An appeals court ruled Wednesday that Lone Star Funds should pay some 64.8 billion won ($58 million) in a corporate tax refund suit filed by the U.S. buyout fund against a regional tax office. The Yeoksam Tax Office levied some 104 billion won in corporate tax on Lone Star over… – Continue reading
Fortescue Metals Group established a company in Singapore that could buy and sell its iron ore more than a year before it started attacking its rivals for doing the same thing. The company, called Fortescue International Marketing, is incorporated and domiciled in Singapore. Still dormant, it is ready to be… – Continue reading
There has recently been a wave of global regulatory reforms which affect fundraising. These changes are far-reaching and can impact how fund managers structure funds, their proposed investor base, how and where funds are marketed, the remuneration that may be received, registrations that may be required and dealings with investors…. – Continue reading
It’s been called mysterious, secretive, and shadowy, but when it comes to the so-called shell company created by former president Bill Clinton as a vehicle for the delivery of consulting services, there’s a whole lot less there than meets the eye. According to the Associated Press, in 2008, Clinton set… – Continue reading
The U.S. is examining banks’ conduct as part of a wide-ranging corruption probe of international soccer that has led to charges against 14 people, including officials with the sport’s organizing body. Money involved in the two-decade-old bribery scheme passed through U.S. banks including Citigroup Inc. and JPMorgan Chase & Co.,… – Continue reading
Investments Derived From Structural Reforms The approved structural Reforms are an unprecedented opportunity for a transformational economic growth in Mexico, being the most relevant from an investment point of view the reforms related to Energy, Telecommunications and Antitrust, which have put Mexico in the radar of Multinational companies seeking to… – Continue reading
Switzerland and the European Union have signed an agreement providing for the automatic exchange of banking information, effective 2018. On Wednesday, Swiss State Secretary for International Financial Matters Jacques de Watteville signed the accord in Brussels along with EU Tax Commissioner Pierre Moscovici and Latvian Finance Minister Janis Reirs. Before… – Continue reading
Perhaps the most quoted dictum from any tax case comes from Judge Learned Hand of the United States Court of Appeals for the Second Circuit in the 1934 case of Evelyn Gregory against Guy T. Helvering (then the commissioner of the I.R.S.): Any one may so arrange his affairs that… – Continue reading
Former Prime Minister Tigran Sargsyan, who is currently Armenia’s ambassador to the United States, has filed a lawsuit against former businessman Paylak Hayrapetyan with a demand that he refute the “libelous information” spread about him and pay 1 million AMD (about $2,100) in compensation for moral damages. Sargsyan demands Hayrapetyan,… – Continue reading
The countries of the Central American region have incorporated and reformed their legislations to the international regulations of Transfer prices and practically all the applicable legal provisions to related parties have already been expanded in the region, which implies, that the companies with regional presence must visualize, review and engage… – Continue reading
The first fiscal amendment of the Juan Carlos Varela government was passed earlier this month on May 4, by Law 27 of 2015. Here are two important pointers of the fiscal reform: 1. TAXABLE INCOME PRODUCED IN PANAMA Article 694 of the CF originally included as taxable income the income… – Continue reading
Many states in our nation suffer the effects of over-taxation. Whether it’s high state income taxes pushing families to seek brighter economic climates or high corporate taxes compelling businesses to relocate their headquarters, taxes play a huge role in how state economies function. One of the most contentious and potentially… – Continue reading
The news that Royal Bank of Canada plans to sell its wealth management services in Barbados no doubt caused some people to question the island’s future as a major centre for this type of business. After all, if the biggest player is leaving the field, what might this say to… – Continue reading
As another season of summer travel starts, Canadian residents with US ties should make sure they are thinking carefully about their tax obligations. Tax compliance may not be first in the minds of most people planning trips to the US, but Congress and the Obama administration certainly are thinking about… – Continue reading
Six of the biggest names in global finance shelled out billions of dollars Wednesday to settle charges of rigging currency markets, but liberal lawmakers complain the government is just doling out slaps on the wrist. On Wednesday, the Justice Department announced a settlement that also saw five banks plead guilty… – Continue reading
Reporting Australian Financial Institutions must report to the Australian Taxation Office by 31 July 2015 on their U.S. accounts or recalcitrant accounts. These financial institutions must have undertaken the prescribed due diligence procedures required under the IGA. Who must report? It is critical that you determine whether you are a… – Continue reading
On May 20, 2015, the US Department of the Treasury released for public comment draft updates to the US Model Income Tax Convention, including provisions to deny treaty benefits to companies that change their tax residence via inversion transactions. The Treasury said other changes are intended to ensure that the… – Continue reading
Switzerland has begun online publication of names of foreigners and foreign firms wanted in tax probes by their countries of origin, including Germany. American citizens are identified only by their initials. The Swiss Sunday newspaper “Sonntagszeitung” said the alpine nation was flooded with formal tracing requests from foreign tax authorities…. – Continue reading
Baku, Fineko/abc.az. Foreign investors may not fear the U.S. sanctions on FATCA during operations on the Azerbaijani stock market. Director of local investment company PSG¬Broker Matanat Iskenderova has stated that the stock market of Azerbaijan is fully compliant with the standards in the field of counteraction to money¬laundering. “Likewise, it… – Continue reading
Switzerland has begun revealing alleged foreign tax dodgers that are wanted by tax authorities in their native countries, Swiss newspaper Sonntagszeitung reported. MOSCOW (Sputnik) – Names, birth dates and nationalities of people suspected by their countries of origin to have stashed money in the alpine tax haven are being published… – Continue reading
In November 2013 the governments of the Cayman Islands and the British Virgin Islands (“BVI”) entered into intergovernmental agreements with the United Kingdom (“UK IGAs”) which contained provisions for the establishment of a framework for the reporting of financial account information. That framework is similar in scope to the framework… – Continue reading
The Serenissima : Foreign Secretary replied to the interpellation submitted by Lazzari and Pedini Amati / FATCA, Valentini: “It is not to be considered as a tax shelter” / Agreement “virtually in place since July 2014”, the signature will come after the ok from Use “FATCA is not an instrument… – Continue reading
America the not so brave CRACKING down on tax evasion “has been a core piece of President Obama’s agenda” since before he took office, according to a spokesman. His administration’s campaign to that end has been a “groundbreaking” success, according to the Department of Justice, the agency that has led… – Continue reading
The Foreign Account Tax Compliance Act (FATCA) – a law passed in 2010 to tackle the abuse of using offshore financial accounts for the purpose of evading US taxes – is now in effect after a two-year delay. As it requires foreign financial institutions worldwide to identify and report to… – Continue reading
The head of a US technology firm that yesterday announced 100 new jobs in the Republic has rejected the “misperception” that Ireland is deemed a tax haven in the US. Qualtrics chief executive Ryan Smith said his firm’s decision to expand its Dublin headquarters was not influenced by the Irish… – Continue reading
Change to the Procedural Requirements at the Bank of Israel The Bank of Israel has recently implemented measures that are designed to minimize legal and reputational risks for Israeli banks. The Bank of Israel circulated a draft directive for all Israeli banks by virtue of which all foreign (non-Israeli resident)… – Continue reading
Hanocal Holdings, a Dutch subsidiary of the Abu Dhabi-based International Petroleum Investment Company, has filed a lawsuit against the South Korean government through the World Bank’s International Center for Settlement of Investment Disputes. This is the second time that Korea is facing international arbitration under the “investor-state dispute settlement” process…. – Continue reading
The Armenian National Committee of America has welcomed the signing of the US-Armenia Trade and Investment Framework Agreement (TIFA) but has said that a renegotiated double tax agreement is a priority in order to fully realize the two nations’ bilateral trade and investment potential, reports Tax News. The TIFA was… – Continue reading
Located along the Northeast corridor of the United States, Rhode Island is a mere 180 miles from New York City. The small coastal state is known for its knowledge economy based on its elite universities and hospitals. In 2013, Rhode Island’s GDP was US$53.2 billion. The largest contributor to the… – Continue reading
To staff their board of directors with the best and most diverse talent, multinational companies commonly elect boards with international representation. It is also common for companies to convene periodic board meetings outside the United States. This may be done, for example, to provide board members with an opportunity to… – Continue reading
It has become a $2 trillion question. Why don’t companies have to make clear exactly how much of their profits are generated offshore each year and not taxed in this country? Why must investors engage in jujitsu to estimate these figures and the risks associated with them? Companies, like individuals,… – Continue reading
Tax Information Exchange Agreement Signed On 19 May 2015, Switzerland and Grenada signed a Tax Information Exchange Agreement. Each country shall notify the other, in writing, of the completion of the procedures required by its law for the bringing into force of the Agreement. The Agreement shall enter into force… – Continue reading
The Treasury Department announced draft changes for the U.S. Model Income Tax Treaty — the baseline text used by the Treasury Department when it negotiates tax treaties. The current U.S. Model was last updated in 2006. The proposed changes in the draft provisions are intended to combat so-called Base Erosion… – Continue reading
The Cayman Islands Department of International Tax Cooperation has extended the deadlines for Cayman Reporting Financial Institutions (RFIs) to provide notification and reporting and to the Tax Information Authority for U.S. FATCA Reportable Accounts. RFIs now have until Friday, May 29, 2015 to submit notifications. The new reporting deadline is… – Continue reading
The Inland Revenue Board (IRB) has informed Malaysian financial institutions (MYFIs) that their filing deadline in respect of the 2014 reporting year under the US Foreign Account Tax Compliance Act (FATCA) has been deferred from June 30, 2015. FATCA requires all FIs outside the United States to submit regular information… – Continue reading
A US criminal investigation into how Swiss banks such as Julius Baer allegedly helped wealthy Americans to hide their money is likely to stretch into next year, the US ambassador to Switzerland signalled in a newspaper interview, reports Reuters. The criminal probe into a handful of banks has paved the… – Continue reading
Canada’s health-care stocks are sizzling, as Concordia Healthcare Corp. and Valeant Pharmaceuticals International Inc.’s buy-and-streamline strategy has pushed the industry’s earnings and margins ahead of U.S. peers. The drugmakers are the two top-performing stocks in the Canadian equity benchmark this year, boosting total returns for the members of the Standard… – Continue reading
NUMBER OF THE WEEK: 40 percent. The average combined federal and state tax rate paid by most U.S.-based firms, according to a Wall Street Journal op-ed by James Freeman today, entitled “The Tax Takeover Craze.” Freeman claims this is “roughly double the average in Europe and Asia,” and is the… – Continue reading
It is quite clear that the more recent past has seen a notable shift in the debate from various supranational initiatives implemented over the years, designed to curtail the activities of smaller offshore financial centres, towards the real issues of tax transparency, regulatory cooperation and managing systemic risk in the… – Continue reading
Bankrupt ex-billionaire Samuel Wyly won a judge’s approval to sell his family’s Colorado ranch, the site of six custom-built homes. The bankruptcy judge in Dallas Wednesday also said Wyly could provide a loan to pay for the ranch’s upkeep before it’s sold. The property will be listed for $50 million,… – Continue reading
By stopping bogus claims of residency, his idea would force foreigners to pay capital gains tax when they sell a home in Canada OTTAWA — Inspired by the legendary FBI ploy to nab a notorious gangster, a B.C. immigration lawyer suggests the Canadian tax system be used to discourage the… – Continue reading
At a time when traders who bet on deals are constantly being thrown curve balls, more bad news: Yahoo! Inc.’s plan to make them rich may be getting derailed. The stock plummeted as much as 12 percent near the end of Tuesday’s trading session because the U.S. Internal Revenue Service… – Continue reading
Experts say Panama’s new reforms will help fight money laundering. Panama’s Congress on April 22 unanimously approved anti-money laundering legislation that will bolster supervision of non-financial sectors through which proceeds from drug trafficking and other illicit activities have been laundered in recent years. To what extent will the reforms, a… – Continue reading
IRS Rules That Policyholder Owns Mutual Fund Shares Under Nonqualified Deferred Annuity Contract The IRS ruled in Private Letter Ruling 201519001 on the tax treatment of a nonqualified deferred annuity contract issued by a life insurance company, finding that public mutual fund shares under the contract will be treated as… – Continue reading
On May 8, 2015, the United States Department of Justice announced that it had entered into a “non-prosecution agreement” (NPA) with Swiss bank Vadian Bank AG under the Department of Justice’s (DOJ) Swiss bank program. In its press release announcing the NPA, the DOJ said, “the department has opened investigations… – Continue reading
Three years after a major restructuring of the business, general insurer AIG Jamaica is moving its operations offshore but will continue to write business for clients here. AIG Jamaica Insurance Company Limited was formerly Chartis Jamaica Insurance Company Limited, which was created in 2012 when sister company American Home Assurance… – Continue reading
INTRODUCTION On May 5, 2015 the Swiss Federal Supreme Court held a public hearing about two cases relating to the reclaim of Swiss withholding tax (WHT) in connection with arbitrage cases and issued its long awaited decisions. Two Danish banks issued the question on treaty entitlement for the refund of… – Continue reading
A proposal to bar insurers from claiming a tax deduction for premiums ceded to offshore affiliates would cost the U.S. economy $1.35 billion in gross domestic product, with private sector losses estimated to run roughly four times as great as the tax revenues raised, according to a new report from… – Continue reading
During a Cabinet meeting Tuesday, chaired by deputy Prime Minister Choi Kyung-hwan,in his role as acting prime minister, the government passed a revised bill that requires the automatic exchange of financial account information for taxpayers from both countries every year, reports Arirang. The agreement will also ensure confidentiality and the… – Continue reading
International fast-food giant McDonald’s avoided paying half a billion dollars of tax in Australia over a five-year period by shifting profits through the low-tax nation of Singapore, a new report by a global coalition of trade unions says. The report, which has been funded and commissioned by a coalition of… – Continue reading
