers were in low-cost offshore locations like Manila, Philippines; Costa Rica; and Bangalore, India. By 2018, 60% of them… – Continue reading

High U.S. Tax Rates Force American Companies to Flee Overseas

The largest producer of nitrogen-based fertilizer in the United States, CF Industries, is considering merging with a Dutch competitor and moving its headquarters overseas to avoid the “double taxation” of profits earned by overseas subsidiaries going to the domestic company. Curtis Dubay, a tax and economic research fellow with The… – Continue reading

Tax-Qualified Retirement Plans: Special Rules Apply to Withholding on Distributions to Non-Resident Aliens

Administrators of tax-qualified retirement plans (or their delegated payor) are responsible for both withholding on distributions and for reporting the tax withheld. If taxes are under-withheld, the administrator/delegated payor may be subject to penalties. Although the rules governing withholding on distributions to US citizens and resident aliens are clear and… – Continue reading

FATCA Bill Causes Heated Debate in Parliament

(ZIZ News) — Tuesday’s sitting of the National Assembly featured heated debates on the Foreign Account Tax Compliance (United States of America) (Implementation and Enforcement of InterGovernmental Agreement) Bill 2015. Prime Minister, Hon. Dr. Timothy Harris, who sought leave to have the bill read a first and second time, was… – Continue reading

Brazil’s BTG Open to More Swiss Private-Banking Acquisitions

(Bloomberg) — Grupo BTG Pactual, the only publicly traded investment bank in Brazil, said it’s willing to consider more acquisitions in Switzerland after completing the purchase of BSI, the Swiss private-banking unit of Assicurazioni Generali SpA. “We are looking. We are always looking,” Renato Cohn, a BTG partner and member… – Continue reading

Interactive map of the swathes of England owned by offshore tax-dodgers

Whole regions of England are now owned by holding companies in tax-havens “from Panama to Luxembourg, and from Liechtenstein to the South Pacific island of Niue.” Private Eye’s interactive map mines Land Registry information to find the properties owned by “companies, arms dealers, oligarchs, money launderers and others who use… – Continue reading

‘Tax Avoider’ Google Should Be Banned From Canadian Leaders’ Debate: Group

Google’s CEO may be “proud” of the way his company avoids taxes, but a Canadian tax watchdog group thinks the tech giant’s tax practices should disqualify it from partnering in a Canadian election debate. The Globe and Mail is hosting a leaders’ debate on the economy Thursday night in partnership… – Continue reading

Bank La Roche & Co AG Reaches Resolution Under US Justice Department’s Swiss Bank

The Department of Justice announced today that Bank La Roche & Co AG has reached a resolution under the department’s Swiss Bank Program. “Today’s agreement is yet another example of a foreign financial institution coming forward, acknowledging its criminal conduct, taking the necessary steps to resolve its criminal exposure, cooperating… – Continue reading

IRS Offshore Account Penalties Expand, More Banks Sign

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

EU blacklists Hong Kong as ‘non-cooperative tax jurisdiction’

Kenneth Leung (PC,F-Accountancy) explains what he – and the government – are doing to get Hong Kong off the EU’s undeserved blacklisting as a “non-cooperative tax jurisdiction”. Why has Hong Kong been placed on this list? There are ten European countries that have named Hong Kong as a tax haven…. – Continue reading

Corruption in China: This will blow your mind

Is Xi Jinping (習近平)’s anti-corruption campaign crushing it or embarrassingly ineffective? You make the call. It was widely reported the year before Xi assumed office that upwards of 18,000 corrupt officials had fled China since 1990 with about US$120 billion. In early 2012, the Ministry of Supervision released figures saying… – Continue reading

Europe moves towards a more transparent tax regime

Note: This article was published by Bloomberg BNA in Tax Planning International European Tax Service Vol. 17 No. 7 July 2015 Introduction The recent LuxLeaks scandal has once again focused political attention on tax planning practices of multinationals (“MNEs”). It comes in the wake of the European Commission investigation of… – Continue reading

Democrats Urge US Treasury Action On Inversions

Seven leading Democrat lawmakers wrote a letter on September 12 to US Treasury Secretary Jack Lew urging him to publish an annual list of companies that have undertaken corporate tax inversions, and to use the Administration’s executive authority further to discourage the use of inversion techniques. Tax inversion techniques are… – Continue reading

Cyprus: Foreign Account Tax Compliance Act (FATCA) – The Decree In Accordance With The Assessment And Collection Of Taxes Law

The decree of 2015 in accordance with the Assessment and Collection of Taxes Law (Exchange of Information within the framework of the Agreement for the Foreign Account Tax Compliance Act) has been issued and published in the official Gazette of the Republic of Cyprus dated 28th August 2015 (Decree 281/2015)… – Continue reading

The Advantages of Enacting a Patent Box Regime

Many countries have enacted a patent box regime in order to spur innovation and create domestic manufacturing jobs. Simply stated, a patent box regime provides a lower tax rate on income from the exploitation of patented goods than for other income. Among the countries that have patent box regimes are… – Continue reading

Not international business as usual

BARBADOS’ OFFSHORE FINANCIAL SERVICES SECTOR is again under threat. The Organisation for Economic Cooperation and Development (OECD), G20 and the European Union (EU) are acting in concert, armed with the Foreign Account Tax Compliance Act (FATCA) and the Common Reporting Standard (CRS). Once implemented, the confidentiality which once protected financial… – Continue reading

Vietnam-US double taxation avoidance will bring more gains than losses

With the agreement with the US, Vietnam has now signed the double taxation avoidance agreements with 70 out of 170 countries and territories with which Vietnam has trade and investment relations. Double taxation is considered a barrier to trade and investment. It discourages transnational investments while prompts individuals and businesses… – Continue reading

PANAMA: UPDATE ON FATCA

Panama in May 2014 indicated its intentions to enter into an intergovernmental agreement (IGA) with the United States, for purposes of implementing the FATCA regime. The Panama agreement would follow the Model 1 IGA. As of early September 2015, Panama has yet to sign the IGA. In preparing for implementation… – Continue reading

U.S. companies given Export-Import Bank subsidies keep profits offshore, skirt taxes

Budgeting battle But like much of the budgeting in Washington, D.C., it gets complicated. The Congressional Budget Office contends the Ex-Im Bank’s surpluses are the result of the accounting method the bank uses and would disappear — or require a taxpayer subsidy — if the bank used a more appropriate… – Continue reading

Tax evader crackdown could reduce offshore banking options for expats

An initiative intended to catch tax dodgers could have a negative impact on those with perfectly legitimate bank accounts. Tax expert Howard Bilton offers advice The draconian Foreign Account Tax Compliance Act (FATCA), introduced by the US Government to tackle tax evasion by its citizens, has already affected Britons living… – Continue reading

Private banking: Singapore, Indonesia in private banking tug-of-war

Indonesians hold $300 billion in Singapore; controversial tax amnesty on the cards. Indonesia’s finance minister Bambang Brodjonegoro told Euromoney earlier this year that tax collection falls way short of targets and must improve to provide funding for infrastructure and other projects It doesn’t take much for Indonesia’s government officials to… – Continue reading

INDIA: FATCA GUIDANCE NOTES

India’s Ministry of Finance, Department of Revenue (Foreign Tax and Tax Research Division) on 31 August 2015 released guidance notes with respect to implementation of the reporting requirements under rules 114F to 114H of the Income tax rules. Rules 114F to 114H implement the intergovernmental agreement (IGA) between India and… – Continue reading

TIGTA report recommends improvements to verify taxpayer claims for social security tax exemption under Totalization Agreements

In a July 17, 2015 report released today, the Treasury Inspector General for Tax Administration (TIGTA) recommended that the IRS coordinate with the Social Security Administration to identify U.S. citizens and resident aliens working in a foreign country and resident aliens working in the United States who may have improperly… – Continue reading

Valiant Bank AG Reaches Resolution Under US Justice Department’s Swiss Bank

The Department of Justice announced today that Valiant Bank AG has reached a resolution under the department’s Swiss Bank Program. “Offshore enforcement remains a top priority of the department, and banks seeking to avoid prosecution pursuant to the terms of the Swiss Bank Program continue to accept responsibility, provide a… – Continue reading

RBS sells corporate loan commitments portfolio

LONDON–Royal Bank of Scotland Group PLC (RBS.LN) has sold a portfolio of corporate-loan commitments related to its banking business in China for 498 million pounds ($755.1 million), as part of the bank’s strategy to focus mainly on U.K. and European customers. RBS said it has reached an agreement with China… – Continue reading

Underground Economics Korea’s Underground Economy Places 6th among OECD Member Countries

Policies are urgently needed for the legalization of the underground economy,” said Representative Oh Je-se of the New Politics Alliance for Democracy, who belongs to the Planning and Financial Committee of the National Assembly on Sept. 10. Rep. Oh added that Korea places sixth among OECD member countries in terms… – Continue reading

The Case For A Territorial Tax Regime For Curaçao

Recently the Curaçao Minister of Justice, Mr. Nelson Navarro, approved the so-called Investor’s Permit to accommodate bonafide high net worth persons and entrepreneurs who seek admission to Curaçao. The purpose of the Investor’s Permit is for the investor to provide real economic benefit to Curaçao by increasing employment opportunities and… – Continue reading

Sebi asks market entities to follow I-T Department norms for FATCA

NEW DELHI: To ensure compliance with FATCA — the new US law to check offshore tax evasion — regulator Sebi today asked all market intermediaries to follow reporting requirements prescribed by Income Tax Department in this regard. Under Foreign Account Tax Compliance Act (FATCA), foreign financial institutions that fail to… – Continue reading

Land owned by companies based in tax havens revealed

LAND including Riverside Retail Park, the Cockhedge Centre and the former site of Mr. Smith’s is owned by companies based in offshore tax havens it has been revealed. Companies are often based offshore to gain from three tax loopholes, including no capital gains tax, no inheritance tax and no stamp… – Continue reading

Private Eye reveals £20m of Cumbrian land and property bought by offshore firms

MORE than £20 million of prime Cumbrian land and property was bought by offshore firms between 2005 and 2014, according to Private Eye magazine. Properties purchased by offshore companies in Cumbria in the last ten years range from prestigious country estates to a hotel and a nursing home. The countries… – Continue reading

Another FC Barcelona Star Could Face Tax Evasion Charges Despite Paying Up

Superstar-laden FC Barcelona might be among the top teams in the Spanish Liga BBVA this season but the team is making news – again – for a more undesirable reason: tax investigations. As Lionel Messi awaits trial on tax evasion charges, another Barcelona star may be joining him. Spanish news… – Continue reading

How to Navigate the Law When Doing Business in Canada

Individuals and business wishing to establish a business in Canada need to familiarize themselves with the laws concerning forms of organization, FDI, competition, taxation, labor, privacy, the environment, and more. Canada has weathered the recent period of international uncertainty and volatility better than most other advanced industrialized nations. It is… – Continue reading

Another four tax information exchange agreements now in force

Bern, 09.09.2015 – The tax information exchange agreements with Andorra, Greenland, San Marino and the Seychelles have come into force. They will apply from 1 January 2016. Following the completion of the corresponding ratification processes, the tax information exchange agreements (TIEA) have come into force with Andorra (27 July 2015),… – Continue reading

Treasury prods firms to fight tax provision

The Treasury Department has pushed American-based corporations to lobby against a tax provision prized by their foreign counterparts, according to people who have heard the pitch. One senior Treasury official in particular, Danielle Rolfes, urged domestic companies to more aggressively target an incentive for interest expensing during a March tax… – Continue reading

KPMG offshore ‘sham’ deceived tax authorities, CRA alleges

A wealthy Victoria, B.C., family paid virtually no tax over a span of eight years – and even obtained federal and provincial tax credits – while being involved in an offshore tax “sham” developed by one of the country’s most respected accounting firms, the Canada Revenue Agency alleges. The Canada… – Continue reading

The New Money-Laundering Sting: Come to the U.S., Get Arrested

Lawyer Patrick Poulin says he helped clients set up offshore corporations in the Caribbean. And that’s what he was working on when he flew to Miami from the Turks and Caicos last year to meet with two Americans who wanted him to invest $2 million from a real estate deal…. – Continue reading