As the Irish government considers closing an infamous tax loophole for corporations, Wall Street has been scrambling to gauge the effect on the pharmaceutical industry. So far, the prognosis seems that damage will largely be minimal. Known as the ‘Double Irish,’ the loophole allows companies to send royalty payments for… – Continue reading
What is FATCA? The Foreign Account Tax Compliance Act (“FATCA”) is a complex reporting and withholding regime enacted by the U.S. government in March, 2010 that is expected to become operational on July 1, 2014. FATCA was designed to combat tax evasion by U.S. taxpayers holding assets through non-U.S. financial… – Continue reading
AbbVie Inc. (ABBV) may scrap its planned 32.4-billion-pound ($51.5 billion) deal for Dublin-based drugmaker Shire Plc (SHP), in what would be the biggest casualty of the U.S. crackdown on so-called tax inversions. Shire stock plunged the most in 12 years after North Chicago, Illinois-based AbbVie said its board will meet… – Continue reading
Ireland’s hard-pressed taxpayers are set for the first easing of austerity in seven years when tax cuts are announced in tomorrow’s payback budget. October 14 2014 will go down as a watershed in a painstaking economic recovery, four years since a banking collapse bankrupted the State and less than a… – Continue reading
A former banker at UBS has been found guilty of handing over protected Swiss bank account data to the US, according to a penalty order issued by the Swiss prosecutors’ office. According to the order, the banker was found to have breached Swiss data privacy laws but not its banking… – Continue reading
A University of the West Indies Professor believes that the global attention being focused on offshore financial centres has come about because the international community remains concerned about money laundering and among other things, the financing of terrorism. Dr. Don Marshall who heads up the Sir Arthur Lewis Insitute for… – Continue reading
KUWAIT, Oct 15 (KUNA) — The US Foreign Account Tax Compliance Act (FATCA) will help the US put pressure on foreign banks to declare the accounts of their US clients abroad, said a leading Audit firm specialist. Kuwait was one of the first nations to have stepped up and have… – Continue reading
On July 21, 2014, the governments of Canada and the United Kingdom signed the fourth protocol (Protocol) amending the Convention between the Government of Canada and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion… – Continue reading
Two Brazilian companies are raising their bid for banana company Chiquita to approximately $658 million. Investment firm Safra Group and juice company Cutrale Group said Wednesday that they are now offering $14 per Chiquita share, up from their previous bid of $13 per share. That’s an approximately 6 percent premium… – Continue reading
October 15: The IRS posted a draft version (as of October 14, 2014) of the general instructions for certain information returns—Forms 1097, 1098, 1099, 3921, 3922, 5498, and W-2G—for the 2015 tax year. The 29-page draft instructions [PDF 500 KB] note that new for 2015 are the following items: FATCA… – Continue reading
IN ONE of the most remembered scenes of the film Casablanca, police chief Louis Renault orders the close of Rick’s Cafe when he is “shocked, shocked” to learn that there was gambling going on in the establishment. Seconds later a waiter presents Renault with his winnings from roulette. Panama was… – Continue reading
INTRODUCTION In a recent publication1, the LMA have announced a change of approach to the allocation of FATCA withholding risk in certain of their precedent facility agreements. Previously, the LMA had not adopted a definitive stance in this area, recognising that borrowers and lenders may wish to allocate the risk… – Continue reading
Minister Findlay meets with Indian counterpart during trade mission to India DELHI, INDIA–(Marketwired – Oct. 15, 2014) – Canada Revenue Agency The Honourable Kerry-Lynne D. Findlay, P.C., Q.C., M.P., Minister of National Revenue, met today with Nirmala Sitharaman, India’s Minister of State for Commerce and Industry and Minister of State… – Continue reading
After announcing Ohio-based Steris Co.’s plans to become British for tax purposes on Monday, CEO Walter Rosenbrough later said on a conference call, “We’re not typically users of aggressive tax policies and I don’t think we are here.” That’s his story, and he’s sticking to it. But even a cursory… – Continue reading
Blue-ribbon corporations are deserting our country “to avoid paying taxes but expect to keep receiving the full array of benefits that being American confers, and that everyone else is paying for,” Fortune magazine reports. That’s right, Fortune wrote it; not Pravda. In a scathing article titled “Positively Un-American” by Allan… – Continue reading
Wealth inequality is growing worldwide, according to a new report by Credit Suisse. A greater share of wealth is being held by a smaller number of ultra-rich families worldwide as larger inheritances, family trusts, and similar arrangements to avoid taxes help the ultra-wealthy gain a greater portion of total capital… – Continue reading
On May 9, 2014, the Tokyo District Court reversed a large tax that had been imposed on a large U.S. multinational’s Japanese holding company (“Japan HoldCo”). Under the Japanese Corporate Tax Law, if a shareholder returns shares to an issuing company (i.e., the issuing company acquires treasury shares), a portion… – Continue reading
The presentation on October 17, 2014 will discuss how FATCA has changed the world and provide perspectives for financial institutions and expatriates SHANGHAI, China, Oct. 14, 2014 (GLOBE NEWSWIRE) — via PRWEB – As of June 30, 2014 China has signed Model 1 IGA (Intergovernmental Agreement) in cooperation with FATCA… – Continue reading
A million Canadians are migrating to the southern United States for the winter. Before you cross the border, buy travel medical insurance. Learn how U.S. income tax rules affect you if you stay in the U.S. for more than four months. Buy travel medical insurance coverage before leaving Canada for… – Continue reading
A vast majority of companies headquartered in the United States expect increased scrutiny of their transfer pricing practices in the short-term as a result of the Organisation for Economic Cooperation and Development’s (OECD’s) base erosion and profit shifting (BEPS) project. A recent EY survey, Connecting The Dots, concluded that 30… – Continue reading
In this issue: An Introduction to Double Taxation Avoidance Qualifying for DTA Benefits in China Applying for DTA Benefits in China Rising operational costs in China mean that business owners must be alert to all possible means of maximizing the performance of their China-based investments. As one such measure, the… – Continue reading
TORONTO , Oct. 2, 2014 /CNW/ – Aggressive international corporate tax avoidance by multinational corporations has become the subject of intense political scrutiny. U.S. politicians have called out some American multinationals, including Apple, Amazon, Starbucks and Google, for relocating profits abroad to avoid U.S. taxes. More recently, politicians accused Burger… – Continue reading
It appears as if Irish eyes won’t be smiling on U.S. corporations soon. The government of Ireland is set to change its tax code tomorrow to eliminate some of those loopholes that American companies have come to love. Among the targets– the so-called “double Irish” tax break. Both the U.S…. – Continue reading
The U.S. government’s attempt to prevent companies from seeking a tax address outside the country hasn’t stopped Steris Corp. (STE) The Mentor, Ohio-based provider of hospital sterilization products and services announced today that it will buy the smaller Synergy Health Plc (SYR) and establish the combined company’s tax address to… – Continue reading
The drugmaker AbbVie said Tuesday it is having second thoughts about its deal to combine with British counterpart Shire after the U.S. government created new limitations on the tax benefits of incorporating overseas. North Chicago, Illinois-based AbbVie said it notified Shire that its board intends to reconsider the recommendation it… – Continue reading
(Reuters) – Former UBS bank executive Raoul Weil was the mastermind of the Swiss bank’s illegal offshore operations that helped thousands of Americans evade taxes, prosecutors said at the start of his federal trial on Tuesday. Weil, 54, was the third-highest ranked executive at the Zurich-based wealth management firm and… – Continue reading
(Reuters) – Luxembourg agreed on Tuesday to end its bank secrecy rules from 2017, yielding to a decade of pressure from Germany and the United States and marking a breakthrough in global efforts to reduce tax evasion. Luxembourg, whose banks hold deposits worth 10 times the nation’s annual economic output,… – Continue reading
Oct. 10 — Withholding agents and foreign financial institutions will be given extra time to comply with requirements for determining an account holder’s foreign status, the IRS said. The Internal Revenue Service, in Notice 2014-59 issued Oct. 10, said withholding agents, foreign financial institutions and payers have until Jan. 1,… – Continue reading
It is said that Argentina faces an economic and political crisis every 10 years. Whenever a crisis arises, Argentinians’ right of ownership is at risk. Devaluation, asymmetric pesification and the current foreign exchange restrictions are a few examples of the challenges we face. What’s more, according to a recent OECD… – Continue reading
Fund managers dealing with funds in Model 1 IGA countries must start focusing now on the application of FATCA to these funds. The U.S. Foreign Account Tax Compliance Act (“FATCA”) is becoming a reality. Fund managers around the world over are facing requests from U.S. withholding agents for FATCA documentation… – Continue reading
In the history of the old west when gun fighters survived a gun fight they might put a “notch” in their pistol as a badge of honor. Well the U.S. Department of Justice can put another notch in its weapon of choice, threat of prosecution” because Deutsche Banks’ Swiss unit… – Continue reading
The IRS updated its streamlined offshore compliance program to provide procedures taxpayers residing both inside and outside the United States should use to participate in the program. The streamlined offshore compliance program is for taxpayers whose failure to comply with requirements to report offshore assets is nonwillful. It is designed… – Continue reading
The IRS announced its intention in Notice 2014-59 to amend temporary regulations it issued under the Foreign Account Tax Compliance Act (FATCA) on March 6, 2014, to modify the effective dates of (1) the standards of knowledge that apply to a withholding certificate or documentary evidence to document a payee… – Continue reading
A failed property development is linked to a tax haven company that triggered an alleged money laundering probe into a wealthy businessman. Albany Heights, more than 400 homes proposed to be built on Auckland’s North Shore, was marketed as an “investors’ dream” but companies connected to the project collapsed with… – Continue reading
Inter vivos and testamentary trusts are used frequently in Canada to implement a variety of estate and tax planning strategies. Over the past few years, however, amendments to Canada’s Income Tax Act (the ITA), and case law have altered the effectiveness of the use of trusts in certain circumstances. In… – Continue reading
Cash in companies run by businessman Declan Conway was moved to two offshore companies Shareholders in two Business Expansion Scheme (BES) companies run by businessman Declan Conway have written to him demanding to know why almost €1.6 million was transferred from both firms to a number of offshore entities. Between… – Continue reading
Foreign investors, not to mention the country itself, need a more stable and predictable regime Foreign companies are depressingly used to run-ins with the Indian taxman. A string of groups, including Vodafone, IBM and Cairn Energy, have been hauled into the dock for not paying their dues in recent years…. – Continue reading
India may have to wait longer for joining “selected” countries with whom Switzerland plans to do automatic exchange of information on tax matters, even as Indian and Swiss officials will meet soon to iron out their bilateral arrangements on suspected tax evasion cases. Switzerland has started a process for putting… – Continue reading
Finance Minister Boris Lalovac has expressed his satisfaction with the numerous meetings he held during his visit to the United States where he attended the annual meetings of the World Bank and the International Fund earlier this week. During their visit to Washington, representatives of the Finance Ministry and the… – Continue reading
The Internal Revenue Service announced changes to one of its limited-amnesty programs for U.S. taxpayers with undeclared offshore accounts. The revisions are to the “streamlined procedure,” which was announced in June and is for taxpayers who weren’t intentionally hiding money abroad. Participants in the streamlined program who live in the… – Continue reading
ZURICH (Reuters) – The U.S. Department of Justice (DOJ) is seeking “total cooperation” from Swiss banks in a draft agreement aimed at allowing the banks to make amends for aiding tax evasion by wealthy Americans, a Swiss newspaper reported on Saturday. About 100 Swiss banks signed up to work with… – Continue reading
Ireland’s finance ministry officials are weighing phasing out a tax device used by multinational companies including Google Inc., according to a person with knowledge of the matter, as the European Union looks into the practice. Ireland is considering whether to eliminate a technique known as the “Double Irish,” which allows… – Continue reading
* Dublin set to change tax residency rules in Oct. 14 budget * Companies already in Ireland to be given time to adjust * Measures due to be signed off by cabinet next Tuesday By Padraic Halpin DUBLIN, Oct 10 (Reuters) – Ireland is set to announce legal changes next… – Continue reading
This week brings a wealth of news in the FATCA arena, which we summarize in today’s post. First, former acting IRS Commissioner Steven Miller speaks out against FATCA and suggests that the benefits of the new information reporting regime imposed by FATCA may not outweigh its costs. An article published… – Continue reading
For a large majority of the ever-increasing number of British expatriates with pensions which remain in the UK, a Qualifying Recognised Overseas Pension Scheme (QROPS) provides a viable and sometimes integral role in retirement planning. This counts for those now residing in Europe, Asia and the Middle East, however arguments… – Continue reading
Two Canadian women mounting a legal challenge to FATCA have expanded their action to include the Minister of National Revenue as a defendant. Gwen Deegan, a graphic designer from Toronto, and Ginny Hillis, a retired lawyer from Windsor, claim the Canadian federal government doesn’t have the constitutional authority to comply… – Continue reading
TORONTO, Oct. 10, 2014 /CNW/ – The Global Citizen Forum 2014, hosted in Toronto, proved to be a launch platform for significant initiatives. On October 3, 2014, its second day, in front of more than 260 delegates, Mykolas Rambus, CEO, Wealth-X, announced the establishment of the Global Residence and Citizenship… – Continue reading
Further to our previous bulletin, following the Notification Ceremony on 11 September the Tax Information Exchange Agreement (TIEA) between the Government of Japan and the Government of the British Virgin Islands will come into effect on 11 October 2014. Following the coming into force of the TIEA both Japan and… – Continue reading
The Hackett Group predicted in a 2012 report that this year would be the start of an eight-year death of offshoring to India Yahoo! just made about $9 billion in cash from Alibaba Group’s initial public offering, and investors are licking their lips at the thought of how Marissa Mayer… – Continue reading
Mission Hills businesswoman Cheryl Womack is scheduled to appear in federal court in Kansas City on November 12 for a change of plea hearing in her criminal case. Womack had earlier entered a not guilty plea to charges of avoiding income taxes and lying to investigators. (Update, 9:03 p.m) It’s… – Continue reading
