The US and Canada are at the forefront of a global increase in new mutual agreement procedures (MAPs) being initiated, OECD figures show. There were 1,910 new MAPs in 2013, a 14% increase from 2012, when there were 1,678 new MAPs. North America accounted for most of this growth, with… – Continue reading
The Financial Accountability and Corporate Transparency (FACT) Coalition is calling on Congress to reject the tax extenders package that includes two wasteful offshore loopholes that allow U.S. companies to dodge billions worth of taxes. The tax extenders are a set of 54 temporary tax breaks, which are ostensibly designed to… – Continue reading
What Managers of U.S. and Non-U.S. Investment Funds Should Do Today FATCA1 went into effect on July 1, 2014 and will be phased in through January 1, 2017. During that period, varying compliance deadlines apply to different types of U.S. and foreign funds. Several important deadlines will occur in December… – Continue reading
The United States won’t give up its right to tax multinationals, and nations will go to war soon with countries like China on taxing rights, a US tax head says. Grant Thornton’s national managing partner of tax in the United States, Randy Robason, is in Australia this week for a… – Continue reading
Legislation seeking to stop U.S. corporations from moving their legal address abroad to avoid paying U.S. tax rates would raise significantly more revenue than originally thought, according to the official congressional scorekeeper. The Joint Committee on Taxation now says that Democratic legislation to curb inversions would raise $33.6 billion over… – Continue reading
Finance Minister Michael Noonan has said that Ireland’s tax regime is fully transparent and that the Government supports international tax reform efforts. Noonan told an Institute of International and European Affairs conference that the world of international taxation is changing rapidly. He pointed out that, “in an increasingly globalized world,… – Continue reading
Donald Grove, Contributing Editor, The Casey Report Implementation of the infamous Foreign Account Tax Compliance Act (FATCA) got underway in earnest on July 1, 2014. A cacophony of protests and warnings could be heard as that date approached, and it has only grown louder as more and more people realize… – Continue reading
Industrial & Commercial Bank of China Ltd. is marketing the largest sale of offshore yuan bonds as China pushes for the wider use of its currency as an alternative to the dollar in business and finance. The nation’s biggest lender by market value is offering about 12 billion yuan ($1.95… – Continue reading
The mayor of London’s refusal to comply with the Foreign Account Tax Compliance Act (FATCA) by paying his American taxes has been labelled “noble” by Nigel Green, chief executive at deVere. Green said Boris Johnson’s claim that it is “outrageous” for the US to tax expat American citizens, made in… – Continue reading
The Position to Date In July 2014, the Cayman Islands government issued The Tax Information Authority (International Tax Compliance) (United States of America) Regulations, 2014 (the “US FATCA Regulations”), The Tax Information Authority (International Tax Compliance) (United Kingdom) Regulations, 2014 (the “UK FATCA Regulations”) and the Guidance Notes on the… – Continue reading
The medical device manufacturer Medtronic has launched a USD17bn bond to finance part of its USD43bn corporate inversion acquisition of Ireland-based Covidien, in replacement of the cash held by its foreign subsidiaries that it was prevented from using following the United States Department of Treasury’s announcement of anti-inversion measures in… – Continue reading
The United States Internal Revenue Service (IRS) has provided guidance with respect to jurisdictions that have been treated as if they had a Foreign Account Tax Compliance Act (FATCA) intergovernmental agreement (IGA) in existence, although that agreement has remained unsigned. Under previous US transitional FATCA rules, IGAs reached in substance… – Continue reading
BVI Business Companies A1. What is the law on keeping and retaining records? Section 98 of the BVI Business Companies Act 2004 (BCA) has always provided that a BVI business company must keep records that: are sufficient to show and explain the company’s transactions; and will, at any time, enable… – Continue reading
Argentina and Belgium have separately accused HSBC bank’s Geneva branch of setting up a network of offshore accounts to help their citizens avoid paying billions of dollars in taxes. The Belgian charges were filed Monday and the Argentine charges were announced Friday. HSBC, formerly known as Hong Kong & Shanghai… – Continue reading
London & Capital’s US family office has seen its assets under management (AUM) surge by 226% to £750 million and managing director Daniel Freedman sees no signs of this growth slowing. The company has been a clear winner in this specialist field after many wealth managers and banks withdrew their… – Continue reading
The Cayman Islands currently has in place an intergovernmental agreement (IGA) with each of the United States and the United Kingdom and has passed domestic legislation to make compliance with the IGAs a matter of Cayman Islands law (Cayman FATCA). The Cayman Islands Tax Information Authority (TIA) issued Guidance Notes… – Continue reading
A Los Angeles tax attorney has received more than 6,500 pages from the Internal Revenue Service on the agency’s Offshore Voluntary Disclosure Program and how it trains its agents. The Brager Tax Law Group asked for the IRS documents through a Freedom of Information Act request in April filed on… – Continue reading
A Canada Revenue Agency crackdown on tax-free savings accounts has some people wondering whether TFSAs will always be shielded from a federal government that might be looking to generate cash. Here’s what will get your TFSA audited by the CRA Bank of CanadaCanada’s Taxman has an audit project targeting Canadians… – Continue reading
Samuel Wyly and the estate of his brother Charles will soon find out if they have to pay the U.S. regulators as much as $700 million after a jury found them liable for a 13-year scheme to use a web of offshore trusts to hide stock holdings and make illegal… – Continue reading
BIRMINGHAM, Mich., Dec. 2, 2014 (GLOBE NEWSWIRE) — via PRWEB – Foreign banking and foreign assets has been under intense scrutiny and the Foreign Tax Compliance Act (FATCA) passed in March 2010 has complexities many US taxpayers do not quite understand. As an account holder with foreign financial institutions taxpayers… – Continue reading
A Swiss banker accused of helping U.S. clients cheat on their taxes wants a judge to grant him bail without his having to appear first in a New York courtroom. Stefan Buck, who was Bank Frey & Co.’s head of private banking in Switzerland and an executive board member, was… – Continue reading
Complying with USA FATCA and UK/EU Data Protection Requirements The US Foreign Account Tax Compliance Act (FATCA), passed by Congress in March 2010, was finally implemented in July 2014. The Act makes the US the only large economy to tax its nationals on all of their earnings anywhere in the… – Continue reading
The refusal by the Mayor of London to pay his American taxes has been hailed as “noble” and “brave” by the CEO of independent financial advisor, deVere Group. The comments from Nigel Green, founder and chief executive of deVere Group, which operates in 100 countries and has $10 billion under… – Continue reading
Stock award is a popular method of rewarding talented and industrious employees. However, employees who render services across different jurisdictions may trigger a taxable presence in two or more jurisdictions. Such employees at times need to deal with the issue of double taxation on such benefits. A normal stock incentive… – Continue reading
The founder of a prominent wealth management firm says the Mayor of London, Boris Johnson, is noble and brave to refuse to pay his US tax bill under the Foreign Account Tax Compliance Act (Fatca). Johnson, who was born in New York, has a US passport as well as a… – Continue reading
It feels like FATCA has been around for years already, yet some companies are still coming to terms with its implications. However, as Kirsten Morel explains, impending deadlines are now creating a real sense of urgency It’s four years since US Congress enacted the Foreign Account Tax Compliance Act (FATCA),… – Continue reading
Pascal Soriot has said that controversial inversion tax deals, branded ‘unpatriotic’ by President Obama, are still taking place despite attempts to curb the practice AstraZeneca’s chief has said inversion deals used by US companies to escape high taxes at home are not over despite a major clampdown on the practice…. – Continue reading
Reminder: All Cayman Islands funds are likely to be caught by the FATCA legislation – regardless whether the fund has any USA investors. With the end of 2014 in sight, Cayman Islands funds must check for compliance with the obligations imposed under the FATCA / tax information sharing regime. For… – Continue reading
BARBADOS AND COLOMBIA have taken significant steps to improve the exchange of information on arrangements with the signing of a Tax Information Exchange Agreement (TIEA) recently. The Barbados-Colombia signing took place on November 25, in Washington D.C. Ambassador John Beale initialled the document on behalf of Barbados, while Colombia’s Ambassador… – Continue reading
Summary: The Australian Taxation Office’s treatment of bitcoin and other digital currencies could see businesses operating in the space close up shop or move offshore, a Senate Committee hearing has heard. Leon Spencer By Leon Spencer | November 27, 2014 — 01:15 GMT The Australian Taxation Office’s (ATO) decision to… – Continue reading
Refund Management Services (http://www.RefundManagement.com), the number one choice for Canada’s biggest winners for U.S. gaming and casino tax refunds, is issuing its congratulations to the World Series of Poker (WSOP) Main Event champion and weighing in on international gaming tax exemption laws. The WSOP is held annually in Las Vegas,… – Continue reading
With the Opposition targeting the government on the black money issue, Finance Minister Arun Jaitley told the Rajya Sabha on Wednesday that the identity of 427 foreign account holders has been established, of which 250 have admitted to having these accounts. Replying to a debate on the issue, Jaitley said… – Continue reading
Microsoft (NASDAQ:MSFT), once again finds itself deep in controversy and this time, on foreign shores. The company has been hit with a $140 million in taxes and interests presented by the Chinese government. This came to light in a rare incident of cross-border tax invasion. An article was published by… – Continue reading
The Ministry of Financial Services has floated for consultation a draft bill aimed at providing a framework for the implementation of the agreement which was signed on November 3, 2014 between The Bahamas and the United States (U.S.) to implement the provisions of the United States Foreign Account Tax Compliance… – Continue reading
The direct taxes international automatic information exchange bill harmonises the Estonian laws with the FATCA agreement. The FATCA agreement is based on the U.S. Foreign Account Tax Compliance Act (FATCA), which aims to collect information about persons obliged to pay tax in the USA, to prevent tax evasion. The bill… – Continue reading
Hal Hicks cleared his throat and addressed a roomful of peers in a midtown Manhattan auditorium. The topic: the tax-avoidance technique called inversion, in which a U.S. company claims a foreign legal address. Waving his hands back and forth as if tracing a pendulum’s swing, Hicks explained how four government… – Continue reading
Despite the Obama administration’s ongoing efforts to crackdown on American companies moving overseas to avoid U.S. taxes, the Treasury Department is still awarding millions of dollars in federal contracts to these companies. Tyco International for example, moved their firm from the U.S. to Bermuda in 1997 and currently operates out… – Continue reading
Love him or hate him, you have to say that Boris Johnson makes a very good point about FATCA. Having been hit with a US tax bill due to his unwanted dual citizenship, Johnson – who is as British as they come in all fairness – says he will not… – Continue reading
Bank Leumi Le Israel (LUMI) BM is close to a $400 million settlement of federal and state investigations into whether it helped Americans evade taxes, according to a person with knowledge of the matter. Under the proposed accord, Bank Leumi would pay about $270 million to the Justice Department and… – Continue reading
WASHINGTON–U. S. authorities on Wednesday approved Medtronic Inc.’s$43 billion merger with fellow medical device maker Covidien PLC after requiring the spinoff of a drug-coated catheter business. The Federal Trade Commission required Minneapolis-based Medtronic to sell off Ireland-based Covidien’s catheter business before completing the acquisition. That $30 million sale, to Colorado-based… – Continue reading
Reuters) – Only a handful of staff at Swiss banks have drawn on a $2.6 million (2 million pound) fund set up to help bankers and other employees who have fallen on hard times because of a U.S. crackdown on tax evasion through hidden offshore accounts. At least 25 people,… – Continue reading
Nov. 26 (Bloomberg) — Bank Leumi Le Israel BM is close to a $400 million settlement of federal and state investigations into whether it helped Americans evade taxes, according to a person with knowledge of the matter. Under the proposed accord, Bank Leumi would pay about $270 million to the… – Continue reading
On 21 November, the States of Guernsey Income Tax (ITO) published bulletin 2014/1 to update the most recent iteration of the draft guidance notes issued jointly by the crown dependencies on 28 July 2014 regarding the implementation under domestic law of FATCA-based reporting. The bulletin provides clarification in response to… – Continue reading
Strategies: Economists suggest removing easy avoidance VANCOUVER — Never mind that business-friendly tax policies – reforms like the dramatic reductions in federal and provincial corporate taxes over the past decade or so – enhance international competitiveness. This doesn’t impress the electorate when the benefits go mostly to the relative handful… – Continue reading
HSBC Holdings Plc (HSBA) will pay $12.5 million to settle claims that its Swiss private-banking unit solicited U.S. investors without being registered. HSBC Private Bank Suisse SA improperly amassed as many as 368 U.S. client accounts after starting to provide cross-border services more than 10 years ago, the SEC said… – Continue reading
A deal between Stryker Corp. (SYK) and Smith & Nephew Plc (SN/) makes as much sense now as it did six months ago. It just might be tougher to pull off. Stryker is considering structuring the takeover as a tax inversion, allowing the Kalamazoo, Michigan-based company to move its legal… – Continue reading
Mr. Eduardo Morgan of Morgan and Morgan Group spoke to United World to clear up misconceptions about Panama’s tax laws. Panama is not a tax haven. The country has none of the aspects that, according to Colombia, identify a tax haven. Our tax legislation does not have any law that… – Continue reading
Canadian taxpayers with an interest in a partnership that holds specified foreign property (as defined in subsection 233.3(1)) may face uncertainty when assessing their form T1135 (“Foreign Income Verification Statement”) filing obligations. Depending on the partnership’s structure, either (1) the taxpayer may be required to file form T1135 in respect… – Continue reading
Martin Lock was formerly the top withholding-tax specialist at the Tax Office, a role that encompassed oversight of profit shifting by multinationals. He is one of many former officers who have voiced their concerns to Fairfax Media about the challenge of arresting the slide in tax receipts from multinational companies… – Continue reading
The central bank resumed its foreign-exchange support through selling the US dollar to the commercial banks after nearly two years and a half to keep the market stable, officials said. As part of the move, the Bangladesh Bank (BB) sold US$45 million at market rate to five commercial banks directly… – Continue reading
