Category: Offshore

Withholding tax on masala bonds set at 5%

To buy corporate bonds one needs to be a registered FPI but to buy masala bonds registration is not compulsory due to which these bonds will have good demand The withholding tax on rupee-denominated offshore bonds (‘masala bonds’) by domestic issuers has been set at five per cent, at par… – Continue reading

Tax Havens Are Turning The U.S. Into An Unequal Aristocracy

French economist Gabriel Zucman, a protégé of Thomas Piketty, has a new book outlining how to avoid this. To Gabriel Zucman, protégé of rock star French economist Thomas Piketty, the United States is starting to look a lot like Europe in the late 1800s. “There’s been this great reversal where,… – Continue reading

US Justice Department Announces Two Banks Reach Resolutions Under Swiss Bank Program

The Department of Justice announced today that Migros Bank AG (Migros) and Graubündner Kantonalbank (Graubündner) have reached resolutions under the department’s Swiss Bank Program. These banks will collectively pay penalties totaling more than $18 million. “It is abundantly clear from the agreements reached to date that for decades, many foreign… – Continue reading

The Rollout of FATCA Is Being Delayed to Help Foreign Banks. Tax Attorney Rob Wood Explains

The Foreign Account Tax Compliance Act, passed in 2010, is a tool devised to help the U.S. locate funds of U.S. citizens being held in foreign banks. (See this earlier FATCA report on LBN). The law requires foreign banks to report data about accounts owned by U.S. citizens to the… – Continue reading

Should Companies Have To Pay Taxes?

Reading companies’ annual reports to the Securities and Exchange Commission is a reliable cure for insomnia. Every so often, though, there is a significant revelation in the paperwork. Last year, one of the most important revelations came from Microsoft’s filings, which spotlighted how the tax code allows corporations to enjoy… – Continue reading

US Signs Competent Authority Agreements With UK, Australia

The Internal Revenue Service has entered into landmark Competent Authority Agreements with authorities in Australia and the United Kingdom to support the implementation of the Foreign Account Tax Compliance Act (FATCA). The US has signed FATCA intergovernmental agreements with both of these nations. Each of these agreements provides that Competent… – Continue reading

The Common Reporting Standard: Automatic Information Exchange Goes Global

Automatic exchange of information for tax law enforcement purposes started first in Europe with the EU Savings Tax Directive, went international with the US Foreign Accounts Tax Compliance Act, and, from 2017, will go global with the recently-agreed Common Reporting Standard, the subject of this feature. Introduction To The Common… – Continue reading

More tax laws planned

Myanmar plans to introduce more laws and regulations to increase its tax income over the coming years, sources said. The Internal Revenue Department (IRD) currently sets polices under the Myanmar Tax Law and the Union Tax Law. Sources at the IRD said they will issue further notifications, if required, to… – Continue reading

IRS Targets Secret Offshore Bank Accounts

US taxpayers with secret bank accounts in Belize are about to feel the full force of the Internal Revenue Service (IRS). A federal court in Miami has issued summonses against Belize Bank International and Belize Bank aiming to identify accounts controlled by US taxpayers from 2006 until 2014. Belize banks… – Continue reading

Foreign Firms Get Retrospective Relief From Controversial Tax

In a big relief to foreign firms, the government on Thursday exempted them from paying minimum alternate tax (MAT) retrospectively from April 2001, provided they did not have a permanent establishment in India. Tax experts said that this government move ends a lot of uncertainty on the controversial MAT issue… – Continue reading

Centre to exempt foreign firms covered by double taxation treaty

IT Act will be amended with retrospective effectto exempt foreignfirms from MAT In a big relief to foreign firms, government on Thursday said the Income Tax Act will be amended with retrospective effect to exempt from minimum alternate tax (MAT) the overseas companies that covered under double taxation avoidance agreements… – Continue reading

Austria: Successful Appeal Regarding Taxation Of Foreign Interest Income

On 26 February 2015, the Austrian Supreme Administrative Court decided in favor of an appeal filed by WOLF THEISS for a client who received tax exempt interest income from other countries. An Austrian taxpayer received interest from Greek, Brazilian and Argentinian government bonds between 2003 and 2007. According to the… – Continue reading

Taxation issues concerning high networth individuals

What constitutes an HNI is a tricky question? In general parlance, HNIs are understood to be the individuals with ultra-high networth with deep pockets having surplus investible funds. As per the Credit Suisse global wealth report, currently India is home to around 1,500 ultra-high networth individuals with wealth of at… – Continue reading

Barclays Bank Seychelles discontinues offshore banking services

(Seychelles News Agency) – The Central Bank of Seychelles (CBS) says it is engaging with Barclays Bank Seychelles to ensure that clients have sufficient time to shift their deposits in their offshore bank accounts, following a recent decision by Barclays to discontinue its banking services for non-residents in foreign currencies…. – Continue reading

Xabi Alonso Denies Tax Fraud : Case Follows Mascherano’s €1.5m Back-Payment

Former Real Madrid midfielder Xabi Alonso has denied that he is guilty of defrauding Spain’s tax authorities. The country’s revenue services claim that Alonso – currently with Bayern Munich – defrauded the state by having his image rights paid to companies based in overseas countries. A complaint has been lodged… – Continue reading

Spanish cops cracking down on Irish Costa criminal’s ‘black money’

For years it has been the currency of the Costa, as criminals simply can’t do business without a bag of ‘black money’. Judges, solicitors and local councils have been prone to their cut on every transaction and complex property transfer for decades. However, now the Spanish are finally cracking down… – Continue reading

What NRI investors need to take note of in the latest IRS Notice

There are many Non-Resident Indians (NRIs) from the US that are fearful of being involuntary discovered through the impending Foreign Account Tax Compliance Act (FATCA) disclosures of their Indian accounts by their foreign banks. The US Internal Revenue Service has issued a notice extending the time under which certain transitional… – Continue reading

Bad Bad, Bad Penalty, Bad OVDP Policy

There are now 50 foreign financial institutions on the IRS list of “bad banks” The list is published at the following link: http://www.irs.gov/Businesses/International-Businesses/Foreign-Financial-Institutions-or-Facilitators If a U.S. taxpayer has or had a foreign financial account that is unreported for FBAR purposes at any of the foreign financial institutions on the “bad… – Continue reading

MAS stance on ARFP tax tipped to force change

Industry welcomes move by Singapore’s financial regulatory authority to go public with tax criticism of ARFP passport scheme. They say it could force Australia and Korea into a corner. Industry figures have welcomed a move by the Monetary Authority of Singapore (MAS) to go public with the reasons it declined… – Continue reading

If You See a Little Piketty in This Tax-Haven Book, That’s Fine

Look out, Thomas Piketty. Here comes Gabriel Zucman. With a slim new book that has the feel of Piketty’s bestselling “Capital in the 21st Century,” Zucman, a baby-faced 28-year-old University of California-Berkeley economist, is taking his own swing at global capitalism. His target: tax havens that he says hide $7.6… – Continue reading

Luxembourg: Luxembourg Leads On FATCA Transparency

The Grand Duchy of Luxembourg is ranked third in the world for the number of financial institutions per-country that have now signed up to report under the Foreign Account Tax Compliance Act (FATCA). IRS figures report 8,525 Luxembourg firms have registered with the FATCA portal, and the total is surpassed… – Continue reading

Davis homes in on offshore tax evasion

High-net-worth, tax-evading South Africans will soon have nowhere to hide, because in future income tax returns will specifically ask them to declare if they have offshore trusts, or directly or indirectly control an offshore trust, Judge Dennis Davis, the convener of the Davis Tax Committee, says. If the South African… – Continue reading

The NZ registered financial service provider that tells potential clients of NZ bankrupts ‘who still live in mansions & drive Ferraris owned by their trusts’

A small office shared with three other companies deep in the bowels of the Outsource IT Tower on Auckland’s Khyber Pass Road opposite a reservoir isn’t necessarily where you’d expect to find the global headquarters of a financial service provider that claims to be following in the footsteps of three… – Continue reading

U.S. tax-evasion probe expands to Belize

U.S. authorities have targeted Belize-based banks in a new expansion of their hunt for Americans suspected of evading taxes by hiding income and assets in offshore accounts. A federal court in Miami on Wednesday approved special “John Doe” legal summonses seeking information about U.S. taxpayers who may hold undeclared accounts… – Continue reading

American Dream Relocates to Bermuda, Says Fishman, Blaming Taxes

Jay Fishman, who built New York-based Travelers Cos. into one of the world’s biggest insurers, lamented that disparities in tax rates are pushing established rivals and industry newcomers outside the U.S. Over the past 15 years or so, “we’ve counted 10, 12, maybe even 15 Bermuda-based startups that ultimately became… – Continue reading

Chevron tax filings challenged by US tax authorities, report says

Chevron’s tax filings face repeated challenges from the United States and other global tax authorities, according to a new union-backed report that calls on world governments to crack down on the energy giant’s alleged profit-shifting tactics. The world’s largest trade union body, the International Trade Union Confederation (ITUC), has called… – Continue reading

Blackstone buys back Intelenet for Rs 2,500 crore

BANGALORE: The world’s largest PE firm Blackstone has acquired the Indian and most of the offshore business process outsourcing (BPO) operations of London-headquartered Serco Plc – formerly Intelenet — for Rs 2,558 crore, or $383 million. This marks Blackstone’s biggest deal in India till date, and a rare instance of… – Continue reading

British Expats Face FATCA Account Closures

Banks are threatening to close accounts of British expats living in the USA if they fail to complete piles of paperwork to comply with the Foreign Account Tax Compliance Act (FATCA). Millions of US expats worldwide are already caught by the law which requires foreign financial institutions to supply details… – Continue reading

HK Report Suggests Tax Incentives For Booking Centers

Hong Kong’s Financial Services Development Council (FSDC) has released a report setting out recommendations on policies, including tax measures, to enhance the city’s role as a regional and global financial booking center. Financial institutions utilize such centers to enter into contracts for financial products, undertake primary obligations for delivery or… – Continue reading

“United States: New Jersey Tax Court Finds Royalty Company Must File And Pay Even Though Related Entity Paid Tax On Same Income “

In a decision released August 14, the Tax Court of New Jersey ruled that an intangible holding company with no physical presence was required to file a New Jersey corporation business tax (CBT) return and pay the related tax due based on its income.1 No relief was available to the… – Continue reading

Practice Transfer Pricing Cause Indonesia Loss Rp 100 T

JAKARTA – Indonesian Institute of Accountants (IAI) considers Indonesia may not completely avoid the impact of the practice of transfer pricing. Therefore, Indonesia must prepare regulatory and law enforcement strong to protect the interests. The practice of transfer pricing is one of the activities of neo-liberalism. According to the National… – Continue reading

Private bank M&A inevitable amid pressures: analyst

Consolidation in Europe’s private-banking industry is inevitable as pressure from clients and regulators increases costs, McKinsey & Co said in a study published yesterday. Pressures on profit margins could force private banks to cut costs and review the number of booking centers they operate, the New York-based consultancy said. The… – Continue reading

PBOC Easing Cushions China Issuers From Fed Hike Volatility

Stimulus unleashed by China’s central bank will cushion Chinese companies –the region’s biggest dollar debt issuers — from a potential Federal Reserve interest rate increase, making cheaper yuan funds available. Five interest rate cuts by the People’s Bank of China since November and rules to relax yuan bond issuance onshore… – Continue reading

Brazil’s BTG Open to More Swiss Private-Banking Acquisitions

(Bloomberg) — Grupo BTG Pactual, the only publicly traded investment bank in Brazil, said it’s willing to consider more acquisitions in Switzerland after completing the purchase of BSI, the Swiss private-banking unit of Assicurazioni Generali SpA. “We are looking. We are always looking,” Renato Cohn, a BTG partner and member… – Continue reading

Interactive map of the swathes of England owned by offshore tax-dodgers

Whole regions of England are now owned by holding companies in tax-havens “from Panama to Luxembourg, and from Liechtenstein to the South Pacific island of Niue.” Private Eye’s interactive map mines Land Registry information to find the properties owned by “companies, arms dealers, oligarchs, money launderers and others who use… – Continue reading

Bank La Roche & Co AG Reaches Resolution Under US Justice Department’s Swiss Bank

The Department of Justice announced today that Bank La Roche & Co AG has reached a resolution under the department’s Swiss Bank Program. “Today’s agreement is yet another example of a foreign financial institution coming forward, acknowledging its criminal conduct, taking the necessary steps to resolve its criminal exposure, cooperating… – Continue reading