Category: North America

Canada transparency laws force ASX companies to disclose tax bills

Two Australian mining companies will be forced to disclose how much tax they pay in every country around the world by new transparency laws introduced in Canada. Paladin Energy and OceanaGold, both dual-listed in Australia and Canada, will have to comply with new Canadian laws requiring all oil, gas and… – Continue reading

Swiss Bankers in Limbo After U.S. Jury Clears Ex-UBS Manager

The courtroom victory of the only Swiss banker to beat the U.S. in a trial over offshore tax evasion may embolden other indicted financial workers to leave a legal limbo some have endured more than five years. Twenty-five offshore bankers, lawyers and advisers have yet to answer U.S. Justice Department… – Continue reading

Scorecard of Offshore Tax Crimes: Advisers, Bankers and Lawyers

A mixed success record has been notched up by the US Justice Department when it comes to prosecuting offshore bankers, advisers and lawyers accused of assisting American taxpayers cheat their taxes. The United States Government, from 2008, has charged 38 individuals, including Swiss bankers like the top three managers of… – Continue reading

Launch of electronic certificates in BVI

On 8th December 2014, the British Virgin Islands Financial Services Commission (FSC) launched the electronic delivery of certificates of good standing for the benefit of users. The digital certificates will have the same security features as the original hard copy and issuers can authenticate these directly via the authentication service… – Continue reading

The Vatican Bank, Christmas Cheer, And FATCA

For centuries the inner workings of the Vatican Bank have been cloaked in secrecy. That was before Pope Francis, who has pledged to restore public confidence in the administration of the Roman Catholic Church. This week we learned the United States and the Holy See have brokered a FATCA agreement… – Continue reading

Worldwide Exchange of Tax Information: OECD Expands upon FATCA to Add New Requirements

While the Foreign Account Tax Compliance Act (FATCA) has focused worldwide attention on U.S. efforts to create a mandatory cross-border exchange of tax information, the enactment of FATCA was not an isolated occurrence. For more than a decade, the Organisation for Economic Co-operation and Development (OECD) has been trying to… – Continue reading

IRS demands Ballmer, other Microsoft leaders testify in corporate tax audit

The Internal Revenue Service has sued former Microsoft CEO Steve Ballmer and a slate of other former and current executives, seeking to compel them to testify in a long-running investigation into how the company’s sales through subsidiaries affected its taxable income. The Internal Revenue Service has sued former Microsoft Chief… – Continue reading

FATCA Registration Resources and Support Information

ALERT: Updated Withholding Foreign Partnership (WP) and Withholding Foreign Trust (WT) Agreements have been released and posted to the FATCA Website.  Both updated agreements are set out in Revenue Procedure 2014-47, which updates and supersedes the WP and WT Agreements originally released as Revenue Procedure 2003-64, 2003-2 C.B. 306. FATCA… – Continue reading

Bank Leumi to Pay $400 Million in U.S., N.Y. Tax Probes

Bank Leumi Le-Israel Ltd. (LUMI) agreed to pay $400 million and admit it helped American clients evade taxes for a decade, in a case showing that U.S. prosecutors and New York regulators are extending their probes of offshore tax evasion beyond Switzerland. The Justice Department filed a conspiracy charge today… – Continue reading

Ingersoll-Rand Cleared for U.S. Contracts Despite Inversion

In August, President Barack Obama pledged to use the powers of his office to discourage the corporate tax-avoidance technique known as inversion, in which U.S. companies claim foreign tax addresses. Four months earlier, according to a previously unreported legal document, his Department of Homeland Security did just the opposite. It… – Continue reading

Father Christmas’s FATCA Concerns

Even Father Christmas should make sure he’s not inadvertently hiding anything from the US tax authorities, says Sophie Mazzier We all risk becoming a little preoccupied with counting at this time of year, don’t we? Actually, with both counting and deadlines. If it isn’t opening those 24 doors on the… – Continue reading

Multinational firm in Mexico tax-avoidance probe to pay up-report

Dec 22 (Reuters) – Mexico’s tax collection agency (SAT) has reached a deal with a multinational company at the center of a tax-avoidance investigation, and the latter will make a ‘substantial’ payment soon, a senior official was quoted as saying on Monday. “We have just closed a case with an… – Continue reading

Lombard Odier targets ASEAN’s super rich in tie-up

Swiss private bank Lombard Odier will seek to tap into the growing number of high-net-worth-individuals (HNWIs) in Southeast Asia via an agreement with Thailand’s Kasikornbank. A recent report by RBC Wealth Management and Capgemini showed that Asia is leading the way in terms of the regional rise in number of… – Continue reading

UBS Whistle-Blower Birkenfeld Seeks Permission to Move to Europe

Bradley Birkenfeld, the former UBS AG banker who won a $104 million whistle-blower award after serving time in U.S. prison for tax conspiracy, now wants to move back to Europe before his term of probation is set to end. Birkenfeld asked a judge to end his probation with less than… – Continue reading

Gearing up for Obama’s visit: Finance Ministry to rush Cabinet note to sign US FATCA

NEW DELHI: The finance ministry is planning to rush through a Cabinet note seeking permission to sign an accord with the US on exchanging investment information before a December 31 deadline, ahead of President Barack Obama’s visit to Delhi at the end of January. The government has got the goahead… – Continue reading

The Year of Transparency’s Tipping Point

More countries are requiring an exchange of client information In 2014, we saw a marked increase in transparency regarding foreign assets. The United States took the lead, and other countries followed suit. It looks like we’ve reached the tipping point, that is, “the magic moment when an idea, trend, or… – Continue reading

My Turn: Legislature needs to work on closing tax loopholes

Gov. Maggie Hassan has done an excellent job working with legislative leaders to craft and oversee the state’s current two-year budget. An array of problems is being effectively managed. This budget will end in balance. But looking ahead to the next two-year budget, we in state government face difficult challenges…. – Continue reading

Attention to NH tax structure is needed

Gov. Maggie Hassan has done an excellent job working with legislative leaders to craft and oversee the state’s current two-year budget. An array of problems is being effectively managed. This budget will end in balance. But looking ahead to the next two-year budget, we in state government face difficult challenges…. – Continue reading

Father-Son Tax Preparers Convicted in Israeli Bank Tax Case

A father and son who ran a tax-preparation business were convicted in Los Angeles of conspiring to help clients cheat the Internal Revenue Service by setting up undeclared offshore bank accounts. David Kalai, the founder and former chief executive officer of United Revenue Service, and his son Nadav, who was… – Continue reading

Cayman begins to see a rise in hybrid funds

UBS Fund Services has had one of its strongest years in terms of winning new clients according to Monette Windsor (pictured), who heads up the Cayman Islands business.   “We’ve invested heavily in our business development team this year and we’ve had to beef up our client onboarding team. We have 165… – Continue reading

Looking back at pensions, platforms and regulation in 2014

Bravura Solutions reflects on a year of reform and looks forward to 2015. The Chancellor’s Autumn Statement last week didn’t deliver anything as revolutionary as the reforms announced in his March budget, but there were a few early Christmas crackers around ISA rules. After a monumental year, let’s look at… – Continue reading

Ranking Facebook, Boris Johnson, Google On Taxes (Diplomatically Please)

Ambassadors are supposed to be diplomatic and suave. Yet even those of the diplomatic corp may occasionally get tongue-tied or utter ill-timed statements. Take U.S. Ambassador to Britain Matthew Barzun. He recently sounded not all that diplomatic about duty, compliance with law, and yes, even taxes. Lee Rigby was a… – Continue reading

Offshore tax probe seeks data from Panama firm

NEW YORK – The multiyear federal crackdown on wealthy Americans who duck taxes by hiding income and assets offshore is targeting a Panamanian legal services firm suspected of arranging anonymous banking services. A Manhattan federal judge on Friday approved special summonses for Sovereign Management & Legal. The approval also covered… – Continue reading

A whopper of a deal at taxpayers’ expense

Burger King Chief Executive Officer Daniel Schwartz swears that the company’s plan to renounce its U.S. “citizenship” and become a Canadian corporation “is really not about taxes.” But a new report by my group, Americans for Tax Fairness, finds that it really is about taxes after all. The report reveals… – Continue reading

Piketty Sticks to Wealth Tax Proposal, Sees Positive Signs

Thomas Piketty’s “Capital in the 21st Century” was a 2014 must-read for anyone interested in economics. But while his claim that income and wealth inequality has risen over recent decades to highs last seen before the start of the First World War was widely accepted, his policy prescriptions were not…. – Continue reading

Volume of controlled transfer pricing deals in 2013 comes to UAH 1.142 trl – fiscal service

The total number of reports on controlled transfer pricing operations, received by the State Fiscal Service of Ukraine, as of October 1, 2014 exceeded 2,500. The head of the department for transfer pricing inspections at the Fiscal Service, Mykola Mishin, said at the round table “Transfer pricing in Ukraine: problems… – Continue reading

The Best Job in the World

This is going to be the plum job for any international tax practitioner: Competent Authority for the Republic of Ireland. It seems pretty clear that the Base Erosion and Profit Shifting (BEPS) project will meet its announced deadline of the end of 2015 to produce final reports on all of… – Continue reading

Luxembourg accedes to EU antitrust demand to divulge tax data

(Reuters) – Luxembourg acceded on Thursday to the demand of the European Commission to release data to further EU antitrust regulators’ investigation into whether it allowed multinationals to pay excessively low taxes. The European Commission launched investigations this year into whether U.S. retailer Amazon (AMZN.O) and a unit of Italian… – Continue reading

Tax Inversions Wrap Up

There has been a recent surge in anti-tax inversion legislation discouraging companies attempting to shift corporate subsidiaries or headquarters to low-tax or tax-free countries. The issue was subjected to a great deal of publicity in April 2014 during the failed hostile takeover by Pfizer (NYSE:PFE) for AstraZeneca (NYSE:AZN) when Pfizer… – Continue reading

Anti-corruption rules fail to force clarity on property ownership, MPs say

Coalition plan for stripping ‘cloak of secrecy’ from shell firms that leaves housing loophole slated by politicians and other critics Business minister Matthew Hancock unveiled ‘the first UK anti-corruption plan bringing action across the government’. Photograph: Jack Taylor/Barcroft Media Government plans to rip “the cloak of secrecy” from corrupt officials… – Continue reading

Wolters Kluwer Financial Services Issues FATCA Guidance for Banks in Asia

Regional Adoption on Pace with Europe as Singapore Signs Agreement Experts at Wolters Kluwer Financial Services today issued guidance on the Foreign Account Tax Compliance Act in an effort to help support banks’ regulatory compliance efforts within the region. The commentary comes in reaction to the news last week that… – Continue reading

DBS Bank launches US dollar investment program in support of currency appreciation

DBS Bank is scheduled to launch a U.S. dollar fixed deposit program for Taiwanese investors intrigued by the recent drop in the United States’ financial deficits, said Seraph Sun (孫可基), head of Consumer Banking at DBS Bank (Taiwan). According to Sun, DBS Bank deems 2015 a hopeful year for the… – Continue reading

US Business Attacks Proposed UK Diverted Profits Tax

The United States Council for International Business (USCIB) has warned that the United Kingdom’s proposal to impose a new tax on so-called “diverted profits” (DPT) would, if implemented, have a major impact on US-based multinational companies. The rules, contained in UK Government’s recent Autumn Statement, propose a 25 percent DPT… – Continue reading

Interviews/Studies Speed Trader Study Shows Treasuries Hurt When Breaking News Hits

High-frequency trading in the U.S. Treasury market makes it harder for investors to buy and sell bonds when news events cause prices to move, according to the Bank of Canada. Researchers studied how liquidity changed as algorithmic-trading programs, which are much faster than people, reacted to economic indicators including the… – Continue reading

Worldwide exchange of tax information: OECD expands upon FATCA to add new requirements

While the Foreign Account Tax Compliance Act (FATCA) has focused worldwide attention on U.S. efforts to create a mandatory cross-border exchange of tax information, the enactment of FATCA was not an isolated occurrence. For more than a decade, the Organisation for Economic Co-operation and Development (OECD) has been trying to… – Continue reading

FATCA Compliance Efforts Give Taxpayers and Foreign Financial Institutions an Advantage with IRS

FATCA causes foreign banking and financial institutions to place priority on information sharing practices and procedures. Foreign banks, financial institutions, and U.S. taxpayers living abroad are being advised to show a strong “good faith” effort in complying with the Foreign Accounts Tax Compliance Act.  Passed in 2010, the law requires… – Continue reading