To check black money generation, the government today approved signing and ratification of the agreement between India and Seychelles for exchange of information with respect to taxes, reports the Economic Times. The agreement will stimulate the information exchange between India and Seychelles for tax purposes, which will help curb tax… – Continue reading
The Treasury Department today updated its FATCA webpage to report the signing of an intergovernmental agreement (IGA) between the United States and St. Vincent and the Grenadines The IGA [PDF 278 KB] signed between the United States and St. Vincent and the Grenadines is dated as having been signed on… – Continue reading
Amit Ramnani, director of Ipanema Wealth, an independent financial consultancy firm, discusses the key issues facing U.S. expatriates. RIO DE JANEIRO, BRAZIL – Many United States citizens living overseas are unaware of the potential tax liabilities they could be facing in near future. To help out the Rio-based firm Ipanema… – Continue reading
Banks overseas, spooked by India’s stringent new black money law, are asking tough questions of people and entities from the country looking to open accounts with them, reports the Economic Times. That’s because it’s not just those who possess unaccounted wealth who will get punished, those found guilty of helping… – Continue reading
American residents or nationals, citizens and green card holders – persons of interest – living in Jamaica are required to file US tax returns and must, by voluntary disclosure, fill out a form to disclose ‘foreign assets’. The filing of a Foreign Bank and Financial Accounts Report (FBAR) is an… – Continue reading
Aug. 19 — Tax authorities and practitioners around the world are awaiting a Canadian court’s ruling on the legality of Canada’s legislation to comply with the Foreign Account Tax Compliance Act. The Federal Court of Canada is due to issue by Sept. 30 a ruling on the validity of the… – Continue reading
South African companies who do direct and indirect business with US organisations, whether in South Africa, Africa, Europe or further afield, must comply with the United States Foreign Account Tax and Compliance Act (FATCA,) or risk being excluded from lucrative markets the world over, reports the Cape Business News. This… – Continue reading
The IRS on 12 August 2015 released a revenue procedure—Rev. Proc. 2015-41—providing guidance and updated procedures regarding advance pricing agreements (APAs). Rev. Proc. 2015-41 addresses the process of how to request and obtain an APA from the IRS’s Advance Pricing and Mutual Agreement (APMA) program and with respect to the… – Continue reading
On August 17th, 2015, Ruling No. 1,580/2015 was published, containing amendments to Ruling No. 1,571/2015 concerning the “e-Financeira”, which is the tax return to be filed for the purpose of informing financial transactions of interest to the Federal Revenue Office. The deadline for filing the e-Financeira, in relation to triggering… – Continue reading
The IRS on 12 August 2015 released Rev. Proc. 2015-40 with respect to requesting competent authority (CA) assistance, and it is generally effective for CA requests filed on or after 30 October 2015. Rev. Proc. 2015-40 updates and supersedes Rev. Proc. 2006-54. The IRS concurrently released Rev. Proc. 2015-41 as… – Continue reading
In late July 2015, Treasury provided an initial notification of “more favorable terms” concerning “certain alternative procedures” under the Model 1 IGA. This notification has been updated, 18 August 2015. Read the updated Treasury notification [PDF 70 KB]
FATCA was enacted into law by section 501(a) of the Hiring Incentives to Restore Employments (HIRE) Act 2010 as a revenue offset to help pay for the continuation of unemployment benefits for workers laid off during the 2008-2010 financial crisis. In July 2008, the U.S. Senate Permanent Subcommittee on Investigations… – Continue reading
THE START OF THE implementation of the Foreign Account Tax Compliant Act on July 1, 2014, combined with the Organisation for Economic Cooperation and Development’s (OECD) adoption of the common reporting standard, the support by the European Union of the automatic exchange of information (AEI), and the strong support by… – Continue reading
Due to a little-noticed provision in the new highway appropriations bill signed into law on July 31 – the Surface Transportation and Veterans Health Care Choice Improvement Act of 2015 – the deadline for filing an FBAR (Report of Financial Bank and Financial Accounts) has been moved up from June… – Continue reading
(CS) German financial institution HSH Nordbank reportedly reached a 22-million-euro settlement with prosecutors in Cologne over setting up offshore companies through Luxembourg to hide client assets from tax authorities. Newspaper “Süddeutsche Zeitung” and broadcasters NDR and WDR first reported on the deal on Tuesday. Allegedly, HSH Nordbank approached the prosecutor’s… – Continue reading
Subsidiaries in Luxembourg of food group had no staff and assets at year’s end of €1.3bn In its 2014 accounts Glanbia Luxfin, a subsidiary of Irish food group Glanbia, reported profits of $14.2 million and tax of $4,175, while Glanbia Luxinvest reported profits of €2.9 million and tax of €38,863…. – Continue reading
South Africans with undisclosed offshore accounts may feel exposed after their offshore Swiss bank account information found its way into the public domain this year. The theft of information relating to some 30 000 HSBC accounts – the biggest banking leak in history – actually took place five years ago… – Continue reading
In May of 2012, and soon before Facebook’s IPO, Eduardo Saverin renounced his U.S. citizenship. Saverin was a co-founder of the social-networking site, and the consensus was that he gave up his citizenship to avoid U.S. taxes that would be levied after the offering. Saverin was widely denounced for his… – Continue reading
In its Resolution of March 25, 2015, on the Annual Tax Report (2014/2114(INI)), the European Parliament renewed its commitment to combating tax havens and tax avoidance. To be sure, most aspects of the resolution have been discussed before. Bundling these aspects into one comprehensive package, however, provides an intriguing snapshot… – Continue reading
Financial Services Minister Hope Strachan said yesterday that the landscape of the country’s financial services industry would be strengthened as a result of the nation’s compliance with the tax information exchange agreements such as the US Foreign Account Tax Compliance Act (FATCA), saying that she was fairly satisfied that The… – Continue reading
Recently, there’s been a lot of news about the difficulties that 2 banks in Belize have been having after their correspondent banking relationship was severed by the Bank of America. The Prime Minister has commented that it’s a situation that is lamentable, but inevitable. Not surprisingly, Opposition Leader Francis Fonseca… – Continue reading
Questions over tax — hotly denied — feature in a row centring on one of the capital’s biggest art collectors One of London’s wealthiest but most secretive families is locked in a bitter feud over the ownership of its empire, which spans high-end London properties to African tobacco-trading businesses. A… – Continue reading
The following article by Dr Monica Galea John, partner in the Financial Services Department, analyses the manner in which the Fourth EU Anti Money Laundering Directive (the “Directive“) which has just made its way through the EU’s legislation, obliges, for the first time, EU member states to maintain central registers… – Continue reading
In DIT vs. M/s. Lufthansa Cargo India: TS- 299-HC-2015, the Delhi High Court held that payment made by assessee (an Indian company) to German company for carrying out overhaul repairs to aircrafts was fees for technical services (“FTS”) under section 9(1)(vii) of the Income Tax Act, 1961 (“the IT Act”)… – Continue reading
The private equity industry has long been known for its ability to take advantage of tax rules. But international changes are set to have an impact on their businesses. After a string of multinationals such as Apple, Google and Starbucks came under fire for paying minimal tax on their British… – Continue reading
There have not been too many applicants in the first month seeking to avail of the three-month long compliance window being offered by the government to come clean on unaccounted money in foreign shores, Justice (retd) MB Shah, who is heading the Special Investigation Team (SIT) on black money told… – Continue reading
The Tax Department of Cyprus has annouced that the FATCA reporting deadline has been moved to 31 August 2015 (from 14 August 2015). The FATCA Agreement between Cyprus and the United States was signed on 2 December 2014. FATCA seeks to obtain information on accounts held by U.S. taxpayers in… – Continue reading
FEEDBACK FROM MY LAST ARTICLE, From The Frying Pan, was encouraging. Our past Prime Minister Errol Barrow asked us, “What is your mirror image of yourselves”. A searching question. Our response to FATCA can throw some light on the matter. Encouraged by the USA, the UK, and soon others, are… – Continue reading
New data from Juniper Research has found that more than one in 10 adults worldwide will engage in some form of mobile or online gambling by 2019, with nearly half of adults in UK and Italian markets playing by that time. While to some extent the finding can be attributed… – Continue reading
Large South Korean companies have sent more than $400 billion to offshore tax havens over the past eight years, with nearly 40 percent of the amount yet to be returned home, data showed Sunday. According to the data by the Bank of Korea and other government agencies, local big firms… – Continue reading
Americans who believe the region is a safe tax haven to hide money and investments overseas should think twice as Caribbean trade bloc countries are moving to full comply with a new U.S. law designed to catch tax dodgers who stash assets in foreign destinations. The Foreign Account Tax Compliance… – Continue reading
The Organisation for Economic Cooperation and Development (OECD) said in a recent report that improving taxpayer services, while making non-compliance harder, is helping revenue bodies increase their efficiency and allowing governments to finance important programs that will further benefit their citizens. According to Tax Administration 2015, which looks at 56… – Continue reading
Introduction In 1934 distinguished US jurist Judge Learned Hand famously opined that “one may so arrange his affairs so that his taxes shall be as low as possible; he is not bound to choose that pattern which will best pay the Treasury; there is not even a patriotic duty to… – Continue reading
Artisan goods marketplace Etsy Inc., which promised to be a beacon for transparency as a public company, recently implemented a strategy that shrouds its offshore tax-cutting arrangements in secrecy. Because of a change in how its Irish subsidiary is registered, Etsy no longer needs to publicly disclose basic financial information… – Continue reading
Yet another American company has announced its intention to carry out a corporate inversion, a fancy term for buying a smaller company, completing some paper work and, for tax purposes, declaring its new headquarters are in a foreign nation. This time it’s Terex, a Connecticut-based heavy equipment and crane manufacturer,… – Continue reading
U.S. COMPANIES HOLDING CASH ABROAD WAITING FOR TAX REFORM. The high U.S. tax rate continues to encourage companies to stash cash and profits offshore while executives wait for tax reform. The Street has an interview with computing giant Cisco’s CFO Kelly Kramer on the company’s plans for more the more… – Continue reading
Revenue authorities need to be “vigilant” in monitoring the super-rich, according to research that called on many of them to improve their scrutiny of their richest taxpayers, reports the Financial Times. The study by the Paris-based OECD is a further sign of the pressure on tax departments to squeeze more… – Continue reading
As the Islamic financial industry continues to experience exponential growth, offshore financial centres (OFCs) are keen to market their value for the development of Islamic financial products. OFCs are working towards establishing comprehensive eco-systems to gain competitive advantages over other jurisdictions for Islamic finance. Most OFCs promote the element of… – Continue reading
On August 11, 2015, the Organisation for Economic Co-operation and Development (OECD) released its annual report addressing global tax administration. The OECD’s stated mission is to “promote policies that will improve the economic and social well-being of people around the world.” The OECD describes its annual report as follows: Tax… – Continue reading
The first reporting cycle for the United States Foreign Account Tax Compliance Act (FATCA) kicked off with the 31 March deadline set by the US Internal Revenue Service’s (IRS) for countries and territories such as Hong Kong that have a Model 2 Intergovernmental Agreement (IGA). Although the IRS has granted… – Continue reading
The nonprofit Korean American National Coordinating Council has provided support to U.S. citizens for travel to Pyongyang. NEW YORK, Aug. 13 (UPI) — A Korean American organization that previously has helped Americans travel to North Korea is under investigation for tax evasion and political activities that violate U.S. tax laws…. – Continue reading
The rise of Islamic finance and sukuk issuances have brought with it a growing phenomenon: Shariah banking is increasingly taking advantage of offshore banking jurisdictions, and this for a number of reasons, reports the Gulf Times. Many offshore centres around the world meanwhile offer a wide range of features allowing… – Continue reading
A CAMPAIGN questioning the “fairness” of land ownership launched across Scotland yesterday. Our Land is a month-long initiative created by Common Weal, Women for Independence and land reform campaigners Andy Wightman and Lesley Riddoch and aims to highlight problems caused by a land ownership system that “allows a handful of… – Continue reading
A good test of a fair and just law is that the people who have to comply consider the rules fair and just. Now and then a law sparks controversy and one such law is the US Foreign Account Tax Compliance Act (FATCA). Five years after the law hit the… – Continue reading
The IRS today released two revenue procedures that that provide guidance regarding the advance pricing agreement (APA) program, and that offer guidance on the process for taxpayers to request and obtain the assistance of the U.S. Competent Authority under the U.S. network of income tax treaties. Rev. Proc. 2015-41 [PDF… – Continue reading
Excerpt from “FATCA in Canada: The Restriction on the Class of Entities Subject to FATCA” first published by the Canadian Tax Foundation in (2014) 62:3 Canadian Tax Journal by Roy Berg and Paul Barba. This article provides an introduction to the Foreign Account Tax Compliance Act (FATCA) for Canadians and… – Continue reading
Switzerland and Belize signed a tax information exchange agreement (TIEA) on August 10, 2015. The agreement is Switzerland’s ninth TIEA. It provides for the exchange of information upon request. It covers Swiss federal, cantonal, and communal taxes on income and capital, and the cantonal and communal inheritance and gift taxes…. – Continue reading
FATCA refers to provisions contained in the Hiring Incentives to Restore Employment Act (the ‘HIRE’ Act) signed into law on 18 March 2010 in the United States. The main purpose of FATCA is to identify and gather information on US persons who may be evading tax through the use of… – Continue reading
Only 23 percent of business leaders feel that recommendations from the OECD on base erosion and profit shifting will be successfully implemented, according to the findings of a new survey by Grant Thornton. Three quarters of business leaders would pay more taxes in exchange for greater clarity from authorities on… – Continue reading
Many tax practitioners will meet holders of foreign accounts who have either deliberately or unintentionally failed to accurately report their foreign accounts and will need to advise them on the best way to make the disclosure to the Internal Revenue Service. Due to the fact that many U.S. taxpayers have… – Continue reading
