Category: North America

Tax Reform In 2015 Can Impact Apple

Summary Corporate tax reform is getting closer, repatriation of foreign profits is a possible outcome. Reform may end the practice of deferment, meaning overseas cash hordes will no longer be part of common corporate practice. Many large U.S. companies will have decisions on how to use funds that are no… – Continue reading

Ferrari Said to Weigh Moving Fiscal Base Outside Italy

Ferrari SpA is considering moving its fiscal residence outside Italy to save on corporate taxes as the supercar maker prepares for its spinoff from Fiat Chrysler Automobiles NV (FCAU), people familiar with the matter said. The manufacturer, which uses the colors of the Italian flag in its logo, may follow… – Continue reading

IRS Extends ‘Deemed Compliant’ Status of Countries for FATCA

The Internal Revenue Service has issued an announcement extending the “deemed compliant” status of countries that are treated as if they had an intergovernmental agreement with the U.S. Treasury Department in place for purposes of the Foreign Account Tax Compliance Act. FATCA, which was included as part of the HIRE… – Continue reading

Former Swiss Banker Collapses During WikiLeaks Data Trial

Rudolf Elmer, the former employee of Julius Baer Group Ltd. accused of revealing details of client accounts via WikiLeaks, collapsed at the start of his trial, forcing the court to postpone the case. It was not clear when the trial in Zurich District Court would continue. Proceedings had been under… – Continue reading

China Graft, Madoff Aides, Luxembourg Rulings: Compliance

China set up a website to collect tips about officials who have fled with ill-gotten gains, as leaders press ahead with a campaign that’s resulted in the arrests of hundreds of alleged economic fugitives so far. The Communist Party’s anti-graft watchdog, the Central Commission for Discipline Inspection, encouraged whistle-blowers at… – Continue reading

BREAKING NEWS — Palm Beach Billionaire David Koch, Brother Charles Named in Euro Tax Haven Scandal!

LUXEMBOURG  — Palm Beach billionaire David Koch and his equally-loaded brother Charles got the government of Luxembourg to sign a secret, custom-made deal that allowed their companies to save hundreds of millions of dollars that otherwise would have been taxed in the United States. On its website this morning, the… – Continue reading

Impact of FATCA on Bermuda Entities

This publication provides a brief overview of the expected impact on entities established in Bermuda of (a) the foreign account tax compliance provisions (“FATCA”) of the Hiring Incentives to Restore Employment Act, 2010 of the United States of America (the “US”); and (b) equivalent rules implemented in relation to United… – Continue reading

Israeli Swiss Bank Tax Evasion Investigation Widens

A senior figure is suspected of secretly keeping accounts in a Swiss bank that were not reported to the tax authorities in Israel, in an affair called the “Swiss Bank Affair,” sources inform “Globes.” Israel Tax Authority investigators conducted a search of the senior figure’s home. As in the information… – Continue reading

Awareness On FATCA Remains Low, Says PwC

KUALA LUMPUR, Dec 10 (Bernama) — Awareness of the US Foreign Account Tax Compliance Act (FATCA) among local financial institutions remains low, PricewaterhouseCoopers (PwC) said. “I’d venture an educated guess that there are more than 1,000 local financial institutions, which fall under the FATCA purview, some of which may not… – Continue reading

Revenue Quebec looking into whether Bombardier is using a European tax haven

Quebec’s finance minister says he understands Bombardier Inc. pays its taxes according to Quebec and Canadian laws and that “we receive what we should receive.” But nevertheless, Carlos Leitão said he has asked Revenue Quebec to look into whether Bombardier is using a European tax haven to avoid provincial taxes…. – Continue reading

Disney and Microsoft dragged into Luxembourg tax avoidance scandal engulfing EU chief Jean-Claude Juncker

Grand Duchy accused of allowing multinational firms to pay virtually no tax Leaked documents reveal more firms used Luxembourg to lower tax There is no suggestion that the tax schemes used by firms are illegal But scandal has dragged in Luxembourg’s former PM Mr Juncker Giant US businesses Disney and… – Continue reading

Former Swiss Banker Collapses During WikiLeaks Data Trial

Rudolf Elmer, the former employee of Julius Baer Group Ltd. accused of revealing details of client accounts via WikiLeaks, collapsed at the start of his trial, forcing the court to postpone the case. It was not clear when the trial in Zurich District Court would continue. Proceedings had been under… – Continue reading

PwC charged with “selling tax avoidance on an industrial scale”; indulging in “scams”

The House of Commons Public Accounts Committee on Monday held a hearing on the role of accountancy firms in tax avoidance and PwC (PricewaterhouseCoopers), the Big 4 accounting firm, was represented by Kevin Nicholson, PwC head of tax in the UK and former HMRC (HM Revenue & Customs) tax inspector,… – Continue reading

FEDS SUE DEUTSCHE BANK FOR TAX FRAUD DATING BACK TO 2000

NEW YORK (InsideBitcoins) — Federal prosecutors with the U.S. Attorneys Office in Manhattan are suing Deutsche Bank, stating that the German bank owes the US Government roughly $190 million in unpaid taxes. The claims of tax evasion stem from gains related to the sale of Bristol-Meyers shares in 2000. Prosecutors… – Continue reading

Luxembourg tax files: how Juncker’s duchy accommodated Skype and the Koch empire

The EU’s most powerful official is under mounting pressure as dozens more multinational corporate names are dragged into the Luxembourg tax scandal following a new leak of confidential documents on Tuesday. Jean-Claude Juncker, president of the European commission, has been battling to distance himself from the growing furore over the… – Continue reading

American citizens like Boris must pay more tax, says US ambassador to UK (but Google and Amazon are doing nothing wrong)

Ambassador to London Matthew Barzun says US citizens must pay up Boris Johnson was born in New York so faces a tax bill in America London Mayor has branded the Transatlantic rules ‘outrageous’ Barzun defends US firms like Amazon and Google over tax dodging Insists they are just playing by… – Continue reading

Leading financial centres ‘must act on corruption’, says watchdog

China and Turkey have fallen in international rankings of perceived corruption, according to a new report released by the Berlin-based anti-corruption watchdog Transparency International (TI).09 Dec 2014 Regulatory Europe Asia Pacific Gulf Africa According to the latest edition of TI’s Corruption Perceptions Index for 2014, which scores countries on a… – Continue reading

Bulgaria Concludes US FATCA Deal

Bulgaria has formally signed up to the US’s Foreign Account Tax Compliance Act (FATCA), just over six months after the two countries concluded a transitional “in substance” agreement. FATCA, which was enacted by the US Congress in 2010 and took effect on July 1, 2014, is intended to ensure that… – Continue reading

Luxembourg says disclosing tax rulings to other states

(Reuters) – Luxembourg is giving details of its tax deals with foreign firms to governments that ask for them, its finance ministry said on Tuesday, addressing critics of its role in helping companies avoid taxes on a global scale. In a statement issued after a Belgian minister revealed he was… – Continue reading

United States: Why Has The IRS Outsourced Microsoft’s Transfer Pricing Audit To A Private Law Firm?

Perhaps it was just a matter of time until the Internal Revenue Service decided to “outsource” its tax audit and litigation function to a private entity, i.e., a law firm. As reported in the December 8th issue of Tax Notes, the Service has hired the law firm of Quinn Emanuel… – Continue reading

EU Tax, Cisco, Google, Burger King: Intellectual Property

European Union nations that offer “patent box” tax breaks should retool their laws so that only deserving companies can claim benefits tied to technical innovations, according to a draft report from a European Union working group. Countries that use this kind of technology tax break should start legislative work next… – Continue reading

New Leak Reveals Luxembourg Tax Deals for Disney, Koch Brothers Empire

A new leak of confidential documents expands the list of big companies seeking secret tax deals in Luxembourg, exposing tax-saving maneuvers by American entertainment icon The Walt Disney Co., politically controversial Koch Industries Inc. and 33 other companies. Disney and Koch Industries, a U.S.-based energy and chemical conglomerate, both created… – Continue reading

ATO tax amnesty nets billions, but hunt for rich with secret Swiss accounts continues

Thousands of rich Australians have come forward to declare billions of dollars in untaxed assets and income stashed in bank accounts in Switzerland and in other countries. The rush comes as what the Australian Taxation office says is the last tax amnesty it will ever offer comes to an end…. – Continue reading

US Anti-Inversion Bill ‘Could Save More Revenue’

The Joint Committee on Taxation has increased, from USD19.5bn to more than USD33.5bn, its estimate of tax revenue that could be saved over a ten-year period from legislation to restrict corporate inversions introduced by Democrat lawmakers in the United States House of Representatives in May this year. A recent letter… – Continue reading

Hong Kong ORSO schemes dealt FATCA threat

Hong Kong’s financial institutions have been urged to assess whether their Occupational Retirement Schemes Ordinance (ORSO) retirement schemes are required to comply with the requirements of the US Foreign Account Tax Compliance Act (FATCA), which aims to prevent tax avoidance by US residents, according to law firm Deacons. ORSO schemes… – Continue reading

The Big Four divided over FATCA interpretation in Russia – report

MOSCOW, December 8 (RAPSI) – The world’s four largest audit firms, which provide services under the FATCA norms, have provided contradictory consultations to their Russian clients, Kommersant newspaper writes on Monday. The Big Four are the four largest international professional services networks, offering audit, assurance, tax, consulting, advisory, actuarial, corporate… – Continue reading

Global regulators need to standardise tax reporting mechanisms

Global regulators need to standardise the mechanisms by which financial institutions exchange tax information on their clients amid concern the number of tax information exchange agreements between various countries is spiraling out of control. This comes as a number of countries and global regulatory bodies introduce their own tax reporting… – Continue reading

Cyprus: Recent Developments In Automatic Exchange Of Information

The exchange of information between tax authorities worldwide is about to enter into a new phase of an active gathering and reporting of data. The eradication of tax evasion has now been elevated to a matter of priority amongst OECD states. There has been an unprecedented push to expand the… – Continue reading

Swiss Bank Drops Out of IRS Tax Compliance Program

Reversing earlier moves taken this summer and fall, a major international bank 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, such as Ireland or Switzerland. During a Zurich speech, Barclays bank executive… – Continue reading

The Country Has Spoken

While the dust is still settling from the mid-term elections and the pundits are trying to figure out what it all means, the American people have made their collective voices heard and delivered a message that they do not like the country’s direction. Exit polling data from Election Day showed… – Continue reading

Reporting Income from Offshore Investment: A Cautionary Tax Tale

The lesson from the ongoing trial of former UBS wealth management chief executive Raoul Weil really shouldn’t be a surprise, but we’ll say it anyway: Do not fail to declare income from offshore investments to avoid taxes. Unless, that is, you and your clients would prefer a really close relationship… – Continue reading

CORRECTED-Israel tax evasion probe leads to 28 arrests

(Corrects headline to remove reference to probe at UBS) Dec 8 (Reuters) – Israel has arrested 28 people so far as part of an investigation into Israelis allegedly holding undisclosed bank accounts with Swiss bank UBS, the Tax Authority said on Monday. “The investigation continues and more arrests are expected,”… – Continue reading

Deutsche Bank Hit With Tax Evasion Charges

Germany’s Deutsche Bank  dodged over $100 million in federal taxes, according to allegations in a lawsuit filed by the U.S. Attorney’s office in the Southern District of New York Monday afternoon. “Through fraudulent conveyances involving shell companies, Deutsche Bank tried to make its potential tax liabilities disappear. This was nothing… – Continue reading

Whistleblower Alleges Vanguard Cheated On Taxes, Costing Taxpayers More Than $1 Billion

On May 1, 1975, Princeton graduate John C. Bogle launched an investment company on a bold new idea: it would be owned by its member funds and operated for the benefit of its shareholders. That company, the Vanguard Group, is now one of the world’s largest investment companies with about… – Continue reading

Putin welcomes billionaires back to Russia – but will they come?

President Putin’s surprise amnesty allowing Russians with cash stashed abroad to bring it back home with no penalty may be a windfall, but then maybe not. The US, Mexico, Italy, Kazakhstan, and many others have tried it with varied success. When financial crises hit, governments have tried to reel in… – Continue reading

Banking secrecy to remain despite FATCA

BEIRUT: There is no threat to Lebanon’s banking secrecy, despite the mounting pressure from the international community to disclose the accounts of Lebanese with dual passports, bankers said. “The United States and some European countries, which are seeking the full cooperation of other states in disclosing the bank accounts of… – Continue reading

Two Years of Magnitsky Act: Facts and Details

The factbox devoted to two years of the so-called Magnitsky Act passed by US Senate. This act allows Washington to deny visas and freeze assets of Russian officials allegedly involved in the death of Russian lawyer Sergei Magnitsky. Five years ago, on November 16, 2009, Sergei Magnitsky, a tax and… – Continue reading

FATCA — final deadline to obtain a GIIN for Model 1 IGA FFIs

Under transitional relief, certain non-U.S. investment funds, including Cayman Islands funds, that qualify as foreign financial institutions (FFIs), have been permitted to certify their status under the U.S. Foreign Account Tax Compliance Act (FATCA) without registering with the Internal Revenue Service (IRS) to obtain a Global Intermediary Identification Number (GIIN)…. – Continue reading

U.S. Wants Swiss Banker in Court for Bail Hearing

A Swiss banker accused of helping American clients cheat on their taxes is a fugitive who must show up in a New York courtroom if he wants bail, U.S. prosecutors argued in a legal filing. Stefan Buck, who was Bank Frey & Co.’s head of private banking in Switzerland and… – Continue reading

PwC pushes for FATCA implementation in Nigeria

PwC Nigeria, a leading professional services firm, has challenged financial institutions operating in Nigeria and the sector’s regulators on the need to develop a regulatory framework to drive the implementation of the Foreign Account Tax Compliance Act (FATCA) in the country. Andrew S. Nevin, a partner at PwC Nigeria and… – Continue reading