Changes to partnership taxation are to go ahead with draft legislation now published, effectively clarifying the tax treatment for partnerships to ensure that the principle of taxing the beneficiary of partnership profit applies and to prevent a double reporting burden on investment partnership This measure makes changes to the income… – Continue reading
Nonresident Alien NRA tax withholding is applicable to U.S sourced income paid to foreign person and does not apply to payments made to U.S. persons. Foreign persons include nonresident alien individual, foreign partnerships, foreign corporations, foreign estates, and foreign trusts. The tax generally must be withheld from the payment made… – Continue reading
On 29 October 2016, the Austrian Ministry of Finance provided interesting guidance on the tax consequences of an alienation of a participation in a Hungarian partner- ship by an Austrian partnership consisting of German partners. The case revolved around an operative Austrian partnership (GmbH & Co KG) with German resident… – Continue reading
In Depth There is mixed news for affected individuals, including far-reaching changes relating to offshore trusts and a further wait (possibly until March 2017) for the rest of the draft legislation. The following are highlights from the government’s response and the draft legislation. Deeming Provisions Deemed Domiciled: Non-doms will become… – Continue reading
Recent CRA comments at the May 2014 IFA international tax seminar1 and a subsequently released CRA technical interpretation2 highlight anomalies in the application of subsections 92(4) and (5) of the Income Tax Act (Canada) (the “Act“).3 These provisions address the situation where shares of a foreign affiliate are held by… – Continue reading
Oct. 7 — The IRS offered two-pronged guidance on the effective dates of agreements for entities that apply on or after April 1 to be withholding foreign partnerships or withholding foreign trusts under the Foreign Account Compliance Act. In general, the Internal Revenue Service said Oct. 7, entities that apply… – Continue reading
VAM Funds has entered into a partnership with UK-based Close Brothers Asset Management (CBAM) to meet a rising demand for discretionary fund management services from international advisers. The tie-up will see three of CBAM’s products, which are normally available only in the UK, become available internationally through VAM Discretionary Funds…. – Continue reading
Avago Technologies Ltd.’s pending takeover of Broadcom Corp. taps an arcane tax structure that has being dusted off amid a rise in cross-border mergers. Avago said it is prepared to offer Broadcom shareholders special partnership units that would defer any taxes triggered by the $37 billion tie-up, which was announced… – Continue reading
It is not uncommon for affluent families from certain countries to maintain offshore structures to hold a portion, and often times a significant portion, of their wealth. The reasons for holding assets outside of their country of residence are many, and such assets are frequently held in foreign corporations. As… – Continue reading
Living in Central Massachusetts, had I the vision of Sarah Palin, who can see Russia from her home in Alaska, I could look north and see New Hampshire on the right and Vermont on the left. It is perhaps an apt metaphor. New Hampshire with its “Live Free Or Die”… – Continue reading
Center City-based Morgan Lewis, the largest law firm in the U.S. in terms of lawyers based domestically, is growing again, this time overseas. The firm said Sunday it was combining with the Stamford Law Corp., an 80-lawyer firm based in Singapore, a booming commercial hub and island nation with a… – Continue reading
VietNamNet Bridge – A lot of private enterprises in Vietnam are shoring up offshore investment activity, particularly in regional markets, to make the most of material sources and tap into opportunities presented by these growing markets. An expert of Vinamilk tests the quality of powdered milk made by the company… – Continue reading
CHINA China Releases GAAR Administrative Measures Courtesy of Mr Glen Wei, an attorney at law, certified tax adviser, and CPA based in China.China’s State Administration of Taxation (SAT) on December 12 issued Decree 32 (dated December 2) introducing administrative measures for applying the domestic general anti-avoidance rule to special tax… – Continue reading
IE Singapore said it helped 28,000 companies with their overseas ventures last year, up 5 per cent from 2013. SINGAPORE: More Singapore companies are expanding their footprints overseas. In its latest annual Year-in-Review released on Monday (Feb 16), IE Singapore said local firms that make an overseas foray are able… – Continue reading
SAS supports Dubai Islamic Bank with Anti-Money Laundering solutions Dubai – SAS, the leader in business analytics software and services, announced its collaboration with Dubai Islamic Bank ( DIB ) to help prevent money laundering among the bank’s customers. SAS will support the bank with Anti-Money Laundering (AML) solutions that… – Continue reading
Many factors influence a foreign buyer’s decision to purchase residential real estate in the United States. Generally, most of these decisions tend to be driven by concerns over political and economic uncertainty in the buyer’s home country. Most foreigners do not leave their home country, family, and friends for trivial… – Continue reading
Five Senate Democrats urged the IRS to put harsher rules into place to stop the offshore tax deals known as inversions. The five Democrats said the recently finalized deal between Burger King and the Canadian doughnut chain Tim Hortons – perhaps the most prominent in the recent wave of cross-border… – 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
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
The concept of base erosion and profit shifting (BEPS) has been debated at various international forums following discussions at the G20 Finance Ministers and Central Bank Governors meeting and the G20 Heads of State summit in Russia last year. The Organisation for Economic Co-operation and Development’s (OECD) BEPS Action Plan… – Continue reading
It’s a surprise to many people that MLPs generate taxable income in retirement plans requiring a tax filing and payment of taxes. Traders and investors are interested in using their IRA and other retirement plan accounts (collectively referred to as “retirement plans”) for making “alternative investments” in publicly traded master… – Continue reading
With U.S. interest rates remaining at historic lows, yield-starved investors have continued allocating massive amounts of capital to exchange traded products offering exposure to master limited partnerships (MLP). So popular are MLP ETFs and exchange traded notes (ETNs) that the asset class has not endured a month of net outflows… – Continue reading
High Court refuses special leave application in capital gains tax dispute The High Court has refused the special leave application by the taxpayer in a case involving the liability to capital gains tax (CGT) of a ‘limited partnership’ formed in the Cayman Islands. The application for special leave followed the… – Continue reading
Minnesota Democrat invested in opponent’s tax-inverting company as son’s private equity firm opens shop in Caymans Sen. Al Franken (D., Minn.) is hoping to saddle his Republican challenger with Mitt Romney-esque charges of “vulture corporatism,” but his own investment activities, and those of his son, could blunt those attacks with… – Continue reading
The European Union expanded its crackdown on illegal tax breaks, ordering Spain to recover money from companies that benefited from rules encouraging merger activity outside of the country. The European Commission said the Spanish measures unfairly rewarded companies for buying stakes in foreign competitors. Telefonica SA (TEF) last year lost… – 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
High quality global journalism requires investment. Please share this article with others using the link below, do not cut & paste the article. See our Ts&Cs and Copyright Policy for more detail. The UK tax authority is using new powers to turn the screw on investors in alleged avoidance schemes…. – Continue reading
Take That pop star and former X Factor judge Gary Barlow has apologised to his fans for his involvement in an illegal tax avoidance scheme. Barlow has posted an open message on Twitter saying he is sorry for any offence he may have caused and stating he has appointed new… – Continue reading
A cynical tax avoidance scheme which “abused the reliefs” offered for research into life-saving vaccines to claim back £77m, has been rejected at a second tribunal. HMRC said investors in the scheme used a Jersey registered limited partnership which claimed to be involved in creating and exploiting intellectual property from… – Continue reading
On August 26, Burger King announced that it entered into an agreement to acquire Tim Hortons, Inc., the Canadian coffee-and-doughnut chain, in a transaction that will be structured as an “inversion” (i.e., Burger King will become a subsidiary of a Canadian parent corporation). The deal is expected to close in 2014… – Continue reading
The Internal Revenue Service has updated the Withholding Foreign Partnership and Withholding Foreign Trust agreements as part of the process of implementing the Foreign Account Tax Compliance Act, or FATCA. FATCA, which was included as part of the HIRE Act of 2010, requires foreign financial institutions to report on the… – Continue reading
Artur Bugsgang, partner at leading Danish law firm LETT looks at Denmark’s tax advantages. Denmark currently ranks fifth in the world in their ease of doing business index. The country is significantly less bureaucratic than the majority of its European neighbours, especially in regard to establishing and operating companies. Despite… – Continue reading
THE INTRODUCTION of changes to the taxation of limited liability partnerships will go ahead on 6 April 2014 despite calls from the House of Lords Economic Affairs Committee and practitioners for 12 months’ delay to the measures. The lords recommended the easement to be put in place until 2015 in order… – Continue reading
New anti-avoidance legislation introduced by HMRC aimed at combating perceived tax evasion in partnerships (including LLPs) takes effect on 6 April 2014. Many property owners could be caught out by these new rules. Including a company in a partnership has become an increasingly popular structure for holding properties, which is… – Continue reading
Peers have attacked the taxman for being “unaware” of the scale of company profit shifting and raised concerns about the amount of tax that has been lost as a result. HM Revenue and Customs allowed the tax minimising practice to become “embedded as acceptable tax planning”, according to the House… – Continue reading
Members of limited liability partnerships still face uncertainty – and the prospect of big, unexpected tax bills – under measures aimed at curbing tax avoidance, business tax advisers warned last week. New rules aimed at curbing the abuse of partnership status by ‘disguised employees’ for tax reasons come into force… – Continue reading
New measures to combat alleged tax avoidance by limited liability partnerships will come in to force on 6 April despite protests from the legal profession and the City, HM Revenue & Customs has confirmed. A revised technical note and guidance on the ‘Salaried members rules’ appeared on the HMRC website… – Continue reading
