Statutes facilitates automatic exchange of financial account data Pensions regulator PFRDA has asked all intermediaries registered with or appointed by the body to take necessary steps to ensure compliance with respect to the implementation of multilateral competent authority agreement (MCAA) and foreign account tax compliance act (FATCA). Financial regulators in… – Continue reading
On August 12, 2015, the IRS issued Rev. Proc. 2015-40, which revises the procedures for obtaining competent authority (CA) assistance concerning issues arising under U.S. income tax treaties. This revenue procedure replaces current guidance, which was last updated almost 10 years ago, in Rev. Proc. 2006-54. Revisions to the former… – Continue reading
Two Cayman residents are challenging a decision by the Tax Information Authority to comply with a tax information exchange request by the U.S. Internal Revenue Service. Lee and Sheila Aronfeld are naturalized citizens of the Cayman Islands but remain taxpayers in the United States, where they are subject to a… – Continue reading
New Delhi: Expressing concerns over the outflow of funds from developing countries, including India, through money laundering and other ways, Minister of State for Finance Jayant Sinha today said as much as $300-600 billion moves out through such channels. “Illicit financial flows means the money that actually is black money,… – Continue reading
The government asked companies and individuals to report their hidden overseas assets voluntarily during a grace period ending in March next year, a move to expand the tax base and strengthen taxation transparency. Those who voluntarily come clean on their hidden overseas assets will be exempted from punishment during the… – Continue reading
New Zealand: GST and the digital economy The New Zealand Government has released a Discussion Document regarding the proposal to impose goods and services tax (GST) on online purchases of goods and services from offshore suppliers by New Zealand resident consumers. The publication Taxing by the megabyte: New Zealand’s GST… – Continue reading
The Finance Ministry said Tuesday that it would pardon individuals and companies that not paid taxes on gains from overseas investments, as long as they voluntarily report their gains for tax payment by the end of March. The tax authority’s policy came from the Park Geun-hye administration’s efforts to expand… – Continue reading
Swiss banking secrecy is no longer viable as the U.S. Justice Department closes in on agreements with most of the institutions that may have helped Americans evade taxes, according to the top American diplomat in Switzerland. Negotiations with about one-third of Swiss lenders, known as Category 2 banks, to finalise… – Continue reading
Malta’s tax legislation provides for a number of benefits which can be derived by companies and their shareholders. The tax rules can lead to a tax burden in Malta which is significantly reduced or completely eliminated in certain cases, and the following are some of the key tax benefits which… – Continue reading
Based on the overview of Jurisdictions Participating in the Convention on Mutual Administrative Assistance in Tax Matters as available on the website of the OECD, on August 31, 2015 Mauritius deposited its instrument of ratification, acceptance or approval for the Protocol of the OECD Multilateral Convention on Mutual Administrative Assistance… – Continue reading
U.S. Sen. Orrin Hatch (R-UT), chairman of the Senate Finance Committee, and U.S. Rep. Paul Ryan (R-WI), House Ways and Means Committee chairman, sent a letter on Tuesday to Treasury Secretary Jack Lew, outlining concerns regarding the country-by-country (CbC) reporting requirements in the works at the Treasury Department. The letter… – Continue reading
For the past few years, Canadians have been taking advantage of our dollar being worth about the same as the U.S. dollar. From buying up real estate to cross-border shopping, being on par with the U.S. dollar has had its advantages. However, in the last few months, economic factors have… – Continue reading
Stanley Amland threw it off. So did Ingrid Bracke. Rhoda May Derksen ditched hers, too. The names, picked at random for this article from the Federal Register, are among the 3,415 Americans who renounced their U.S. citizenship or relinquished their residency permits last year. As a national debate rages about… – Continue reading
In addition to its main function to eliminate double taxation, a tax treaty is also intended to promote foreign direct investment (FDI). Investors normally consider the treaty networks of a targeted investment country in deciding their investments. The more extensive the treaty networks, the more attractive for the investors. Extensive… – Continue reading
ISLAMABAD The government has refused to bow down to the pressure of the traders over the withholding tax on the banking transactions, saying this tax could not be withdrawn at any cost. “We are not considering to withdraw the withholding tax on the banking transactions”, said Shahid Hussain Asad, Senior… – Continue reading
The Channel Islands (Jersey and Guernsey) have long been known as leading offshore centres for the establishment of investment funds and other investment structures. In particular, Channel Island vehicles are often used for alternative investment structuring – including private equity, infrastructure and real estate. This article explains the trends in… – Continue reading
Mexico’s government withheld hundreds of millions of dollars in tax refunds owed to Procter & Gamble, Unilever, and Colgate combined as it sought to coax them and other multinationals to pay more income tax locally, according to people close to the talks. After luring foreign companies with corporate tax breaks… – Continue reading
On 4 August 2015, the Senate Economics References Committee tabled its report, Digital currency – game changer or bit player making a number of recommendations including: digital currency transactions should be treated in the same manner as money for the purposes of the goods and services tax (GST) and recommends… – Continue reading
Ambassador Furio De Angelis, the UN Refugee Agency’s man in Ottawa, says the media attention on the refugee crisis hitting Europe from all directions is a good thing, and one he hopes will translate into “concrete action.” He said the situation is dramatic, but it’s also a reflection of his… – Continue reading
International worldwide transactions in Mexico face a weakness as a result of an old and outdated provision which disallows for income tax purposes, the deduction of payments made abroad on a prorated basis with other parties that are not subject to Mexican income tax, such as foreign residents with no… – Continue reading
Manx residents are being warned that new global standards on tax co-operation will put their financial affairs under greater scrutiny. Letters have been sent out by the Treasury to a number of taxpayers highlighting apparent discrepancies in their taxable income. This follows information passed on to the Income Tax Division… – Continue reading
Funds Discovered in Kolomoyskyi’s Cyprus Kitty Investigative reporters have discovered that IMF bailout funds intended for Ukraine have mysteriously found their way to a Cyprus bank account controlled by notorious Ukrainian oligarch Ihor Kolomoyskyi. A huge chunk of the $17 billion in bailout money the IMF granted to Ukraine in… – Continue reading
Italy’s Cabinet on August 7 approved legislation to ratify the tax agreements signed with Switzerland, Liechtenstein, and Monaco. The protocol to the existing double tax agreement between Italy and Switzerland was signed on February 23, 2015. The Cabinet noted that, once the protocol enters into force following ratification by both… – Continue reading
The former chief executive of Nudie Juice, Andrew Binetter, is being sued by the Australian Taxation Office following allegations he oversaw a tax scam involving millions of dollars. The case, which is due to be heard in the Federal Court before Justice Gleeson today in Sydney, follows investigations by the… – Continue reading
New Zealand on August 31, 2015, launched a public consultation on the Government’s proposed residential land withholding tax. Revenue Minister Todd McClay said the proposed tax would apply only to offshore sellers. He said it is an important part of the Government’s residential property tax compliance work and will ensure… – Continue reading
More than 900 people with six-figure incomes were obliged to contribute more. Hundreds of high earners who tried to use tax breaks and shelters to maximise their income ended up paying over €60 million tax under measures introduced in recent years. The high-income individual’s restriction was introduced following controversy that… – Continue reading
Investigative journalist Khadija Ismayilova delivered a scathing final statement in a Baku courtroom on August 31, calling Azerbaijan’s government a “repression machine” and dismissing her trial as a “scam” aimed to silence her. Before she was cut off without finishing her remarks, Ismayilova told the court that her reporting proved… – Continue reading
NEW YORK, NY–(Marketwired – Aug 31, 2015) – Cross-border mergers and acquisitions are at their hottest pace since before the financial crisis. In fact, M&A volume was $1.10 trillion in 2014, up from $775.3 billion in 2013 and the highest since 2008. And intangible assets like intellectual property and goodwill… – Continue reading
United Kingdom | August 31 2015 Last month, the UK government announced sweeping changes to the taxation of “resident non doms,” a classification of individuals who receive favorable tax treatment from the UK government. The UK tax obligations of an individual depend in large part on the individual’s “domicile” under… – Continue reading
Ministry of Finance officials say they are “monitoring developments” in Washington after the District of Columbia included Bermuda on a list of tax havens. The Island was one of 39 jurisdictions named on the list in changes to the municipality’s Budget Support Act. The changes will first have to be… – Continue reading
Navigating the murky waters of the Foreign Account Tax Compliance Act (FATCA) can be tricky. U.S businesses and individuals transacting in Latin America need to adhere to the requirements and regulations imposed by the fact. Here are four things every U.S business and individual needs to know about FATCA. Tax… – Continue reading
Rejecting “treaty shopping” claims, India’s High Court of Punjab and Haryana has ruled that India should not tax capital gains from the sale by Mauritian entities of shares held in an Indian company if they are proven resident in Mauritius. The ruling was given in Serco BPO Private Limited v…. – Continue reading
Shifting of income between parent and subsidiary companies for the purpose of avoiding taxation has been a consistent concern for state departments of revenue. States have enacted a variety of rules to ensure that the entities involved file and pay taxes accurately. In Spring Licensing Group, Inc. v. New Jersey… – Continue reading
A resolution was published in Panama’s official gazette in early August 2015 that provides rules concerning benefits under income tax treaties for the avoidance of double taxation. Specifically, under this new guidance, taxpayers can seek a ruling from the tax authorities as to whether treaty benefits will apply to a… – Continue reading
The following fact pattern should is representative of a tax evasion and structuring case. A taxpayer receives checks in the ordinary course of business from customers. Some of those checks are deposited into the business bank account and some are cashed. The cashed checks don’t equal or exceed $10,000. The… – Continue reading
The Swiss authorities, already annoyed by India’s new black money law that puts pressure on its banking system, has now rejected an Indian government request for legal assistance to proceed against a Swiss firm for alleged bribery. A report by the NZZ am Sonntag newspaper said Switzerland’s office of the… – Continue reading
On 25 August 2015, the Indian Ministry of Finance released an order extending the Foreign Account Tax Compliance Act (FATCA) reporting filing deadline for Indian Financial Institutions to 10 September 2015 (from 31 August 2015). The FATCA Agreement between India and the United States was signed on 9 July 2015…. – Continue reading
Stanley Amland threw it off. So did Ingrid Bracke. Rhoda May Derksen ditched hers, too. The names, picked at random for this article from the Federal Register, are among the 3,415 Americans who renounced their U.S. citizenship or relinquished their residency permits last year. As a national debate rages about… – Continue reading
The Foreign Account Tax Compliance Act (FATCA) requires, in essence, that U.S. citizens who reside outside the U.S. disclose to the IRS all of their foreign banking assets including retirement plans, savings accounts, etc. It also requires foreign banks to assist the IRS in applying the disclosure rules or else… – Continue reading
Proposals for consistent global rules on company tax cause worries all round CLARITY or chaos? Supporters of the Base Erosion and Profit-Shifting (BEPS) project, being worked on by the OECD, argue that it will bind multinationals to a consistent set of global tax rules, providing them with less licence than… – Continue reading
Mumbai, Aug. 29 : The Reserve Bank of India (RBI) has asked all banks and financial institutions to be prepared to implement the Foreign Account Tax Compliance Act (FATCA). In a notification issued on Friday, the RBI said that India has signed an agreement with United States for improving international… – Continue reading
The Cayman Islands Department for International Tax Cooperation (DITC) has advised that it is in the final stages of preparing its FATCA data to be provided to the IRS. Information on US Reportable Account Notifications and 2014 Returns for US FATCA should now be completed and successfully submitted. It is… – Continue reading
The Internal Revenue Service loses billions of dollars annually because of offshore tax evasion. For years, a number of American taxpayers have evaded federal income taxes by channeling income into secret foreign or offshore bank accounts in some 70 countries. An award-winning investigative series by the Tribune-Review, $hadow Economy ,… – Continue reading
India and Germany have agreed to resume negotiations on partial revision of double taxation avoidance agreement (DTAA), the government said on Friday. The two countries have agreed to explore possibilities of enhancing tax related information while continuing to share information on the basis of existing agreements, the ministry of finance… – Continue reading
It’s a decision that could spell relief for many Mauritius based investors. This week the Punjab & Haryana High Court has re-iterated that a Mauritian tax residency certificate is sufficient to avail treaty benefits. Senior advocate Porus Kaka tells CNBC TV18’s Menaka Doshi that this re-iteration is important given the… – Continue reading
New legislation on abuse of law and statute of limitations The Italian Government has recently approved a new decree, which reshapes the definition of abuse of law and tax avoidance and changes the rules on the statute of limitations in the event of tax crimes. The decree also introduces a… – Continue reading
After years of commentary on FATCA from a distance, this writer got a little taste of it up close. It left a very unpleasant aftertaste and is taking a long time to go down. FATCA is bad for America. While knowing of, and criticising FATCA for years, it finally became… – Continue reading
Reevaluating reporting options and investmentsSmart choices and targeted investments today may help contain the approaching resource crunch and the long term costs of compliance FATCA has placed tax reporting front and center with management committees of financial institutions, but it represents just the tip of a potentially larger iceberg. Legislation… – Continue reading
Acting U.K. Overseas Territories Minister Grant Shapps said Thursday he is hopeful that Cayman and the Mother Country can reach some form of agreement on requirements to list the beneficial owners of companies registered here. “There’s more than one way to skin a cat,” Mr. Shapps said during a brief… – Continue reading
The Luxembourg tax authorities issued a circular providing guidance and rules for issuing certificates of tax residence and access to application of income tax treaty provisions for the avoidance of double taxation for Luxembourg “undertakings for collective investment” or UCIs. The circular sets forth guidance for SICAVs / SICAFs and… – Continue reading
