Category: North America

January Global Tax-News Update

This edition of the Tax-News monthly feature takes in noteworthy events in the international tax arena, including attempts to inject new life into the campaign for comprehensive tax reform in the United States, and developments in the areas of free trade, indirect taxation, BEPS and tax transparency and compliance. US… – Continue reading

How to navigate Obama’s new tax proposals if you own property in the U.S.

While President Barack Obama’s new tax proposals may never see the light of day, given the Republican majorities in both the House and Senate, they have generated discussion among cross-border tax practitioners. Dual citizens living in Canada or Canadians who own U.S. properties may wonder whether they need to reopen… – Continue reading

Unravelling of $10 billion stuck in tax disputes windfall for US

BENGALURU: US President Barack Obama’s visit to India could help unlock over $10 billion stuck in tax disputes between India and various countries. The move will largely benefit American technology companies as a big chunk of the disputes involve software development and IT-enabled services (ITeS) sectors. India’s competent authority Akhilesh… – Continue reading

Agreement delivers new protocol to Switzerland-Italy tax treaty

A year in review: the far reach of the IRS in Canada – Foreign Account Tax Compliance Act What is FATCA? The Foreign Account Tax Compliance Act1 (“FATCA”) was enacted by the United States Congress in order to deal with non-compliance by US taxpayers using foreign bank accounts. FATCA requires… – Continue reading

Unravelling of $10 billion stuck in tax disputes windfall for US

BENGALURU: US President Barack Obama’s visit to India could help unlock over $10 billion stuck in tax disputes between India and various countries. The move will largely benefit American technology companies as a big chunk of the disputes involve software development and IT-enabled services (ITeS) sectors. India’s competent authority Akhilesh… – Continue reading

U.S. Senate’s Hatch sees support for tax reform

(Reuters) – The U.S. Senate’s top tax law writer sounded determined on Friday about pursuing comprehensive tax reform, though this is viewed as unlikely by most analysts. “Though there are disagreements on the details, there is bipartisan support for tax reform in Congress,” said Orrin Hatch, Republican chairman of the… – Continue reading

Tax cafe: The FATCA conundrum deepens for India

The Foreign Account Tax Compliance Act (FATCA) is a new chapter in the US Internal Revenue Code. Chapter 4 was added by the Hiring Incentives to Restore Employment (HIRE) Act. It seeks to identify US taxpayers having accounts at foreign financial institutions (FFIs) and attempts to enforce reporting of those… – Continue reading

IRS Warms Public to be Aware of Tax Scams

It’s income tax season and many people are working to prepare their tax returns but the IRS is warning people to beware of tax scammers. Although tax scams happen year round, they tend to occur more often during tax season. That’s why, around this this time each year, the IRS… – Continue reading

Keen interest in DTA with Israel

NEGOTIATING A DOUBLE  Taxation Agreement (DTA) with Israel was a major talking point when that country’s Ambassador to Barbados, Mordehai Bivas, paid a courtesy call on Minister of Foreign Affairs and Foreign Trade, Senator Maxine McClean at her Culloden Road headquarters. Senator McClean told the Ambassador: “One of the things… – Continue reading

Techie fee thorn in US ties

New Delhi, Jan. 23: India and the US have failed to make much progress in the totalisation pact that addresses the the problem of the double payment of social security taxes by Indian software professionals in America, dampening expectations surrounding President Barack Obama’s visit this weekend. Top officials said discussions… – Continue reading

Corporate Tax Deal to be Signed With U.S.

India has worked out a bilateral tax agreement with the United States, which could be signed during U.S. President Barack Obama’s visit, that would boost foreign investment and ease investors’ concerns raised by high profile cases against Vodafone and Shell. The pact, which industry executives say would specifically target the… – Continue reading

Luxembourg: Tough times for a favorite tax haven

Luxembourg’s business-friendly tax laws have saved companies billions. The party’s almost over. On a typical day, thousands of passengers pull into Luxembourg’s central train station and traverse the busy shopping street of Rue de la Gare, where everything from pastries to rain boots is on offer. Few, however, step inside… – Continue reading

US tech giants launch fierce fightback against global tax avoidance crackdown

Lobby groups representing Google, Amazon and other powerful US tech multinationals have launched a fierce attack on global plans to stamp out artificial corporate structures used to avoid tax. In responses to the latest stage of a two-year, G20-led programme of international tax reform, lobbyists for the US tech industry… – Continue reading

Vizor Simplifies FATCA and AEOI Reporting Obligations for Tax Authorities

Leading regulatory supervision software provider adds new features to provide a robust, future-proof FATCA & AEOI system. Ottawa, Canada (PRWEB) January 22, 2015 Vizor, the leading regulatory supervision software provider, today introduced new features that help Tax Authorities meet their Foreign Account Tax Compliance Act (FATCA) obligations as well as… – Continue reading

New CBSA transfer pricing policy creates opportunities and obligations for importers

Transfer pricing has been a favorite Canada Border Services Agency (CBSA) enforcement target for some time now. Payments made by importers because of income tax transfer pricing requirements can trigger obligations and liabilities under Canadian customs laws. This arises, for example, when CBSA seeks to assess duties and taxes on… – Continue reading

Cayman Islands: FATCA: International Tax Compliance Implications For PRC And Hong Kong

The US Foreign Account Tax Compliance Act (FATCA) is in the vanguard of a global movement towards the automatic exchange of information on tax matters. The US enacted FATCA in 2010 to tackle the problem of tax evasion by US citizens and residents who under-report or fail to report income… – Continue reading

Obama in India: India, US finalise framework to resolve transfer pricing cases

NEW DELHI: India and the US have finalised a framework to resolve transfer pricing cases, some of them pending for five years, in what could end tax trauma for more than 50 American MNCs such as Microsoft, IBM and Oracle by the fiscal year-end and send a strong signal to… – Continue reading

Adobe Products’ Acrobatic Tax-Dodging Skills

Despite its throwback name, Adobe Products is a cutting-edge technology company whose products—notably, PDF files—are used by millions of Americans every day. As it turns out, Adobe’s tax-avoidance technology is pretty 21st-century too. The company’s newest annual financial report, released earlier this week, discloses that Adobe is currently holding more… – Continue reading

Obama IRS Shares Private Financial Data With Foreign Tyrants

To comply with unconstitutional pseudo-treaties negotiated by the Obama administration without the consent of Congress or any semblance of constitutional authority, the IRS announced that it will be sharing private financial information on U.S. bank account holders with foreign powers. No warrant is needed for foreign governments or tyrants to… – Continue reading

The World Wide Tax Web: FATCA Data Sharing Goes Online

The IRS has unveiled a secure web application, the International Data Exchange Service (IDES), for cross-border data sharing. IDES will allow Foreign Financial Institutions (FFIs) and tax authorities from other countries to transmit financial data on U.S. taxpayers’ accounts, via an encrypted pathway, to the IRS. The tool is part… – Continue reading

Year in Review: Legislation and Guidance for Financial Institutions in 2014

2014 was a year replete with new legislative and regulatory initiatives impacting federally regulated financial institutions. The key initiatives introduced or implemented in 2014 are outlined in our annual year in review. PRUDENTIAL REGULATION: GUIDANCE FROM OSFI Proposed New Bail-in Regime for Large Banks On August 1, 2014, the Government… – Continue reading

Putin Uses Tax Reform To Coerce Oligarchs Into Repatriating Assets

President Vladimir Putin is pushing harder on Russia’s richest citizens to repatriate offshore assets amid a slump in the ruble and the imposition of sanctions by the US and the European Union, The Business Times said. Under new tax rules signed into law by a presidential decree in November, Russian… – Continue reading

Canada: Towards A Global FATCA?: OECD, G20 Unanimously Endorse Global Automatic Information Exchange

On October 29, 2014, through the OECD “Global Forum on Transparency and Exchange of Information for Tax Purposes,” both the OECD and G20 countries endorsed a new Standard for Automatic Exchange of Financial Account Information in Tax Matter. 59 countries are so-called “early adopters” and are committed to undertaking their… – Continue reading

IRS Form W-9 Year 2015

A person who is required to file an information return with the IRS must obtain your correct taxpayer identification number (TIN) to report, for example, income paid to you, payments made to you in settlement of payment card and third party network transactions, real estate transactions, mortgage interest you paid,… – Continue reading

Investments outside of Canada? CRA’s offshore compliance division issues letter to select taxpayers

In December 2014, the Canada Revenue Agency (CRA) issued a letter to a sample of taxpayers to remind them of the criteria for filing a T1135-Foreign Income Verification Statement and to review their income tax filings to ensure they have been properly reporting the relevant assets and income. All Canadian… – Continue reading

Hillary Clinton Raises Eyebrows Speaking To Bank Under Investigation For Offshore Tax Evasion

Hillary Clinton will give two speeches Wednesday in Canada and is co-hosted by the Canadian Imperial Bank of Commerce. The bank has recently come under investigation from the United States for helping wealthy Americans offshore money in the bank’s Caribbean accounts to avoid paying federal taxes. The Elizabeth Warren-supporting wing… – Continue reading

New Brief: Representative John Delaney’s New Proposal Lets Corporations Off Easy

On Dec. 12, 2014, Rep. John Delaney (D-MD) proposed a new version of his “repatriation holiday” tax plan. The latest version would require multinational corporations to pay a token amount of taxes on their accumulated offshore profits and exempt those profits from any further U.S. income tax. Delaney’s new plan… – Continue reading

Costa Rica submits to money laundering probe by Latin America task force

Costa Rica’s going under the magnifying glass for the next two weeks as international money laundering experts comb through the country’s books. President Luis Guillermo Solís declared the audit from the Financial Action Task Force of Latin America (GAFILAT) a subject of national interest in Monday’s edition of the official… – Continue reading

Trust Protectors

Over the past few years, Canadian courts have started taking note of the existence of trust protectors. Despite comments from a certain Saskatchewan judge in 2009 (“As indicated, the term “trust protector” is foreign to me…”[1]), recognition of trust protectors as a legitimate party to a trust may be on… – Continue reading

Swiss Banker Convicted in WikiLeaks Trial Is Spared Prison

(Bloomberg)– A Swiss banker who faced more than three years in prison for providing WikiLeaks with confidential details of his former employer’s offshore activities walked out of a Zurich courtroom a free man on Monday. Rudolf Elmer, 59, was given a suspended fine of 16,800 Swiss francs ($19,397) for violating Swiss… – Continue reading

Dems ready new push on offshore tax deals

Congressional Democrats are preparing new efforts to curb the offshore tax deals that drew the ire of President Obama last year. Senate Minority Whip Dick Durbin (D-Ill.), Sen. Jack Reed (D-R.I.), Rep. Sandy Levin (D-Mich.) and Rep. Lloyd Doggett (D-Texas) will introduce legislation on Tuesday seeking to stop the maneuver… – Continue reading

Cayman Islands: Caribbean IFCs: Well Regulated Parts Of The International Furniture

Observers of offshore financial centres will know that post 2008 they have been weathering a perfect storm. Firstly, reduced transactional flows, simply because there is less money available for structured finance and investment generally. Secondly, a constant barrage of negative publicity, which deliberately seeks to conflate tax evasion and tax… – Continue reading

Canadian Importers May Now Seek Import Duty Refunds

Since the introduction of the Transaction Value System of customs valuation by Canada on January 1, 1985, the Canada Border Services Agency (CBSA) has maintained a stated policy of denying refund claims of related party importers who seek to amend declared values for duty to account for adjustments that decrease… – Continue reading

Asia’s richest to cling onto wealth for longer

Asia’s ultra-high-net-worth-individuals (UHNWIs) are expected to hang onto their wealth for longer, as succession planning becomes an increasingly pertinent issue among this investor demographic elsewhere in the world. According to a new report by consultancy Wealth-X, around US$16 trillion of global UHNWI wealth is expected to be handed over to… – Continue reading

2015 legislative and regulatory agenda is a mixed bag

No issue dominates this year’s legislative and regulatory agenda of the risk management and property/casualty insurance community as reauthorization of the federal terrorism insurance backstop did even several weeks ago. Extension of the program, which lapsed several days before Congress reinstated it in early January, united the industry around a… – Continue reading

U.S. and China Team Up to Launch Global Tax System

In the world of offshore asset protection and personal finance, you regularly come across the claim that there are only two countries that actively tax their residents’ worldwide income: the United States and Eritrea. All other countries only tax income earned at home. That’s apparently no longer true. It turns… – Continue reading

European Commission lays bare Amazon tax deal with Luxembourg

High quality global journalism requires investment. Please share this article with others using the link below, do not cut & paste the article. Luxembourg’s unorthodox tax deal with Amazon was laid bare by European Commission investigators on Friday, who believe it artificially lowered and “capped” the online retailer’s tax bill,… – Continue reading