Category: Regulatory

Countries and Companies Square Off Over International Tax

An OECD initiative on tax evasion is causing ripples around the world While a host of topics — from the necessity and the proposed scope of corporate tax reform, to corporate rate reduction and corporate inversions — are of major concern to those engaged in international tax, the overriding issue… – Continue reading

Mauritius Sets FATCA Reporting Deadline

The Mauritius Revenue Authority (MRA) has informed Mauritius-based financial institutions (MFIs) that the filing deadline for submitting their US Foreign Account Tax Compliance Act (FATCA) data for the 2014 reporting year is July 31, 2015. FATCA requires all FIs outside of the United States to submit regular information on financial… – Continue reading

Canada: Tax Measures Impacting Employers – Canadian Federal Budget 2015

Yesterday afternoon, the Canadian government tabled the 2015 Canadian Federal Budget. Two measures are particularly relevant to certain employers. Withholding Relief for Non-Resident Employers and Employees To take effect next year (if the measure is enacted), Budget 2015 proposes an exemption from certain withholding requirements on payments from “qualifying non-resident… – Continue reading

Structural weakness: The tall order against high-profile tax evaders

ISLAMABAD: Haphazard and impractical comments are the norm when tax authorities release collection figures of major political personalities. Newspaper columnists and television anchors try their level best to humiliate them but the endeavour is too shallow to spark a relevant public debate. There is no doubt politicians pay income tax… – Continue reading

Bulgaria court distrains BGN 1.5 mln property of ex-MP Hristo Biserov

Sofia. At the request of the Commission for Establishing Property Acquired from Criminal Activity Sofia City Court levied distraint on property of former MP Htristo Biserov and his step-son Ivaylo Glavinkov, worth BGN 1,555,883, the press office of the commission announced, as cited by the Bulgarian National Radio (BNR). The… – Continue reading

HMRC ramps up investigations into quick rich earners

The tax affairs of individuals with a rapidly rising wealth are to come under more intense scrutiny by HM Revenue & Customs (HMRC). International law firm, Pinsent Masons, said the UK’s tax office has intensified its clampdown on suspected tax avoidance among newly successful entrepreneurs, professionals and celebrities, monitoring them… – Continue reading

11th Circuit Punts Tax Shelter Question to Florida Justices

When should the beneficiaries of an IRS-targeted tax shelter be allowed to sue their enablers? That’s the question the federal appellate court in Atlanta posed to the Florida Supreme Court April 17 in an ongoing bankruptcy-related case. The answer, which turns on statutes of limitations, probably will boil down to… – Continue reading

Bad News About Unfiled FBARs, Another Indictment

A recent indictment by the United States Attorney’s office in California illustrates the inter-relationship between currency transfer restrictions, (such as those involving Iran), foreign financial account reporting (the FBAR requirement) and the failure to report taxable income (filing of a false tax return). In United States of America vs. Ali… – Continue reading

Bermuda Promotes Captive Insurance to Canadian Industry

Island Delegation to Tout Jurisdiction as Risk Capital and Potential e-Commerce Hub HAMILTON, Bermuda, April 27, 2015 (GLOBE NEWSWIRE) — A 15-strong delegation of Bermuda industry, government and regulator representatives will take part in a Canada roadshow next week, targeting top-level executives and touting the corporate benefits of setting up… – Continue reading

British Virgin Islands Government Launches FATCA & AEOI Portal with Vizor Software

British Virgin Islands through its International Tax Authority (BVI ITA), went live last week with the Vizor for FATCA & AEOI solution, the “BVI Financial Account Reporting System”. Today, Vizor Ltd. announced that BVI went live with the Vizor for FATCA & AEOI solution. The British Virgin Islands Government (BVIG)… – Continue reading

EU Member States should benefit from the Capital Markets Union

On Saturday 25 April, at the second session of the informal meeting of the Economic and Financial Affairs Council (ECOFIN), one of most important issues on the agenda was the further development of the Capital Markets Union concept, which was broadly supported by the ministers and Governors of central banks…. – Continue reading

Bermuda – South Korea Tax Information Exchange Agreement Enters Into Force

The Tax Information Exchange Agreement between Bermuda and South Korea entered into force and became effective on 13 Fevruary 2015. Once requested for information by one state, the other state is obligated to release the information in 90 days unless the information contains business secrets or classified business processes. If… – Continue reading

Bermuda: Bermuda’s Trust Law: Ticking All The Right Boxes

With the Transcontinental Trusts Bermuda Forum taking place next week, it is timely to reflect on some of the attractive features and structuring alternatives that Bermuda’s trusts and related law provides and to consider some recent exciting developments. Bermuda provides a flexible, cost effective regime for the formation and administration… – Continue reading

New Tim Hortons owners slash corporate taxes post-Burger King deal

When Burger King’s owners first announced last summer’s mega-deal to gobble up Tim Hortons, the fast-food firm’s executives downplayed a key reason why they were acquiring the Canadian coffee chain and relocating corporate HQ to Canada: to cut its taxes. “Tax wasn’t really the driver of this,” Daniel Schwartz, the… – Continue reading

Uzbekistan – United States FATCA Agreement Signed

On 3 April 2015, Uzbekistan and the United States signed a Foreign Account Tax Compliance Act (FATCA) Agreement. FATCA seeks to obtain information on accounts held by U.S. taxpayers in other countries. It requires U.S. financial institutions to withhold a portion of certain payments made to Foreign Financial Institutions (FFIs)… – Continue reading

How Gilded Ages End

Americans have overcome oligarchy before — and there’s no reason we can’t do it again. Rising inequality seems to pose an insurmountable political problem. If the underlying causes are technological change and globalization, the forces appear to be unstoppable. Alternatively, if the causes are primarily political and involve the power… – Continue reading

Cayman FATCA portal registration a significant test for industry

Tim Thornton, Chief Data Officer, Mitsubishi UFJ Fund Services comments on the upcoming deadline for registration on the Cayman FATCA portal… The upcoming 30 April deadline for registration on the Cayman FATCA portal is another milestone in the implementation of FATCA. The relatively short window from the portal being available,… – Continue reading

Revenue probe into capital gains tax-avoiding contracts for difference could yield €99m

THE REVENUE Commissioner’s large cases division is investigating almost 100 schemes it suspects were designed by companies and wealthy individuals to avoid paying capital gains tax. The taxman is enquiring into 89 cases which used sophisticated financial instruments known as contracts for difference to generate artificial losses. The schemes avoided… – Continue reading

Pots of stashed cash in tax havens ‘a myth’

The world’s high and ultrahigh net worth families are run much like businesses these days, with family governance in place as well as fund structures in favourable tax jurisdictions that allow for consolidated reporting across diversified assets. That is the way the world is moving, with global tax authorities grouping… – Continue reading

EU finance ministers back efforts to fight tax avoidance by multinationals

European finance ministers have backed efforts to fight rampant tax avoidance by multinationals in the wake of the LuxLeaks scandal. But European Union members face tough negotiations to work out the details. Under a new plan the bloc’s 28 countries would share tax deals agreed with some of the world’s… – Continue reading

India: Transfer Pricing Regulations Engulfs Market Intangibles

Trade in today’s global era visualizes significant number of international transactions in form of transfer of goods, services, capital and intangibles. International transfers arise within the Multinational Enterprise group entities and are called intra-group transfer. What is actually paid by one entity to another entity in the intra-group transfer is… – Continue reading

Financial Services Act and Financial Institutions Act: results of consultation procedure

The federal government has published the results of the consultation on the Financial Services Act and the Financial Institutions Act (for further details please see “Federal Financial Services Act and Federal Financial Institutions Act”). The Financial Services Act governs the prerequisites for providing financial services and offering financial instruments and… – Continue reading

Tax treaty shield will not apply to a majority of foreign investors

FPIs are battling it out with the income-tax department, which has issued notices demanding that they pay MAT to the tune of Rs40,000 crore New Delhi/Mumbai: Despite the government affirming that foreign portfolio investors (FPIs) can use tax treaties to fight tax demands on past capital gains, a majority of… – Continue reading

US, UK funds approach India on MAT citing OECD

However, OECD being persuasive may not help funds based out of nations whose treaties do not give specific exemption The Indian government’s clarification that it would honour tax treaties while making a demand of Minimum Alternate Tax (MAT) at the effective rate of 20 per cent came as a relief… – Continue reading

Goodman Luxembourg firm paid 0.4% tax on profit of €52.6m

Company accounts provide insight into Parlesse Investments A Larry Goodman company based in Luxembourg made a profit of €52.6 million in 2013 and paid just 0.4 per cent tax, according to accounts in the tiny EU member state. The company, Parlesse Investments Sarl, began operations in 2010 and had accumulated… – Continue reading

British Virgin Islands: FATCA – Impending Deadlines For BVI Financial Institutions

On 20 March 2015, the British Virgin Islands Government issued revised guidance notes regarding the Intergovernmental Agreements between the British Virgin Islands (“BVI”) and the United States of America (the “US”) and the United Kingdom (the “UK”) to improve international tax compliance (the “Guidance Notes”). The Guidance Notes confirm that… – Continue reading

BSI Provides Road Map For Future Swiss Bank Agreements

On March 30, 2015, the U.S. Department of Justice announced that it had entered into a nonprosecution agreement with BSI SA, the first Swiss bank to reach resolution with the U.S. government as to its potential criminal exposure for assisting its U.S. clients in engaging in tax evasion.[1] As part… – Continue reading

Tax-base erosion cripples Africa

Multinationals play such a large role in many nations’ budgets that effective control is crucial. Business Tax-base erosion cripples Africa 24 Apr 2015 00:00 Lisa Steyn Multinationals play such a large role in many nations’ budgets that effective control is crucial. Finance Minister Nhlanhla Nene says practices such as incorrect… – Continue reading

Consultation on Automatic Exchange of Financial Account Information in Tax Matters in HK launched

Hong Kong (HKSAR) – The Government today (April 24) launched a consultation exercise to gauge views on proposals to apply, with adaptations for Hong Kong, the prevailing international standards on the automatic exchange of financial account information in tax matters (AEOI). On the basis of the Organisation for Economic Cooperation… – Continue reading