Category: Regulatory

Russian Federation: Russia’s Deoffshorisation: First Foreign Ownership Filing Deadline Approaching Swiftly

Ahead of their joint event on Deoffshorisation Compliance on 21 May, TMF Group’s Sub Regional Director for CIS and the Nordics Alex Medlock and Artem Toropov, Senior International Tax Associate at law firm Goltsblat BLP LLP (the Russian practice of Berwin Leighton Paisner), outline the key deoffshorisation/CFC compliance requirements and… – Continue reading

Black money trail: India in talks with 28 nations for info

NEW DELHI, MAY 19: In its ongoing quest to draw information on illegal incomes stashed abroad, the Indian revenue authorities are in negotiations with as many as 28 different countries/jurisdictions for tax information exchange agreement (TIEA). This agreement will enable Indian tax authorities to receive banking related information even from… – Continue reading

Parliament set to combat ‘obscure financial dealings’

As money laundering is estimated to cost over €1 trillion a year, MEPs are set to vote on measures to set up an EU register of beneficial company owners. One of the hot topics at this week’s plenary session is parliament’s proposed measures against money laundering and terrorist financing, which… – Continue reading

DFSA and DIFC Registrar of Companies co-host FATCA Outreach Workshop

The Dubai Financial Services Authority (DFSA) and the Dubai International Financial Centre (DIFC), Registrar of Companies (RoC), jointly hosted an outreach workshop last week regarding the Foreign Account Tax Compliance Act (FATCA). FATCA is extra-territorial US legislation that affects Financial Institutions (FIs), particularly those which have accountholders who are US… – Continue reading

Kuwait said to ban remittances to 12 countries

Kuwait working to ban remittances to 12 countries, including Arab states, claiming the locations are being used to funnel funds to terrorists, Arabic daily Al Anbaa has reported, citing a ministerial source. The blacklisted countries include islands known to host offshore accounts of companies that run illegal money laundering businesses,… – Continue reading

How to make international tax less challenging

Authorities worldwide have increased scrutiny of tax-avoidance strategies in the past year, CFOs and finance directors of multinational clients told global tax consulting firm network Taxand. Sixty per cent of multinationals reported an increase in audits by tax authorities in the past year, and 70% said authorities had increased their… – Continue reading

New Challenge to Tax Planning: Morality and Politics Are Now In Play

In 1934, a distinguished American jurist, Judge Learned Hand, famously opined that “one may so arrange his affairs so that his taxes shall be as low as possible; he is not bound to choose that pattern which will best pay the Treasury; there is not even a patriotic duty to… – Continue reading

A Corporate Governance Give-Away to Tax Inverters?

In July 1997, Tyco International (with then Wall St darling Dennis Kozlowski at the helm) was “acquired” by a relatively small provider of home security services, known as ADT Inc. The deal arguably exploited some strategic synergies between the two companies, but far and away the biggest benefit to Tyco… – Continue reading

Chairman Royce, Rep. Pallone welcome US-Amenia Trade & Investment Framework Agreement

The advantages of off-shore investments Two of the top reasons that South African investors are given to encourage offshore investments are that going offshore diversifies your portfolio and that it gives you access to sectors you could never find on the resource-heavy JSE. “While those are not reasons to be… – Continue reading

Tax Planning: Should Wealthy Clients Move?

“Location, location, location” the well-known real estate mantra, is a notion that advisors of high- and ultrahigh-net-worth clients might also want take to heart. “Residency drives how much sophisticated wealth structuring and asset protection you can do,” says Merrill Lynch advisor Adam Katz. While the concept that it’s better to… – Continue reading

US Bill Would Simplify Multistate Workers’ Taxation

The bipartisan Mobile Workforce State Income Tax Simplification Act, which which would simplify tax reporting requirements for those workers employed in multiple state US jurisdictions, has been introduced into the House of Representatives by Hank Johnson (D – Georgia) and Mike Bishop (R – Michigan). States currently have widely varying… – Continue reading

Indian move to check illegal capital outflows

THE BJP-led National Democratic Alliance government, which had made a lot of noise about black money and the illegal stashing of funds abroad in the run-up to general elections last year, finally got down to some serious work to tax ill-gotten wealth and curb its growth. Last week, the government… – Continue reading

OECD says countries won’t be able to game tax system

Short cuts, loopholes and other forms of skulduggery will not be tolerated when the automatic exchange of tax information comes into force, a top official from the Organisation for Economic Co-operation and Development (OECD) has promised Swiss bankers, reports FinFacts. Grace Perez-Navarro, second in command at the OECD’s tax policy… – Continue reading

Confidentiality concerns grow pre-global tax evasion crackdown

Governments and tax partners need to work to ensure confidentiality is protected when new international tax transparency rules come into force in 2017, according to OECD director, Pascal Saint-Amans. “There is a fundamental difference between the automatic exchange of information and the existing system of exchange upon request, particularly because… – Continue reading

UK: Non-UK Domiciliaries: Inheritance Tax Issues And Opportunities

This note is intended as an introduction to inheritance tax (IHT) issues that need to be covered where a “non-dom” (an individual domiciled outside the UK) is planning on becoming resident in, or is already resident in, the UK. It should be emphasised that this is a complex subject, and… – Continue reading

PANAMA UPDATE: New Regime on Bearer Shares Effective in 2015

Executive Summary: The Panamanian government has engaged in an extensive period of consultations with local and foreign experts, practitioners, professionals and regulators, in a concerted effort to ensure that the jurisdiction continues to embody the highest international standards in terms of functionality and transparency (while preserving confidentiality). To that effect,… – Continue reading

I-T targets 50 APAs with MNCs in FY16

The I-T dept has received over 500 applications from MNCs for signing APAs. Income-tax department has set a target of 50 advance pricing agreements (APAs) to be sealed with multinational companies in the current fiscal that will exempt cross-border transactions by these firms from rigorous auditing to check income suppression…. – Continue reading

Black money: Switzerland may change laws, start sharing banking information

“We will have a black money discussion (with finance minister Arun Jaitley) to solve and clarify (the issue),” said Swiss economic affairs minister. Amid India enacting a law to deal with the menace of black money stashed abroad, Switzerland on Friday said that it is considering amendments in its domestic… – Continue reading

Can Another State Tax Your Trust?

Smartly setting up trusts requires knowledge of state tax laws, not just federal rules. Consider Robert L. McNeil, a chemist and onetime Pennsylvania resident who amassed a fortune as the business brain behind Tylenol. McNeil established trusts for his family but chose to locate them in Delaware, for tax purposes…. – Continue reading

In major anti-graft raid on Sabah, MACC freezes RM560m in 1,623 accounts

KUALA LUMPUR, May 15 ― The Malaysian Anti-Corruption Commission (MACC) today froze 1,623 bank accounts of companies and individuals involving over RM560 million in the first day of its “Operasi Bersepadu” in Sabah. The commission’s investigation division chief Datuk Mohamad Jamidan Abdullah said the operations were launched to crack down… – Continue reading

FATCA – implications for financial institutions

Introduction to FATCA On December 16 2013 Malta and the United States entered into an intergovernmental agreement (IGA) to implement rules and regulations under the Foreign Account Tax Compliance Act (FATCA). FATCA, enacted in 2010 by the United States, requires US taxpayers and financial institutions to report financial information to… – Continue reading

New anti-avoidance rule targeting large foreign multinational businesses

Following on from a press release issued by the Treasurer on May 11th, the government has released a draft bill containing a new limb to the general anti-avoidance provision, which is directed at foreign multinational groups who have global revenue exceeding $1 billion. The law will apply where: • the… – Continue reading

You’d be stupid not to try to cut your tax bill, says Bono: U2 frontman branded ‘hypocritical’ in light of his ‘anti-austerity posturing’

Singer revealed he bases some business ventures in the Netherlands Tax rates in the European country far lower than in his native Ireland Bono said ‘smart people’ were ‘just be sensible’ about ‘the way we’re taxed’ Sunday Times Rich List ranked U2 as the country’s third richest musicians He has… – Continue reading

Unnerved by tax demands on capital gains, foreign funds flee for safety

The minimum alternate tax row has damaged the credibility of government promises to enforce an investor-friendly tax regime and made the Indian stock market Asia’s worst performer this year New Delhi/Mumbai: Castleton Investment Ltd, a unit of GlaxoSmithKline Plc (GSK), in 2012 asked an arm of the Indian finance ministry… – Continue reading

BEPS Analyses Possible Without New Disclosures: Stakeholders

The Organisation for Economic Co-operation and Development (OECD) has published stakeholders’ comments on its discussion draft on base erosion and profit shifting (BEPS) Action 11, on improving analysis of BEPS. Through Action 11, the OECD hopes to develop recommendations to better chart the scale and economic impact of BEPS issues,… – Continue reading

Nigeria: Lawmakers to Suggest Special Courts On Tax, Corruption to Buhari

Senators and members of the House of Representatives under the Anti-Money Laundering and Cyber Security Coalition are expected to meet and suggest to President-elect retired General Muhammadu Buhari the establishment of special courts that will deal with cases of tax evasion and corruption offences. Chairman of the coalition, Senator Aloysius… – Continue reading

Armenian parliament decides to double-tax people

The parliament of Armenia has approved amendments to the law on income, setting a 13% tax rate for workers employed abroad. The Armenian government says they should be registered in Armenia and pay taxes in their homeland. Consequently, 65 MPs voted for the amendments, RusArmInfo reports. Armenian Deputy Minister of… – Continue reading

Australia: Federal budget 2015-16: Quick guide – the big business measures

Last night, the Federal Treasurer, Joe Hockey MP, released the 2015-16 Federal Budget. After public self-evaluation of its last budget as over-reaching, the Government has gone back to basics whilst still focussing on repairing the budget deficit in the medium to long term. The budget deficit is projected to be… – Continue reading

Chairman Royce, Rep. Pallone welcome US-Amenia Trade & Investment Framework Agreement

House Foreign Affairs Committee Chairman Ed Royce (R-CA) and Congressional Armenian Caucus Co-Chair Frank Pallone (D-NJ) were among the first Congressional leaders to welcome the May 7th signing of the U.S.-Armenia Trade and Investment Framework Agreement (TIFA), a longstanding policy priority for the Armenian National Committee of America (ANCA). Chairman… – Continue reading

Italian tax reform: facilitating inbound foreign investments

I. Introduction Following the approval by Parliament of Law No.23 of 11 March 2014 (hereinafter “Delega Fiscale”[1]), the Italian Government is now taking action and adopting the Legislative Decrees necessary to enforce this innovative tax reform. In fact, on 21 April 2015 the Council of Ministers has approved the drafts… – Continue reading