From Premier International Tax Library With the publication in September of Notice 2014-52, the IRS has made it extremely difficult for any foreign corporation that is not primarily engaged in an active business to acquire a U.S. business in exchange for its stock without risking being transformed into a U.S…. – Continue reading
A delegation from the US Internal Revenue Service (IRS) visited Israel last week to meet representatives of the Israel Tax Authority. Sources inform “Globes” that the purpose of the meeting was to implement the agreement for the exchange of information between Israel and the US concerning the accounts of US… – Continue reading
CRA has launched the Electronic Funds Transfer (EFT) initiative, introduced in the 2013 Budget as one of several new measures to crack down on international tax evasion and aggressive tax avoidance. Read: Top 10 tax changes of 2014 Effective January 1, 2015, certain financial intermediaries, including banks, have to report… – Continue reading
Other bodies announce similar probes; bank agreed to pay $400 million to US he Attorney General’s Office will open an investigation into the Bank Leumi Group, it revealed Thursday, weeks after the bank agreed to pay $400 million to United States and New York authorities for helping American taxpayers hide… – Continue reading
The Attorney General will examine the civil and criminal implications of the bank’s conduct in helping US citizens evade US taxes. Attorney General Yehuda Weinstein is to examine the Bank Leumi (TASE: LUMI) tax evasion affair, in which the Israeli bank helped American customers evade US taxes. Weinstein is consulting… – Continue reading
Many factors influence a foreign buyer’s decision to purchase residential real estate in the United States. Generally, most of these decisions tend to be driven by concerns over political and economic uncertainty in the buyer’s home country. Most foreigners do not leave their home country, family, and friends for trivial… – Continue reading
Countries are competing to lower their tax rates to please the corporate giants, but the result is a massive collective loss of revenue. Only international coordination can wipe out the practice and defeat the negative influence of the Big Four accounting firms. Tax havens have long existed in the popular… – Continue reading
Massive growth in the global foreign currency exchange (forex) markets has attracted the interest of traders and investors alike. With a plethora of currencies available and trade volumes running into the trillions of dollars, forex markets provide a convenient way to take advantage of inherent leverage and volatility, and to… – Continue reading
The 4,029-page tax code is so complex both parties want to revise it. On business tax reform, they share surprising common ground, raising the potential for partial tax reform to be enacted this year. As the 114th Congress convenes this week, it has a golden opportunity to rid itself of… – Continue reading
With particular reference to issues associated with the requirements of the Foreign Account Tax Compliance Act (FATCA), the United States Internal Revenue Service (IRS) has updated Publication 515: The Withholding of Tax on Nonresident Aliens and Foreign Entities. It is specified that the Publication is for withholding agents who pay… – Continue reading
More than 100 countries including India, China and Russia have already entered into agreements with the US on the Foreign Account Tax Compliance Act (FATCA) and with new FATCA requirements coming into effect on 1st of January 2015 applying to U.S. and non-U.S insurers and insurance brokers, large portions of… – Continue reading
SINGAPORE – On December 9, 2014, Singapore became the first country in Southeast Asia to sign an Intergovernmental Agreement (IGA) on tax information sharing with the United States. The signing follows an in substance agreement reached between Singapore and the US in May 2014. Most countries around the world have… – Continue reading
Barbados appears to be moving into full financial information-sharing mode as the world’s most powerful countries put their foot down on tax evasion. It is already known that last November Government signed an Inter Governmental Agreement with the United States (US) to exchange information on their citizens who have thousands… – Continue reading
Data as of a week before deadline The total number of Indian financial institutions who have signed up with the American tax authorities under the Foreign Account Tax Compliance Act (FATCA) was less than 500 as per data from less than a fortnight ago. There were a total of 442… – Continue reading
Due to its geographical proximity to the mainland, modern and (until now) friendly banking system and transparent legal regime, Hong Kong has long served as a popular gateway into China for foreign businesses. Americans in particular have favored the former British colony, which retains its widespread use of the English… – Continue reading
Many registered firms are subsidiaries of the same organisation, so actual number could be much lower than latest available figure of 442 Sachin P Mampatta | Mumbai January 6, 2015 Last Updated at 22:47 IST The picture regarding the number and proportion of Indian financial institutions which had registered with… – Continue reading
What’s coming our with with regards to the Foreign Account Tax Compliance Act (FATCA) in 2015? 2015 sees a number of impeding developments regarding FATCA compliance as the US presses on with its quest to target tax non-compliance by U.S. taxpayers with foreign accounts. Nick Matthews, Global Head of Forensic… – Continue reading
What’s coming our with with regards to the Foreign Account Tax Compliance Act (FATCA) in 2015? 2015 sees a number of impeding developments regarding FATCA compliance as the US presses on with its quest to target tax non-compliance by U.S. taxpayers with foreign accounts. Nick Matthews, Global Head of Forensic… – Continue reading
The IRS released three updated documents through its electronic FATCA news service. Form 1042-S is used to report certain amounts from US sources paid to foreign persons (including persons presumed to be foreign). Form 8938 is used by certain individuals to report specified foreign financial assets if the total value… – Continue reading
Medtronic Inc. took one step closer to becoming an Irish company when shareholders voted in favor of acquiring Dublin-based medical supply maker Covidien Ltd. Covidien shareholders similarly voted on the deal early today and also approved it. The acquisition now goes before the Irish High Court, which may take several… – Continue reading
As the Organisation for Economic Co-operation and Development (OECD) passes the halfway point in its joint project with the G20 to address base erosion and profit shifting (BEPS) concerns, it is worth pausing to examine what the consequences of some of the proposed changes may be. Much of the focus… – Continue reading
Holley Nethercote commercial & financial services lawyers David Court, a partner at Holley Nethercote Commercial and Financial Services Lawyers was recently interviewed by an international publication regarding the implementation of FATCA in Australia. Below are some of David’s thoughts – How have you approached FATCA? What’s your biggest challenge? What… – Continue reading
HSBC, Sovereign, FedEx, DHL & UPS all expecting summons from IRS American IRS officials are said to be carrying out investigative work concerning FATCA transgressions from the American Consulate in Hong Kong, according to a report issued in the South China Morning Post. The article quoted Travis Benjamin, a Partner… – Continue reading
The future for offshore tax planning, also known as “aggressive tax planning” is likely to be limited to if not curtailed by the global exchange of information agreement signed in October, 2014 by 51 countries and growing. The link below is to a video summary of the predicted consequences of… – Continue reading
Multinationals told to be more cautious about intra-group transactions as Beijing imposes stiff measures against avoidance and evasion Multinationals have been advised to take notice of Beijing’s New Year resolution to crack down on tax avoidance and evasion, especially after the announcement of the general anti-avoidance rule (GAAR) and new… – Continue reading
HSBC Holdings and the city of Hong Kong, which were last month linked to an international tax evasion network, are currently under scrutiny as part of efforts by U.S. authorities to hunt down American tax evaders, the South China Morning Post (SCMP) reported Monday, citing lawyers. Official with the U.S…. – Continue reading
U.S. Internal Revenue Service officials are stepping up an international tax evasion investigation into HSBC Holdings and the city of Hong Kong in an effort to crack down on American tax evaders, the South China Morning Post reported. IRS officials are now stationed in overseas Asian jurisdictions, including at the… – Continue reading
New Delhi: As a probe continues into misuse of stock markets for routing black money and tax evasion, the regulatory and other agencies suspect that GDR route is being used for bringing back suspected illicit funds stashed abroad. The modus-operandi, in cases currently under scanner, involves an intricate web of… – Continue reading
The Price of Offshore Revisited was written by James Henry, a former chief economist at the consultancy McKinsey, for the Tax Justice Network. Tax expert and UK government adviser John Whiting said he was sceptical that the amount hidden was so large. Mr Whiting, tax policy director at the Chartered… – Continue reading
Europe’s tax showdown could be headed straight to people’s wallets. With the new year, a change in fiscal rules in the European Union is increasing the tax on many purchases of digital content like e-books and smartphone applications. Under the new rules, first approved in 2008, the tax rate on… – Continue reading
Critics said the deal would allow Medtronic avoid taxes while providing preferential treatment to executives. The promise of 1,000 new Minnesota jobs was not enough to convince the state’s pension board to support a $48 billion corporate transaction that will move Medtronic’s legal headquarters overseas. A four-member subcommittee of the… – Continue reading
The new year could bring important changes to the tax landscape. Here are several issues that will affect how much taxpayers owe for 2015 and beyond: Federal tax policy There is serious talk of overhauling the federal tax code. “There appears to be a consensus” on making changes, says Stephen… – Continue reading
A number of financial institutions rushed to meet a registration deadline after a late-night regulatory circular on Tuesday urged them to sign up with American tax authorities. The circular had advised registration by Thursday. The institutions have to do so under America’s Foreign Account Tax Compliance Act (Fatca). It requires… – Continue reading
A number of financial institutions rushed to meet a registration deadline after a late-night regulatory circular on Tuesday urged them to sign-up with American tax authorities. The circular came out on 30th December, and asked institutions to register by 1st January. The institutions have to sign up under the Foreign… – Continue reading
The conditions for becoming tax-resident and tax non-resident vary from country to country and depend on such things as length of stay, type of accommodation, location of family, and nationality. In most tax systems, presence of an individual in a country for 183 days or more in any 12-month period… – Continue reading
Summary New FATCA requirements that apply to U.S. and non-U.S. insurance brokers and insurance companies will take effect on January 1, 2015. Those requirements impose new information gathering and reporting rules when U.S. insurance and reinsurance premiums are sent outside the U.S. Background The Foreign Account Tax Compliance Act (FATCA)1… – Continue reading
Swiss banks are training their crosshairs on Israeli customers. Legal sources said that in the past two weeks, the large banks in Switzerland have begun sending many queries to their Israeli customers demanding confirmation either that the assets deposited with the banks were reported to the Israeli tax authorities, or… – Continue reading
In recent court filings made in various federal district courts in Washington and California, the Internal Revenue Service is seeking to enforce testimonial summonses issued to current or former Microsoft employees, including former CEO Steven A. Ballmer. The summons had been issued earlier this fall. Microsoft’s outside tax counsel responded… – Continue reading
[HONG KONG] Asia could set another record for international bond issues in 2015 if Chinese companies continue to borrow offshore at the same voracious pace they did this year, while bankers expect a heavy redemption schedule and larger pipelines from India and Indonesia to lift activity. Barclays is forecasting volumes… – Continue reading
Within its list of frequently asked questions (FAQs) on issues associated with the requirements of the Foreign Account Tax Compliance Act (FATCA), the United States Internal Revenue Service (IRS) has provided added information for foreign financial institutions (FFIs) in jurisdictions with in-substance intergovernmental agreements (IGAs). FATCA, which was enacted by… – Continue reading
NEW DELHI: All Indian financial institutions with exposure to the US will have to register by tomorrow with the American tax authorities to avoid a hefty penalty tax of up to 30 per cent under the new Foreign Accounts Tax Compliance Act (FATCA). While it has extended the deadline for… – Continue reading
The Vatican Bank is the latest to join the ranks of a hundred other countries worldwide that have agreed to the terms of the FATCA. Since its enactment in 2010, the Foreign Account Tax Compliance Act or FATCA, has seen American Tax Law extend its reach further than ever before…. – Continue reading
Forbes is reporting on the Vatican Bank’s decision under pressure to comply with the FATCA requirements for reporting on American citizen accounts. In his annual Christmas messages to more than one billion Catholics, the Pope may have left out something: offshore account compliance. Maybe, but the U.S. Treasury is more… – Continue reading
NEW DELHI: While India is yet to sign a final pact with the US for the Foreign Accounts Tax Compliance Act (FATCA), close to 1,000 Indian financial institutions and their overseas units are believed to have already registered with the US tax authorities under this new regime. The tricky situation… – Continue reading
Currently, there is a tendency among those who take an interest in international tax developments to look to the future and try to guess how the international tax landscape will look in, say, three of four years, once countries begin to implement the OECD’s base erosion and profit shifting (BEPS)… – Continue reading
Regulator concerned over lack of reciprocity from US in Fatca norms Signing of an inter-government agreement (IGA) between India and the US on the Foreign Account Tax Compliance Act (Fatca) might not be smooth, despite New Delhi getting a one-month extension for this, as the Securities and Exchange Board of… – Continue reading
You may have heard in the news about Boris Johnson. He’s a flamboyant politician in the U.K. with an unruly mop of blonde hair. Recently, he made news by publicly saying he absolutely won’t pay his U.S. taxes. And yes, he is the mayor of London (the “real” London, where… – Continue reading
Fiat Chrysler Automobiles publicly denied a media report saying it was thinking about moving the tax residence of its Ferrari luxury sports car division outside Italy. “These rumors have no grounds,” FCA said in a company statement. “There is no intention to move the tax residence of Ferrari SpA outside… – Continue reading
NEW DELHI: India and some other countries have got one more month from the US to sign the Foreign Account Tax Compliance Act (FATCA), an agreement which seeks to facilitate flow of financial information. “US has given a month’s extension to India and some other counties to sign FATCA,” Revenue… – Continue reading
The informal Washington D.C. dinner that took place 40 years ago has become the stuff of legend. That’s when economist Arthur Laffer used a beverage napkin to sketch a chart that became known as the “Laffer Curve.” The following four decades proved Laffer’s point: People change their behaviors in response… – Continue reading
