There is a saying that you can fool the people sometimes, but you can’t fool the people all the time. People patronising a bank might feel that high science is being practised in the back offices of banks; science beyond the ken of ordinary mortals. Perhaps! Related articles Barbados banks… – Continue reading
After several years of delays, the Foreign Account Tax Compliance Act (FATCA) finally took effect on July 1, 2014. Congress enacted FATCA as part of the Hiring Incentives to Restore Employment Act in 2010 to stop U.S. taxpayers from evading U.S. taxes through undisclosed offshore accounts and investments. FATCA requires… – Continue reading
The US giant trying to take over Britain’s biggest drinks can maker in a £4.3billion deal is a serial user of tax havens. Ball Corporation is in talks to buy FTSE 250-listed Rexam that would create an industry goliath. The deal could be finalised as early as this week, and… – Continue reading
The nation’s largest organization of accounting and tax professionals is urging the Senate to approve income tax treaties between the U.S. and various countries. In a February 3 letter to Senator Bob Corker (R-Tenn.), chairman of the Senate Committee on Foreign Relations and Senator Robert Menendez (D-N.J.), the committee’s ranking… – Continue reading
Guest Post by Andrew Blair-Stanek, Assistant Professor of Law at University of Maryland Carey School of Law Patent owners routinely tell the IRS, under penalties of perjury, that their patents have little value. Litigators representing defendants should take advantage of these remarkable admissions. IP has become the world’s leading tax… – Continue reading
This past December, the Multistate Tax Commission’s (MTC) transfer pricing advisory committee and its project facilitator Dan Bucks recommended what it calls the “preliminary design” approach for a proposed Arm’s Length Adjustment Services (ALAS) program. While still subject to approval, states have already put designs on increasing state transfer pricing… – Continue reading
More than 100 tax disputes involving Indian associates of US companies such as IBM and Microsoft are set to be settled out of court by April this year with the income tax department and the US Internal Revenue Service identifying disputes in the contract research, IT and software sectors for… – Continue reading
As countries share more information, opportunities to squirrel away cash abroad will continue to narrow AMONG the sins that have most angered the austerity-weary everywhere is the use of undeclared offshore accounts to stash the wealth of the rich. Greeks were particularly enraged when data stolen from Swiss banks showed… – Continue reading
A Labour government would push for UK overseas territories to be put on an international blacklist if they refuse to co-operate with a drive against tax avoidance, Ed Miliband has told them. In a letter to their leaders, he said they would have six months to compile a public register… – Continue reading
Feb 7 (Reuters) – A former Swiss banker charged by U.S. prosecutors with helping wealthy Americans evade taxes has been arrested in Germany pending extradition to the United States, his lawyer said on Saturday. Roger Keller, a onetime client adviser in Zurich at Wegelin & Co, was one of three… – Continue reading
This past December, the Multistate Tax Commission’s (MTC) transfer pricing advisory committee and its project facilitator Dan Bucks recommended what it calls the “preliminary design” approach for a proposed Arm’s Length Adjustment Services (ALAS) program. While still subject to approval, states have already put designs on increasing state transfer pricing… – Continue reading
The serious doubts expressed by many, most recently Professor Christians of McGill University, as to the Constitutional authority cited by the US Treasury1 in support of each Inter Governmental Agreement (an “IGA”) entered into by it on behalf of the United States government to implement FATCA have been rendered practically… – Continue reading
A swath of changes to corporation tax in the European Commission’s pipeline topped the Taoiseach’s agenda when he met the president of the European Commission, Jean Claude Juncker officially in Brussels. New rules that would force every country to make public the tax arrangements with larger companies, including multi nationals… – Continue reading
Report skewers PwC for creation of Shire tax shelter it calls ‘tax avoidance on an industrial scale’ Shire’s Ireland address has made the specialty drugmaker a prime takeover target. AbbVie was attracted but dumped the $55 billion buyout when the U.S. Treasury Department threw cold water on the deal with… – Continue reading
Are you confident that your clients will never be sued? And if they are sued, are you certain that they will be treated fairly by the U.S. legal system? People are now being forced to protect themselves and their assets from liabilities that were never a concern in the past. … – Continue reading
Bond trader Ben Eiler swapped life in suburban Georgia for an island in the Caribbean, and he didn’t even have to apply for a visa. The towering 38-year-old native of Arkansas is one of at least 250 people who’ve accepted Puerto Rico’s invitation to well-heeled U.S. citizens to move to… – Continue reading
As middle class flees, Puerto Rico tries luring rich people The towering 38-year-old native of Arkansas is one of at least 250 people who’ve accepted Puerto Rico’s invitation to well-heeled U.S. citizens to move to the island and enjoy life without taxes on capital gains, an enticing offer for those… – Continue reading
Ed Miliband insists no hypocrisy over offshore donation and admits he will ‘probably’ have to pay the Mansion Tax, which affects houses worth more than £2million Ed Miliband has faced allegations of hypocrisy after it emerged that the Labour party has accepted a donation from a company registered in the… – Continue reading
The latest numbers are in and they are impressive. Since 2009, over 50,000 taxpayers with delinquent FBAR forms have come forward. Although many taxpayers are now seeking to take advantage of the IRS’ offshore account amnesty program, the IRS continues to ramp up enforcement efforts against the stragglers that ignore… – Continue reading
The latest numbers are in and they are impressive. Since 2009, over 50,000 taxpayers with delinquent FBAR forms have come forward. Although many taxpayers are now seeking to take advantage of the IRS’ offshore account amnesty program, the IRS continues to ramp up enforcement efforts against the stragglers that ignore… – Continue reading
Details have emerged this week that the company Samantha Cameron – the prime minister’s wife – works for is based in a tax haven. Smythson – a luxury leather goods retailer with a Royal Warrant from the Queen – is owned through a parent company in Luxembourg and connected to… – Continue reading
More than half of Australia’s trade is money being sent offshore by companies to their overseas arms – with almost a third going to Singapore and Switzerland. Australian companies sent more than $100 billion to related parties in the low-tax nation of Singapore and another $15.6 billion to “hubs” in… – Continue reading
MUMBAI: The Mumbai bench of the tax tribunal has clarified that additional tax liability cannot be claimed from competitive industries in the name of location savings arising out of the country’s low-cost manufacturing base. The ruling may benefit pharmaceutical, auto, IT and IT-enabled companies, among others, that are engaged in… – Continue reading
February 4: The Luxembourg tax authorities this week released a draft version of a new administrative circular for implementing the FATCA regime. The new draft guidance concerns the file format to be used for the automatic exchange of information between the Grand-Duchy of Luxembourg and the United States.
Google has told the Australian parliament that it would prefer issues around taxation of multinational corporations to be dealt with by the G20 or the Organisation for Economic Co-operation and Development (OECD), rather than have individual countries attempt to go it alone. The Australian government is attempting to tackle profit… – Continue reading
Jersey’s financial institutions are now able to register in Jersey in preparation for US FATCA, which commences this year. The Foreign Account Tax Compliance Act (FATCA) requires financial institutions outside the USA to report information on financial accounts held by their US customers to the Internal Revenue Service (IRS). A… – Continue reading
(Reuters) – U.S. federal prosecutors have launched a new probe into whether Swiss bank UBS AG helped Americans evade taxes through investments banned in the United States, the Wall Street Journal reported, citing people familiar with the investigation. UBS, which paid $780 million in 2009 to settle a separate Justice… – Continue reading
The US Internal Revenue Service (IRS) has clarified that a foreign financial institution must obtain a customer’s self-certification details when opening a new account, in a new addition to its Frequently Asked Questions on its Foreign Account Tax Compliance Act (FATCA) website. The IRS was asked: If a Reporting Model… – Continue reading
The US government is scrutinising UAE expats’ bank accounts in a bid to clamp down on tax evasion. Strict new rules that came into effect last year mean US expats who have retained dual nationality, and Gulf-based nationals born in the US or to an American parent, could be US… – Continue reading
On February 2, the Obama Administration released its fiscal year 2016 budget (FY 2016 Budget). The hallmarks of the FY 2016 Budget are proposals that would impose (i) a minimum tax on the current foreign earnings of U.S. corporations and their controlled foreign corporations (CFCs) and (ii) a one-time 14%… – Continue reading
HONG KONG — China’s tax officials plan to step up efforts to collect taxes from multinational corporations in the latest of a series of moves in the last year, mostly against Western companies. The activities have included police raids on the headquarters of companies’ China operations and heavy fines under… – Continue reading
New Delhi, Feb. 4: The notification of a social security deal with Norway – often called totalisation agreements — may pave the way for a similar pact with the US that has been hanging fire for a decade. Under the pact, employees sent by Indian firms to Norway on a… – Continue reading
Negotiations over the India-United States nuclear deal continued until “Air Force One landed in Delhi” carrying President Barack Obama. According to sources, the nuclear deal and other agreements announced during Mr. Obama’s visit to India for Republic Day were being finalised right down to the moment his plane touched down…. – Continue reading
The European Commission has turned a blind eye to secretive tax deals that Ireland and other countries have been doing with multinationals for decades. Only after complaints from the US did it launch investigations into the most high-profile cases — Apple in Ireland, Starbucks in the Netherlands, and Amazon in… – Continue reading
Some 776 American citizens or long-time residents renounced their status in the third quarter of 2014, according to the Treasury Department. If that trend continues, the U.S. will see more than 3,000 renunciations this year-a record. Why are so many Americans forfeiting their citizenship? In 2010, Congress passed the Foreign… – Continue reading
NEWS: Spain’s Foreign Minister said “it was fine” for Fabian Picardo to speak in Madrid: “as long as no one forces me to listen”. The Chief Minister was introduced by the British Ambassador. In a breakfast speech in central Madrid to a room filled with some 250 politicians, businessmen, diplomats… – Continue reading
Time is ticking for India to sign its inter-governmental agreement (IGA) with the US under the Foreign Account Tax Compliance Act (FATCA) after it received a one month extension on the original December 31 deadline. President Obama’s visit to India last week fuelled speculation that the IGA could be signed… – Continue reading
The Internal Revenue Service (IRS) has released revised versions of its Tax Guide for Aliens, providing guidance for resident and nonresident aliens for use in preparing their 2014 tax returns, and of its Tax Guide for Individuals Receiving Income from the United States Possessions – American Samoa, Puerto Rico, the… – Continue reading
Law360, New York (February 03, 2015, 10:22 PM ET) — Casino operator Caesars Entertainment Corp. has created a new anti-money laundering position in the wake of federal inquiries into its practices, hiring away a top compliance expert from Wal-Mart Stores Inc., according to a spokesman. Former Wal-Mart compliance expert Ben… – Continue reading
The IRS has one foot in the 21st century, and the other in the days of Camelot. The majority of taxpayers can file their federal income tax returns online. And those eager to see how soon they’ll get their refunds can even use the IRS’s mobile app. But thanks to… – Continue reading
The ARIA Investment Platform has launched a range of portfolio strategies on its investment platform aimed at US Investors caught by increasingly tough legislation. The Cautious Income Balanced and Adventurous Strategies are advised by Parala Capital, based on its Parala Macro Multi-Asset Allocation strategies, and are available on the ARIA… – Continue reading
On 30 January 2015 the Legislative Council passed certain changes to the Mandatory Provident Fund Schemes Ordinance (“MPFSO”). Such changes, when they come into force, will enable the withdrawal of benefits on the terminal illness of an employee, and also enable a phased withdrawal of accrued benefits. In addition, the… – Continue reading
Many wealthy foreigners considering their options for investment, permanent residency or citizenship in the US are concerned about the US tax policy. Many have heard of the US income tax on worldwide income, but in reality, astute advisors can mitigate or eliminate the additional expense. US Freedom Capital, the premier… – Continue reading
The National Taxpayer Advocate Nina Olson is a strong and vocal advocate for taxpayer rights. Her annual report to Congress castigates the IRS for its unfair application of offshore account penalties, and its disparate treatment of innocent Americans caught in reporting snafus. Some of the report asks the IRS to… – Continue reading
GCC nationals with dual citizenship face IRS efforts to collect income tax from non-residents Thousands of Gulf States nationals could be US tax evaders and not even know it. According to Italian-Swiss lawyer Giovanni Rossi who works for a law firm handling many of similar cases, the number could reach… – Continue reading
Eleventh-hour legislation in December kept many tax breaks alive for the 2014 tax year, but they weren’t extended beyond that. (See chart on page 26.) So clients who want to take advantage of those breaks need to get with a knowledgeable practitioner—and quickly. “CPA firms nationwide face a staffing challenge… – Continue reading
India and US reach common ground on Mutual Agreement Procedure (“MAP)” and break new ground on Advance Pricing Agreements (“APA”) Suchint Majmudar Just ahead of Obama’s momentous R-Day visit to India, the Competent Authorities of India and US reached a landmark breakthrough in cases involving mutual agreement procedure under the… – Continue reading
The IRS issued two New Releases this week that restate its focus on offshore tax evasion. The first was January 29, 2015 which followed the First International Criminal Tax Symposium. “The Internal Revenue Service Criminal Investigation Division (IRS-CI) and Her Majesty’s Revenue & Customs (HMRC) co-hosted a three-day International Criminal… – Continue reading
Critics question whether Galuteria actually lives in Senate District 12, which he has represented since 2008. State Sen. Brickwood Galuteria admitted Monday that he has improperly claimed a rental property in Palolo as his primary residence and will likely have to pay back taxes on the nearly $1.8 million home…. – Continue reading
The Internal Revenue Service announced in January that its International Data Exchange Service (IDES) is open for enrollment, and that financial institutions and host country tax authorities will be able to use IDES to securely send their information reports on financial accounts held by Americans to the IRS under the… – Continue reading
