Category: North America

Mexico: International Transactions And Cost-Sharing Limitations In Mexico

International worldwide transactions in Mexico face a weakness as a result of an old and outdated provision which disallows for income tax purposes, the deduction of payments made abroad on a prorated basis with other parties that are not subject to Mexican income tax, such as foreign residents with no… – Continue reading

$1.8 Billion IMF Ukraine Bailout Money Deposited in Ukraine Oligarch Kolomoyskyi’s Cyprus Offshore Bank Account

Funds Discovered in Kolomoyskyi’s Cyprus Kitty Investigative reporters have discovered that IMF bailout funds intended for Ukraine have mysteriously found their way to a Cyprus bank account controlled by notorious Ukrainian oligarch Ihor Kolomoyskyi. A huge chunk of the $17 billion in bailout money the IMF granted to Ukraine in… – Continue reading

Cross-Border M&A Is Hot, but There’s a Trap for Tax Planners: Picking the Wrong Way to Value Intangibles Can Irk Authorities

NEW YORK, NY–(Marketwired – Aug 31, 2015) – Cross-border mergers and acquisitions are at their hottest pace since before the financial crisis. In fact, M&A volume was $1.10 trillion in 2014, up from $775.3 billion in 2013 and the highest since 2008. And intangible assets like intellectual property and goodwill… – Continue reading

CORPORATE CLOSE-UP: LICENSING SUBSIDIARY THAT FELL PREY TO ADDBACK REQUIREMENT MUST ALSO FILE RETURN, NEW JERSEY RULES

Shifting of income between parent and subsidiary companies for the purpose of avoiding taxation has been a consistent concern for state departments of revenue. States have enacted a variety of rules to ensure that the entities involved file and pay taxes accurately. In Spring Licensing Group, Inc. v. New Jersey… – Continue reading

India: FATCA Reporting Deadline Extended

On 25 August 2015, the Indian Ministry of Finance released an order extending the Foreign Account Tax Compliance Act (FATCA) reporting filing deadline for Indian Financial Institutions to 10 September 2015 (from 31 August 2015). The FATCA Agreement between India and the United States was signed on 9 July 2015…. – Continue reading

Taxing multinationals: Patently problematic

Proposals for consistent global rules on company tax cause worries all round CLARITY or chaos? Supporters of the Base Erosion and Profit-Shifting (BEPS) project, being worked on by the OECD, argue that it will bind multinationals to a consistent set of global tax rules, providing them with less licence than… – Continue reading

LB&I: “PRACTICE UNITS” ON FOREIGN-TO-FOREIGN TRANSACTIONS, TRANSFER PRICING RULES

The IRS today publicly released two new “practice units”—i.e., training aids intended to describe for IRS agents leading practices for specific international and transfer pricing issues and transactions—providing overviews of foreign-to-foreign transactions under section 367(b) and the transfer pricing rules under section 482. The two new practice units (release date… – Continue reading

Transfer pricing audits: flipping the tested party

Introduction Transfer pricing methods and tested parties Troubling trend Tools for taxpayers Introduction In some recent transfer pricing audits the Internal Revenue Service (IRS) has ‘flipped the tested party’ after examining transactions between related US and foreign companies. Typically, this practice results in the attribution of a larger portion of… – Continue reading

Leumi Asked to Consider Bonus Clawbacks After U.S. Tax Fine

The Bank of Israel asked Bank Leumi Le-Israel Ltd. to set up an independent committee to examine management performance and bonuses after the lender agreed in December to pay a fine to U.S. authorities in a tax probe. Leumi, Israel’s second-largest lender, agreed the $400 million fine after a seven-year… – Continue reading

Israel Banking Watchdog Says Leumi Execs May Have to Return Bonuses

Regulator demands Bank Leumi investigate top management in wake of U.S. tax-evasion settlement. Bank Leumi should take back bonuses it paid three former senior executives after the lender was forced to pay a huge penalty to the United States for tax violations that occurred under their watch, Banks Supervisor David… – Continue reading

Uncertainty for offshore financial centres?

The Cayman Islands as one of the leading offshore financial centres have a great level of uncertainty in its future with all the recent developments around tax compliance. One looming uncertainty is the European Union’s (EU) Alternative Investment Fund Managers Directive (AIFMD) passport. The AIFMD is one of several measures… – Continue reading

Government decides to revise convention of double taxation

Pakistan has decided to revise obsolete convention of double taxation and provision of fiscal evasion convention with the United State of America (USA) aimed at bringing the treaty at par with neighbouring countries, well informed sources told Business Recorder. Pakistan and US signed a convention on the avoidance of double… – Continue reading

Taiwan, Japan deal on double taxation avoidance close: official

Taipei, Aug. 27 (CNA) Taiwan and Japan have nearly completed negotiations on a bilateral agreement to avoid double taxation, a Taiwanese official said Thursday. The date of its signing is still being discussed, the official said. The negotiations on the agreement have almost been concluded, Chou Shyue-yow (周學佑), deputy director-general… – Continue reading

marcus evans to Host the 4th FATCA and Global Tax Compliance Forum

This Annual Conference Provides Global Tax Compliance Experts With Insight on Adopting an Internationally Accepted Standard of Tax Transparency and Compliance NEW YORK, NY–(Marketwired – August 25, 2015) – marcus evans, the world’s largest event management group, will host the 4th FATCA and Global Tax Compliance Forum on November 4-6,… – Continue reading

US rule to give investment advisers anti-money laundering duty

US fund managers and other investment advisers would have to take steps to combat money laundering and report suspicious transactions to authorities under a long-awaited US Treasury rule proposed on Tuesday, reports Reuters. If made final the proposal by Treasury’s Financial Crimes Enforcement Network (FinCEN) would close a long-standing hole… – Continue reading

Russian “Economic Patriotism” May Shake Things Up For Wealth Managers

New de-offshorization and capital amnesty laws could have widespread effects In an attempt to encourage “economic patriotism,” Russia recently adopted two new laws: (1) The De-Offshorization Law, which makes a number of major changes in the existing systems of corporate and personal taxation in Russia, particularly as they pertain to… – Continue reading

New tax rules could erode financial privacy

Security fears; Global authorities to begin sharing sensitive data If you have a bank account somewhere overseas, that information will make its way back to the Canada Revenue Agency (CRA) in a couple of years. In 2018, international tax authorities will begin automatically sharing financial information under the terms of… – Continue reading

Barclays Pressing Swiss Private Bankers to Double Client Assets

The new head of Barclays Plc’s Swiss unit is pushing private bankers in Geneva and Zurich to double client assets in four years as international competitors exit the world’s largest hub for offshore wealth. James Buchanan-Michaelson, who joined from Coutts International in June, aims to increase Swiss assets, including loans,… – Continue reading

Country-By-Country Reporting: The Transfer Pricing Game-Changer

This month’s feature examines proposals for new tax information reporting requirements for large multinational businesses as part of wider and ongoing changes to the international tax system – proposals which have been described by international tax experts as the most significant development in the field of transfer pricing since TP… – Continue reading

HSBC spills details on 400 Indian accounts in Singapore; half are from Mumbai

After the leak of two major secret documents from HSBC’s Swiss private banking arm that revealed names of roughly 2,000 Indian account holders, the global bank itself has done it now. For the first time ever, HSBC Singapore shared a new list of 1,200 individuals all across the globe of… – Continue reading

Canada: Anti-Avoidance And Intercorporate Dividends: Changes To Section 55 Of The Income Tax Act

The Income Tax Act (ITA) contains many anti-avoidance rules forbidding taxpayers from misusing the provisions of the ITA to achieve tax benefits contrary to Canadian tax policy. The 2015 Federal Budget has proposed changes1 to one of these anti-avoidance rules, which may significantly impact the ability of business owners to… – Continue reading

Hearing Set on Injunction to Stop FATCA Reporting

Aug. 21 — A federal court will hold a hearing Sept. 4 on whether to stop the U.S. from requiring banks in four countries to report information on U.S.-owned accounts under the Foreign Account Tax Compliance Act. As the Sept. 30 deadline for that reporting approaches, the U.S. District Court… – Continue reading

Canada’s dirty money detection system ‘broken all the way through’

Money laundering experts say there is no way for Canadians to know how much dirty money is being laundered in Vancouver real estate through Canadian lawyers. As a Province investigation revealed Monday, Canada’s financial intelligence unit Fintrac has ramped up an audit of Vancouver’s booming property market because of concerns… – Continue reading

India Seeking To Resolve International Tax Disputes

India will soon settle international tax disputes with close to 120 American companies as well as entities from Japan and other such countries, according to the nation’s Revenue Secretary Shaktikanta Das. Earlier this month, India announced a Framework Agreement under the mutual agreement procedure provision of the India-US tax treaty… – Continue reading

Inniss optimistic about Barbados’ removal from blacklist

MINISTER OF INTERNATIONAL Business, Donville Inniss is optimistic that given Barbados’ and Italy’s continued efforts at strengthening bilateral relations, Barbados could soon be removed from Italy’s blacklist. He made this disclosure this morning during his brief remarks at the end of a signing of a Double Taxation Agreement (DTA) between… – Continue reading

REFILE-Swiss law aims to return foreign funds stashed by erstwhile leaders

Aug 24 (Reuters) – Switzerland expects to adopt a new law by the end of the year that will speed restitution of illicit funds stashed in the Alpine country, where thousands of ‘politically exposed persons’ are believed to hold bank accounts, a top Swiss official said on Monday. Swiss authorities… – Continue reading

Real estate bought with offshore cash raises money laundering concerns

Investigator says Canadian real estate market has developed reputation as a place to launder money A report prepared for Canada’s anti-money laundering watchdog points to offshore cash in the real estate sector as a “significant risk” for criminal wrongdoing. The Financial Transactions and Reports Analysis Centre of Canada, commonly known… – Continue reading

HONDURAS MAKES CARLOS SLIM PAY ITS TAX

The multinational companies in Latin America demand security, efficient services, infrastructure and good educational standards, but they are not very willing to contribute themselves by paying their fair share of tax. Honduras is a case in point, and is one of the most unequal countries on the continent. The government,… – Continue reading

Bahamas “largely compliant” says OECD Tax Policy Director

The director of the Organization for Economic Co-operation and Development’s (OECD) Centre for Tax Policy and Administration, Pascal Saint-Amans, has praised The Bahamas for its “tremendous progress” in adopting Foreign Account Tax Compliance Act (FATCA) standards and paving the way for automatic exchange of information between the US and The… – Continue reading

British banks’ offshore banking activities ‘the greatest threat to national solvency’

A new paper shows that British banks engaged in more offshore banking than any other financial centre. Researchers examining the resilience of the world’s financial centres after the global economic crisis conclude that the future stability of the UK is perhaps the most uncertain of all. The paper concludes that… – Continue reading

Proposal to make arbitration mandatory under MAP dropped

India opposed the proposal saying it impinges on the sovereign rights of developing countries in taxation New Delhi: An international proposal to make arbitration mandatory and binding under mutual agreement procedures (MAP) in tax treaties has been dropped after India strongly opposed it. Last year, the Organisation for Economic Co-operation… – Continue reading

Ireland making ‘little or no’ effort to curb corruption – report

Ireland has made “little or no” effort over the past four years to create a corruption-free playing field for global trade, violating its “obligation to combat cross-border bribery”, reports the Irish Times. The Transparency International Exporting Corruption report, released on Thursday, found that Ireland, along with countries such as Russia,… – Continue reading