Category: North America

President Obama’s fiscal year 2016 revenue proposals

SUMMARY On February 2, 2015, the Obama Administration (the “Administration”) released the General Explanations of the Administration’s Fiscal Year 2016 Revenue Proposals (commonly known as the “Green Book”), which contains significant detail about the fiscal year 2016 revenue proposals. This memorandum discusses certain aspects of the Green Book relating to… – Continue reading

London offers world stage and war chest for Republican 2016 hopefuls

Potential candidates can gain foreign experience and donations in the British capital but expatriate supporters want action on Obama’s onerous tax demands Republican donors in the UK are lobbying the presidential hopefuls visiting London in search of foreign policy credentials and wealthy corporate allies to abandon President Barack Obama’s aggressive… – Continue reading

3 IRS Strikes? FATCA, FBARs, An ‘Abode’ In U.S. Although You Live Abroad

With over 7 million Americans living abroad, many have complained about the rigorous IRS enforcement of global tax reporting, the risk of draconian FBAR penalties for reporting foreign accounts, and FATCA discrimination. FATCA, America’s global tax enforcement law, applies virtually everywhere. It is easy for the IRS to find you,… – Continue reading

Obama Wants a New Tax on U.S. Companies’ Overseas Profits

(Bloomberg) — President Barack Obama will propose that U.S.-based companies pay a minimum 19 percent tax on their future foreign earnings, capturing profits that are now often beyond the government’s reach. Obama will also seek a 14 percent mandatory tax on about $2 trillion in stockpiled offshore profits, said two… – Continue reading

23 FDI proposals deferred for possible tax treaty abuse

NEW DELHI: Getting tough with investment proposals from tax heavens, FIPB has deferred 23 applications in its last three meetings apprehending “treaty abuse”. According to sources, the Department of Revenue has expressed doubt that a few foreign companies were evading tax by routing their investments through tax heaven countries with… – Continue reading

HSBC the latest bank to implement FATCA

IRS threatens 30% withholding tax on non-compliant banks Dubai: Many people, including American citizens working in the Gulf state, received recently letters from their UAE-based banks asking them for more details and papers in compliance with American laws introduced by tax service. The move comes as many citizens of the… – Continue reading

Massie: Stop taxing Social Security recipients

NKY congressman says that current system amounts to ‘double taxation’ on people. His bill could save some seniors thousands of dollars. Are you a higher-income Social Security recipient who must pay federal taxes on your benefits? U.S. Rep. Thomas Massie is your friend. Massie, R-Garrison, last week introduced the latest… – Continue reading

Firms prepare for new tax rules as China vows crackdown

Feb 1 (Reuters) – The Chinese government’s vow to increase tax scrutiny of foreign companies has sent firms rushing to tax advisors ahead of the implementation on Sunday of new rules designed to rein in cross-border tax avoidance. Tax professionals and business lobbies alike have welcomed the move as an… – Continue reading

Hunt for black money leads Enforcement Directorate to 10 British Virgin Islands investors

MUMBAI: The hunt for black money stashed abroad is moving beyond Liechtenstein and Switzerland. Over the last fortnight, at least ten individuals — all from Mumbai and holding shares of companies in the Caribbean tax haven British Virgin Islands (BVI) — have been told by the Enforcement Directorate (ED) to… – Continue reading

Offshore Tax Evasion: The IRS & Swiss Banks

LIGHTNING RELEASES (1/30/2015) – Attorney Gary S. Wolfe of The Wolfe Law Group is pleased to announce, after 12 years of research, the publication of his 10th book, Offshore Tax Evasion: The IRS and Swiss Banks, now available for immediate download through the Amazon Kindle store. Switzerland is the epicenter… – Continue reading

The IRS’s Weak Tea

At the US agency responsible for enforcing the Fatca tax withholding reporting law, an apparent lack of frequency in updating GIIN registrations, along with the as-yet-untested launch of its compliance service, reflect poorly on its capabilities I covered Foreign Account Tax Compliance Act (Fatca) developments in this space just two… – Continue reading

FATCA agreement between Curaçao and the U.S. – the data protection and contractual client confidentiality issues

Speed read On 16 December 2014, Curaçao and the U.S. signed an intergovernmental agreement (“Curaçao-IGA”) setting out the information reporting and withholding requirements applicable to banks and other financial institutions resident in Curaçao (“FI’s”) under the Foreign Account Tax Compliance Act (“FATCA”). By virtue of the Curaçao-IGA, FI’s will be… – Continue reading

IRS Announces That More Than 50,000 Have Enrolled In OVDP; Amnesty Program To Remain Open Indefinitely

Yesterday, the Internal Revenue Service unveiled its latest statistics on participation in its Offshore Voluntary Disclosure Program (OVDP), an amnesty program for taxpayers with undisclosed foreign bank accounts that has existed in various forms since 2009.  To date, more than 50,000 taxpayers have made voluntary disclosures regarding offshore bank accounts,… – Continue reading

M&A activity by US multinationals in technology sector likely to increase, says expert

Cash reserves held outside the US for tax reasons by US multinationals are “likely to fuel a big increase in M&A activity over the next year”, said Eloise Walker a tax expert at Pinsent Masons, the law firm behind Out-law.com.30 Jan 2015 Corporate Tax Corporate tax International tax M&A Advanced… – Continue reading

IRS Voluntary Disclosure Regime Expands Maximum Penalty Bracket

The IRS recently announced an expansion of the list of banks and advisors that trigger the highest penalty bracket within its Offshore Voluntary Disclosure Program. The addition of Sovereign Management & Legal, Ltd. and Bank Leumi to the increased penalty list will have repercussions in Asia, Israel and the United… – Continue reading

IRS Targets Banks In FATCA Crackdown

The US Internal Revenue Service (IRS) has posted tax investigators to foreign embassies to lead a Foreign Account Tax Compliance Act (FATCA) crackdown on suspected tax evasion. The Asia Pacific financial centres of Hong and Singapore are two of the main targets, according to industry experts. The move follows claims… – Continue reading

Dominican Republic must soon ease banking secret, Taxman warns

Santo Domingo.- Internal Taxes Agency director Guarocuya Felix on Thursday warned that Dominican Republic must soon dismantle the barriers which limit the automatic access to information of the financial sector’s taxpayers, because despite the Arbitration Court resolution to break banking secrecy when the tax administration so requires, the information doesn’t… – Continue reading

Unfiled FBAR Conviction Against St Louis Man–Report of Foreign Bank and Financial Accounts

The United States Department of Justice secured a conviction against a St. Louis man accused of not reporting foreign bank accounts in Switzerland and Singapore. Raju Mukhi, age 67, was indicted last year on charges of willful failure to file an FBAR and filing false tax returns. Offshore accounts with… – Continue reading

HSBC Still Aiding Tax Fraud Even After Justice Department Settlement: Report

This story has been updated. At her confirmation hearing Wednesday, attorney general-designate Loretta Lynch said she has been “very aggressive” in pursuing white-collar crime. “At the outset, no individual is ‘too big to jail.’ And no one is above the law,” said Lynch. Yet according to a new report from… – Continue reading

London: ‘a global haven for criminal financial activity’

London is a global haven for criminal financial activity – with billions of pounds laundered through British banks each day, according to the head of the UK’s National Crime Agency. “Many hundreds of billions of pounds of criminal money is almost certainly laundered through UK banks and their subsidiaries each… – Continue reading

Important royalty withholding tax decision

Introduction The taxpayer, Seven Network Limited, has won a recent decision (22 December 2014) in the Australian Federal Court, Seven Network Limited v Federal Commissioner of Taxation (2014) FCA1411, which is significant to all broadcasters, particularly involving the delivery of live sport and other entertainment. Briefly, the key issue raised… – Continue reading

IRS and British Tax Agency to Co-Host 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 Tax Symposium in Washington, D.C. January 27 – 29, 2015. The symposium focused on combatting offshore tax evasion and international financial crimes—including cyber-crime—and brought together delegates from criminal tax and… – Continue reading

Transfer Pricing Leaders To Address Latest Trends At Bloomberg BNA-Baker McKenzie Global Conference In Paris March 30-31

ARLINGTON, Va., Jan. 28, 2015 /PRNewswire-USNewswire/ — Bloomberg BNA today announced that its Global Transfer Pricing Conference: Paris, held in conjunction with Baker & McKenzie and in association with the Tax Management Education Institute, will occur on March 30-31 immediately after the Organisation for Economic Co-operation and Development (OECD) Global… – Continue reading

IGA with United States of America under FATCA – Registration

Inter-Governmental Agreement (IGA) with United States of America (US) under Foreign Accounts Tax Compliance Act (FATCA)- Registration Please refer to circular DBR.AML.No.9644/14.07.018/2014-15 dated December 30, 2014, on the captioned subject. 2. In partial modification to the above circular, it is clarified that those RRBs which do not have more than… – Continue reading

Microsoft NZ ownership transferred from US to Luxembourg

Microsoft denies a transfer of ownership of its New Zealand business from the United States to Luxembourg is related to the tiny European state’s favourable tax policies. Luxembourg, which has a population of less than 600,000, has been accused of facilitating large-scale tax avoidance by multinationals. Microsoft New Zealand was… – Continue reading

Bank Negara urged to act on 1MDB funds in Cayman Islands

The existence of 1MDB’s RM7 billion in the Cayman Islands and its return to Malaysia must be verified. KUALA LUMPUR: Pandan MP Rafizi Ramli urged Bank Negara Governor Zeti Akhtar Aziz, in a statement on Wednesday, to invoke the Anti Money Laundering Act and ensure that a reported RM7 billion… – Continue reading

The era of offshore bank secrecy is dead

Almost every day brings new evidence that the era of bank secrecy for tax evaders using Swiss and “offshore” bank accounts in “tax havens” is over. Both tax authorities and banks are clamping down on unreported offshore accounts. Early in 2014, Swiss bank Credit Suisse agreed to pay fines of… – Continue reading

Global Tax Transparency Rising in 2015 As FATCA, OECD Initiatives Gain Momentum

Jan. 23 — The growth of global tax transparency is expected to leap ahead in 2015—meaning companies, individual taxpayers and financial institutions must exercise new levels of caution, practitioners told Bloomberg BNA. With more than 100 intergovernmental agreements under the Foreign Account Tax Compliance Act and dozens of countries signing… – Continue reading

Lionel Messi representative admits depositing cash in Caribbean tax haven

Money from charity games featuring Barça star was sent to Curaçao, Civil Guard says Messi charity games investigated for link to drug traffickers Charity soccer matches organized under the name of Argentinean star Lionel Messi in four countries in 2012 and 2013 raked in hundreds of thousands of euros that… – Continue reading

Congress Should Pass the Stop Tax Haven Abuse Act to Combat International Tax Avoidance

Each year U.S. multinational corporations avoid an astounding $90 billion in corporate income taxes by booking their profits on paper through international tax havens. At a time of growing inequality and budget austerity, it is outrageous that we allow the world’s richest companies to get away with not paying their… – Continue reading

‘The age of financial privacy is over’

Jonathan Weiss hasn’t lived in the US for 25 years. But that didn’t keep his foreign bank account from being frozen in the wake of new US tax laws. Find out how you can avoid the same fate at the hands of FATCA. “I had been living in Switzerland for… – Continue reading

Puerto Rico Expands Tax Haven Deal For Americans To Its Own Emigrants

Puerto Rico’s Acts 20 & 22, tax incentive laws aimed at luring wealthy American investors to move there and at reviving the Island’s economy, are celebrating their third anniversary this month. While Puerto Rico’s economic situation remains bleak (it currently has more than $73 billion of “junk” status debt, unemployment… – Continue reading

Bank Leumi hit by lawsuit from shareholders over U.S. tax settlement

(Reuters) – Shareholders in Israel’s Bank Leumi are seeking to file a class action lawsuit worth about 475 million shekels ($119 million) against the bank over its handling of a U.S. probe into alleged tax evasion, Bank Leumi said on Sunday. Leumi, Israel’s second largest lender, said the lawsuit argues… – Continue reading

Indian MFs’ rising US headache

Fatca registration, which is mandatory, could reveal technical violations of three other American laws, with penal consequences The Foreign Account Tax Compliance Act (Fatca) might be a bigger headache for the Rs 11 lakh-crore-mutual fund (MF) sector than earlier believed. Fatca is an American legislation, under which financial institutions (FI)… – Continue reading