The FACT (Financial Accountability and Corporate Transparency) Coalition today submitted comments to the Treasury Department praising their previous actions to limit inversions while also calling for additional measures. The proposals come as a part of the open comment period for Notice 2014-52, Rules Regarding Inversions and Related Transactions, originally issued… – Continue reading
Think tank targets key aspects of Republic’s role in multinationals’ tax affairs Key features of Ireland’s role in the tax affairs of major technology companies such as Google and Microsoft are being targeted by the OECD’s base-erosion and profit-shifting (Beps) project, it has emerged. Ideas being worked on by the… – Continue reading
Unlike China, Japan‘s manufacturing activities rose in December. Flash PMI from HSBC came out at 52.1, up from 52 in November. A reading over 50 signals expansion. Meanwhile, the Nikkei newspaper reported that Japan’s government is considering lowering the corporate tax rate by 2.5 percentage points starting next April. Among… – Continue reading
On 2 December 2014 the Cyprus finance minister and the American ambassador to Cyprus formally signed the intergovernmental agreement (“IGA”) between Cyprus and the USA under the Foreign Account Tax Compliance Act (“FATCA”), an American tax measure enacted in 2010 with the purpose of implementing mechanisms designed to prevent and… – Continue reading
With regards to the US Foreign Account Tax Compliance Act (FATCA); the Caribbean Association of Banks (CAB) has strongly urged governments in the region, who have yet to complete the process towards a signed Intergovernmental Agreement (IGA) with the USA to do so prior to 31 December, 2014. FATCA was… – Continue reading
The total number of new company registrations increased across offshore jurisdictions in the first half of 2014, according to Appleby, a provider of offshore legal, fiduciary and administration services. In the first half of 2014, there were 46,455 new offshore company incorporations, representing a 4% increase on the preceding six… – Continue reading
Is it a straw in the wind? Last week’s report on tax reform from the Republican staff of the U.S. Senate Committee on Finance has caused a flutter in the global expat community. Page 282 contained these words: “The United States is the only industrialized country in the world that… – Continue reading
While the media has been feasting on Lux Leaks and other stories of “multinational tax dodging”, academic accountants have determined that U.S. multinational corporations (MNCs) have no particular tax advantage over U.S. domestic firms. In fact, a new study finds the average effective tax rate for U.S. MNCs is slightly… – Continue reading
HONG KONG (CNNMoney) — He left America at the age of seven, has never earned a penny there, but might owe the U.S. government $6,000 in taxes. Meet Elad Shahar, who was born in 1969 to Israeli parents in New York when his father was posted there for work. Anybody… – Continue reading
On December 1, 2014, Treasury and the IRS issued Announcement 2014-38 which provides relief to those countries which have reached FATCA Intergovernmental Agreements (IGAs) in substance, but have not signed such agreements. Background In 2012, Treasury and the IRS released Model 1 and Model 2 IGAs to implement the Foreign… – Continue reading
Abu Dhabi, 16th December, 2014 (WAM) – The Central Bank of the UAE organized a workshop on the US Foreign Account Tax Compliance Act (FATCA), to which banks and other financial institutions in the UAE were invited, on Monday, 15 December 2014 at its Head Office in Abu Dhabi. Squire… – Continue reading
(CNS Business): Barclays Bank’s Swiss operations is ending its cooperation with the Internal Revenue Service’s efforts to prevent investors from investing money in foreign countries with more amenable tax structures and policies. During a Zurich speech, Barclays bank executive Francesco Grosoli announced that the firm’s Swiss operations had “recently exited… – Continue reading
Armenia’s Central Bank (CB) claims thatsome data regarding money flows to and from offshore financial centers is protected from public disclosure under the law. We say ‘some’, because the CB is being selective when it comes to which information can be disclosed and what cannot. When Hetq contacted the CB,… – Continue reading
Something strange happened in 2014 — Americans became very interested in corporate tax policy. It started in the spring, when U.S.-based pharmaceutical giant Pfizer, which produces blockbuster drugs like Lipitor and Viagra, floated a possible merger with its British-based rival AstraZeneca. Normally a merger of that size would make a… – Continue reading
In prior advisories, we have discussed the new withholding tax law commonly known as “FATCA” (standing for “Foreign Account Tax Compliance Act”). (See “FATCA’s July 1 Effective Date Has Arrived; Last-Minute Guidance Has Been Issued” and “Last Substantial Package of FATCA Regulations Released; Deadlines Approaching”.) To help implement FATCA, the… – Continue reading
The surge in U.S. companies avoiding taxes by taking a foreign address has been condemned by President Barack Obama and stirred a policy debate in Congress. What’s often overlooked is that these “inversions” are typically a final step in a hopscotch of multinational tax dodging. Many companies invert after years… – Continue reading
Dec. 15— The Internal Revenue Service filed a petition in U.S. district court to enforce a summons against Microsoft Corp. to produce “books, records, papers and other data” related to the pricing of intangibles under two cost-sharing arrangements (United States v. Microsoft Corp., W.D. Wash., No. 2:14-mc-00117, petition filed 12/11/14)…. – Continue reading
Background On 15 December, 2014, the OECD hosted a webcast to update the global tax community on progress under the Base Erosion and Profit Shifting (“BEPS”) Plan. This year, the OECD produced 10 different reports (“BEPS Reports”) covering several actions specific to transfer pricing. This latest OECD webcast summarised efforts… – Continue reading
December 15: The IRS has posted the final version of Form 8938, Statement of Specified Foreign Financial Assets (Rev. December 2014) for 2014, on the IRS website. Form 8938 is to be used to report specified foreign financial assets if the total value of all the specified foreign financial assets… – Continue reading
They never really lived in U.S., but still have to pay taxes HONG KONG (CNNMoney) —He left America at the age of seven, has never earned a penny there, but might owe the U.S. government $6,000 in taxes. Meet Elad Shahar, who was born in 1969 to Israeli parents in… – Continue reading
Some of the best tax minds in the country agree on one thing: Corporate tax reform will be a very, very heavy lift. Sure, the White House and top lawmakers who will be in charge of writing tax law next year have signaled their openness to the idea. And, yes,… – Continue reading
Rome (dpa) – The head of Italy‘s tax office, Rossella Orlandi, on Monday criticized automaker Fiat‘s decision to move its tax residence to Britain after completing a merger with US peer Chrysler. “I would … like to stress that we need some sense of national pride. In Germany tax rates… – Continue reading
A bill filed in the U.S. House of Representatives proposes to reform the tax code and attract new money for transportation and other infrastructure. The bill filed by U.S. Rep. John Delaney, D-Md., would create incentives for U.S. corporations to bring back profits stored in offshore accounts and invest it… – Continue reading
At its Fall Meeting in Nashville, Tennessee on December 11-12, the MTC’s Executive Committee voted to formally contact states to solidify whether there is sufficient financial commitment to fund any potential MTC transfer pricing program. The MTC also formally announced that Iowa, Pennsylvania and Rhode Island will join the MTC… – Continue reading
The wise thing is to forget the past, bring reforms to prevent generation of black money Considering other man’s point of view is Decency — George Orwell This quality seems to be in short supply in India although it is the most needed even to understand any black money retrieval…. – Continue reading
Around the world, countries are desperately seeking ways to stop multinational companies from earning profits within their borders without paying taxes on them, while stashing trillions in tax havens like the Cayman Islands. The British government, after a search, says it knows how to tax the profits Google earns in… – Continue reading
Financial institutions around the world including those in Asia are struggling to stay compliant with local privacy regulations that restrict the sharing of client data, whilst at the same time trying to meet the demands of costly FATCA reporting requirements. FATCA, the Foreign Account Tax Compliance Act, which came into… – Continue reading
Just how the US Foreign Account Tax Compliance Act (FATCA) is impacting on the lives of Americans in sometimes unintended is illustrated in the tax troubles of the Mayor of London. Boris Johnson, a former British MP, has dual British and US nationality. He was born in New York but… – Continue reading
As multinationals are forced to reveal more about themselves, where should the limits of transparency lie? HOWARD SCHULTZ, the head of Starbucks, said last year that “the currency of leadership is transparency.” If so, bosses should be feeling ever more qualified to command their troops. Business is being forced to… – Continue reading
RBI says it has no information on any offshore accounts, allegedly held by three industrialists as per list ‘released’ by Washington NGO; This list doesn’t mention any Swiss bank account PANJIM: There is no evidence in public domain of any of the three industrialists named by Goa Foundation Director Claude… – Continue reading
When the Chesapeake Bay Foundation, the Johns Hopkins University and other Maryland nonprofits want to maximize the money they can spend in pursuit of their missions, they do what many wealthy individuals and businesses do. They open investment accounts overseas. Many of Maryland’s wealthiest nonprofits — including the University of… – Continue reading
MONTREAL – The problem is not that Bombardier Inc. played a complex shell game since at least 2010 by refinancing and redirecting US$500 million of its financing activities to Luxembourg, a notorious tax haven. It’s that it does so legally — and is hurting its home country despite being one… – Continue reading
Rep. John Delaney (D-Md.) introduced a new plan Friday to pay for highway improvements through fresh revenues from offshore income. Under the measure, offshore corporate income would be taxed at 8.75 percent, allowing multinationals to bring cash back to the U.S. far cheaper than at the top corporate rate of… – Continue reading
All those Dutch sandwiches, double Irishes and Luxembourg, uh, lunchboxes that US multinational companies use to defer taxes and shift profits abroad are expected to be re-empowered today when the Senate votes to enact a one-year tax extension package. Included in the package is a renewal of two breaks, one… – Continue reading
On 9 December 2014, the Government of Singapore and the Government of the United States signed an intergovernmental agreement (“IGA“) to facilitate the implementation of the Foreign Account Tax Compliance Act (“FATCA“) in Singapore. The IGA is based on the United States Department of the Treasury’s Model 1 IGA and… – Continue reading
There’s big news from across the pond. The U.K. government’s Autumn Statement (formerly known as the pre-Budget report), released December 3, promises to change how multinational corporations will be taxed – and offers a cautionary tale for would-be U.S. tax reformers. Britain will introduce a “diverted profits” tax, targeting corporations… – Continue reading
This is a United World interview for USA Today for a report on Antigua and Barbuda. Brian Stuart-Young, CEO of Global Bank of Commerce and Non-resident Ambassador to China, spoke about opportunities for American investors in the energy sector, Antigua’s robust framework for financial services, and the potential for the… – Continue reading
There’s big news from across the pond. The U.K. government’s Autumn Statement (formerly known as the pre-Budget report), released December 3, promises to change how multinational corporations will be taxed – and offers a cautionary tale for would-be U.S. tax reformers. Britain will introduce a “diverted profits” tax, targeting corporations… – Continue reading
For busy in-house counsel and compliance professionals, we have tried to summarize the most important international anti-corruption developments in the past month with links to primary resources. November was definitely a busy month with a variety of developments. Here is our Top Ten list: Bio-Rad $55 Million FCPA Resolution. On… – Continue reading
Law360, New York (December 11, 2014, 3:21 PM ET) — Amazon.com Inc. CEO Jeff Bezos got out of having to testify in a suit concerning a Luxembourgian subsidiary and tax obligations for the years 2005-2006, when the U.S. Tax Court granted his motion to quash the Internal Revenue Service’s subpoena… – Continue reading
Findings from Americans for Tax Fairness directly contradict Burger King’s earlier insistence that the merger would create ‘no tax benefit’ Burger King acquires Tim Hortons and calls Obama’s bluff on tax Burger King stands to avoid paying hundreds of millions of dollars in US taxes if it completes its pending… – Continue reading
Jonathan Gruber, MIT professor and Affordable Care Act (ObamaCare) architect, faced the House Oversight committee earlier this week. Gruber was grilled over his comments pertaining to the passage of ObamaCare through Congress and the law’s mechanics. The professor has been caught on camera multiple times almost bragging about the deception… – Continue reading
Stocks rose today for the first time in four trading days in the wake of a report showing strong retail sales in November and as oil continues its sharp decline. The Dow Jones industrial average gained 63.19 points to 17,596.34, the Standard & Poor’s 500 index rose 9.19 points to… – Continue reading
The US Treasury estimated that it will cost foreign banks and financial institutions $8 billion to comply with Fatca. This amount does not take into account the amount of time and cost that US citizens will need to take to comply with the demands of foreign banks and financial where… – Continue reading
Do trustees need to register with the US Internal Revenue Service (the “IRS”) before 1 January 2015? Does registration need to be made in respect of a trust? These questions need to be given due consideration by Cayman Islands and British Virgin Islands (“BVI”) trustees and the trusts in respect… – Continue reading
Exports of Ukrainian goods through offshore companies fell by 90 percent in the first nine months of this year, according to the State Fiscal Service, dropping to $334 million. British Virgin Islands, a jurisdiction known for the lack of transparency, remains the most popular offshore destination with Ukrainian companies, attracting… – Continue reading
In the light of new revelations in the Luxembourg tax evasion schemes, some MEPs will push to fast-track the European Parliament’s legislative reports being drafted by the legislature’s economic committee. “The new revelations show this is a European problem that needs a European solution. Citizens and SMEs pay their taxes,… – Continue reading
Bank Leumi Le-Israel Ltd. (LUMI) expects to reach an accord with the U.S. government by next month over accusations Israel’s second-largest bank helped Americans evade taxes. “The management believes it is right to reach an agreement with authorities, just as global banks have done,” Leumi’s legal adviser Hanan Friedman said… – Continue reading
Maples and Calder Michael Gagie, Richard Grasby, Tim Clipstone, Christopher Capewell, Jon Fowler and Tim Frawley Do trustees need to register with the US Internal Revenue Service (the “IRS”) before 1 January 2015? Does registration need to be made in respect of a trust? These questions need to be given… – Continue reading
More paperwork as governments force wealthy to declare overseas assets. What you need to know. It won’t be long before there is no place in the world to hide money from your home country. Governments have tried to catch people who aren’t paying their taxes, or worse, are laundering money… – Continue reading
