Category: Regulatory

Anti money laundering / Barclays / Corruption / HSBC

UK multi-agency anti-money laundering drive will give law enforcement better oversight of suspicious accounts, says expert

Posted On: April 9, 2015

A recently-announced joint initiative between the government, banks and law enforcement agencies could give those investigating suspected money laundering offences better oversight of suspicious accounts, an expert has said. However, regulatory law expert Anne-Marie Ottaway of Pinsent Masons, the law firm behind Out-Law.com, said that the new intelligence-sharing initiative could… – Continue reading

Apple / Google / Investments / KPMG / Microsoft / Tax Laws

KPMG says be cautious in tax reform

Posted On: April 9, 2015

Tax and business consultants KPMG are warning the government to be cautious in reforming corporate tax law in its moves to target offshoring of corporate profits. In its submission to the Senate inquiry examining corporate tax avoidance, KPMG said while governments need to ensure they are receiving appropriate amounts of… – Continue reading

Capital gains / Residence / Tax Credit

Seaton sponsors income tax bill

Posted On: April 9, 2015

• “Budget deficit calls for combination of cuts, and contributions,” says Seaton This week Republican Representative Paul Seaton, R-Homer, introduced a bill that would impose an income tax on residents and non-residents deriving an income source from within the state of Alaska. Proposed as a diversification strategy, Seaton said that… – Continue reading

Double Taxation / Tax Credit / USA

Professional Employer Organizations: new tax services possible

Posted On: April 9, 2015

Currently, Professional Employer Organizations (PEOs) have no comprehensive federal framework under which to offer employment tax collection and remittance services to their clients. The Small Business Efficiency Act (“SBEA Act”) is set to change this effective as of January 1, 2016, following an interim deadline for the IRS to establish… – Continue reading

Anti money laundering / CSP / Legislation / Singapore

Enhanced regulatory framework for corporate service providers to kick in on May 15

Posted On: April 9, 2015

SINGAPORE – An enhanced regulatory framework for corporate service providers (CSPs) to combat money laundering and terrorism financing will take effect from May 15. The strengthened regime for CSPs will help to further boost Singapore’s reputation as a trusted international financial and business centre with robust regulatory frameworks against money… – Continue reading

China / Double Taxation / Fees / Intellectual Property / OECD / Profit Shifting / Royalties / Transfer pricing

China’s pre-emptive strike on OECD profit-shifting initiative

Posted On: April 9, 2015

China has introduced measures to deny income tax deductions for certain service fees and royalties paid by Chinese companies to their overseas affiliates. They appear to stem from China’s initiatives to implement rules it sees as related to the OECD’s Base Erosion and Profit Shifting project (BEPS) They will likely… – Continue reading

Amazon / Court cases / Deloitte / Directors / Fees / Google / Legislation / Malta / Starbucks / Statutory / Tax Planning

Auditors are not forensic investigators – Booker

Posted On: April 9, 2015

Changes are in the pipeline which will have a dramatic impact on the way that auditing firms handle public-interest entities (PIEs) as from December 2016 – but Deloitte CEO Malcolm Booker is very wary about how this could work in practice. According to the legislation, auditors would have to enter… – Continue reading

Residence / Residency

Mike Duffy got briefing on residency rules, Senate clerk says

Posted On: April 8, 2015

With a retired Senate law clerk on the stand, lawyers got into the question of Mike Duffy’s “primary” residency. OTTAWA—The complicated question of just where suspended senator Mike Duffy had a “primary” residence began to be probed in depth Wednesday, with much hanging on definitions, rules and senators’ understandings. Duffy’s… – Continue reading

Advance Pricing Agreement / Australia / Google / Ireland / Microsoft / Netflix / OECD / Offshore Companies / Profit Shifting / Singapore / Tax Credit / Tax Planning / Tax treaties / Transfer pricing

Google, Apple and Microsoft defend tax set-up that shifts revenue offshore

Posted On: April 8, 2015

Executives tell Senate inquiry paying tax overseas for Australian sales is how the global tax system works, while News Corp Australia demands Netflix pays GST Senior executives from three major tech firms have defended corporate structures which allow most of the revenue from their Australian operations to be taxed in… – Continue reading

Automatic Exchange of Information / British Virgin Islands / Cayman Islands / FATCA / OECD

British Virgin Islands: Cayman Issues User Guide To Automatic Exchange Of Information Portal

Posted On: April 8, 2015

As noted in an earlier update, the deadline for the registration of Cayman Islands Financial Institutions with the Cayman Islands Tax Information Authority was recently extended to 30 April 2015. In anticipation of the upcoming go-live date of the Cayman Islands Automatic Exchange of Information Portal (Portal), the Cayman Islands… – Continue reading

Australia / Capital gains / Dividends / Double Tax Treaty / Offshore Investments / Tax competition

Extending dividend benefits to foreign investors may address competition concerns

Posted On: April 8, 2015

The Federal Government has floated the idea of lowering the corporate tax rate – arguing the current rate of 30% is not internationally competitive. The rationale is that globalisation makes capital perfectly mobile and the marginal non-resident investor in Australian companies will go where corporate tax rates are lowest. At… – Continue reading

Base Erosion & Profit Shifting / Europe / Investments / OECD / Tax treaties

OECD rules will hurt cross-border funds, forum told

Posted On: April 8, 2015

Draft plans to remove tax benefits for cross-border funds to eradicate Base Erosion and Profit Sharing could significantly impact investment into Ucits, the Alfi conferences hears. New draft OECD rules designed to combat Base Erosion and Profit Sharing (Beps) could have dire unintended consequences for cross-border funds, warned Roger Exwood,… – Continue reading

France / OECD

OECD Says France Must Pursue Greater Reform

Posted On: April 8, 2015

The latest survey of France’s economy by the Organization for Economic Co-operation and Development (OECD) has highlighted an urgent need for more reform. The report highlights policies that are contributing to slow economic growth in France. In particular, it criticizes the “excessive tax burden” and overly complex administrative procedures, which… – Continue reading

Residency / United Kingdom

Miliband Vows to End U.K.’s ‘Indefensible’ Non-Domicile Loophole

Posted On: April 8, 2015

Ed Miliband hardened his stance on tax avoidance by pledging to end the U.K.’s non-domicile loophole used by the wealthy, hitting back at Conservative accusations a Labour government would hit working families the hardest. “There is no bigger symbol of this failure to expect people right to the top to… – Continue reading

HSBC / HSBC Holdings PLC / New York / Panama / Residence / Warnings

Miliband Vow to Tackle Tax Loophole Seen Hurting City of London

Posted On: April 8, 2015

Labour Party leader Ed Miliband’s vow to close a tax loophole sparked fresh scrutiny on wealthy residents and drew warnings the plan could threaten London as one of the world’s major financial centers. Miliband pledged on Wednesday to abolish the non-domicile status if he’s elected on May 7, allowing some… – Continue reading

Cyprus / Double Taxation / Georgia / Lebanon / Liechtenstein / Morocco / Oman

Georgia Considers Tax Code Amendments

Posted On: April 8, 2015

A Bill containing various amendments to the Tax Code has been discussed and agreed by the Georgian Economic Council. Among the measures contained in the Bill is a reduction in the rate of tax for individuals letting property, from 20 percent to five percent. There is also a proposed incentive… – Continue reading

Apple / Bank of America / Cayman Islands / Chevron / Citigroup / Dividends / FACT / Gaming / Investments / Legislation / Luxembourg

Stop this egregious injustice: Why a bipartisan tax holiday is just another corporate handout

Posted On: April 8, 2015

Corporations like Apple shouldn’t get a sweetheart deal to “onshore” profits, tax expert Scott Klinger tells Salon One of the more consequential paradoxes of American politics concerns the myth and the reality of bipartisan legislation. The myth is that American voters want it, and they want it bad. In fact,… – Continue reading

Dividends / Double Taxation / Forms / Statutory

AM 2015-01—does previously taxed income “tier up” to a domestic corporate shareholder?

Posted On: April 8, 2015

Introduction In a recent chief counsel memorandum (AM 2015-01), the IRS addressed a long uncertain tax question: when a US corporate shareholder includes an amount in income under subpart F, does the subpart F inclusion increase the corporate shareholder’s “earnings and profits” immediately or only when the earnings are actually… – Continue reading

Canada / FATCA / France / Google / IGA / Japan / LinkedIn / New York / Twitter

Conor Crowley, Managing Director, Vizor Software to Speak at Knowledge Congress’ Live Webcast

Posted On: April 8, 2015

New York, NY, April 08, 2015 –(PR.com)– The Knowledge Group/The Knowledge Congress Live Webcast Series, the leading producer of regulatory focused webcasts, has announced today that Conor Crowley, Managing Director, Vizor Software will speak at a 2-hour webcast entitled “FATCA for Government Agencies: What You Need to Know in 2015… – Continue reading

EU / Europe / FedEx / Ikea / Jean-Claude Juncker / Luxembourg

Despite Investment, Luxembourg Costs EU ‘Billions’ in Tax Breaks

Posted On: April 8, 2015

Luxembourg has been accused of hypocrisy after announcing that it will contribute $87 million towards an EU investment fund, with tax campaigners instead calling for the country to scrap its special tax rules, which analysts say is costing the EU “hundreds of billions every year.” The small European Duchy has… – Continue reading

Double Taxation / Gaming / Lebanon / Legislation

Horseshoe Cincinnati’s March revenues best in a year

Posted On: April 8, 2015

CINCINNATI — March traditionally is the best month for gambling operations, and new tallies show the Horseshoe Cincinnati Casino had its best month for revenues since a year ago. Last month’s results for the Horseshoe Cincinnati, with $17.5 million in revenues, bested every month since March a year ago. Revenues… – Continue reading

China / Credit Suisse / FATCA / Liechtenstein / Panama / Russia / Switzerland / Tax cheats / UBS

Obama’s war on tax cheats gains ground

Posted On: April 8, 2015

The Obama administration is gaining ground in its war against tax cheats, racking up victories in a global crackdown that has made it harder to escape the Internal Revenue Service. President Obama’s battle against offshore tax evaders hasn’t gotten the publicity of some of his other priorities but under his… – Continue reading

Canada / Investments / Permanent establishment / Real Estate / Residence / Tax Credit

Canada: Tax Traps Of Owning U.S. Real Estate

Posted On: April 8, 2015

Many Canadian Snowbirds who have become fed up with Canada’s long, hard winters (and there are bound to be many more this year, especially from the Eastern provinces) have purchased winter homes in Southern U.S. states. This has been an especially popular move over the past few years, with U.S…. – Continue reading

Canada / Investments / Legislation / OECD / Tax Credit

Canada: 2015 Federal Budget Predictions

Posted On: April 8, 2015

By now, most of us know that the ruling Conservatives announced they will release the Federal Budget (calling it Economic Action Plan 2015 – the “Budget”) on April 21, 2015. Once again, I will be in attendance in Ottawa representing CPA Canada and our firm. What do I predict will… – Continue reading

HSBC / Julius Baer / Switzerland / Tax evasion investigations / UBS / Zuercher Kantonalbank

‘Stay tuned’ for more Swiss bank deals over tax evasion: U.S. official

Posted On: April 8, 2015

(Reuters) – More Swiss banks that helped wealthy Americans evade taxes will soon strike agreements with the U.S. Department of Justice to avoid prosecution, an official overseeing the U.S. government program told Reuters. “I would stay tuned,” Acting Assistant Attorney General Caroline Ciraolo of the Justice Department’s Tax Division said… – Continue reading

Australia / G20 / Google / OECD / Profit Shifting / Tax treaties / Transfer pricing

Experts caution Australia on unilateral ‘Google tax’

Posted On: April 8, 2015

Taxation experts have warned against unilateral action on corporate tax avoidance, telling a Senate Economics Committee Australia should be proactive and show leadership in the OECD and G20 tax processes already underway. The inquiry, initiated by Greens leader Christine Milne, is exploring tax avoidance and aggressive minimisation by corporations registered… – Continue reading

Europe / FATCA / OECD

United States: Webinar Rewind: FATCA And AIFMD Update For Latin American Managers

Posted On: April 8, 2015

Our webinar, “FATCA & AIFMD: An Update on International Compliance for Latin American Managers”, provides detailed information and guidance on both FATCA and AIFMD. The discussion included; FATCA Notification and Reporting deadlines, the importance of documented procedures, U.K. FATCA, the OECD Common Reporting Standards, Marketing in Europe, Reverse Solicitation and… – Continue reading

Double Tax Treaty / Gibraltar / Isle of Man / Legislation / Malta / Statutory

Malta first to enable overseas pension freedom

Posted On: April 8, 2015

Malta has become the only jurisdiction to offer full UK-style pension freedoms for British ex-pat savers in qualifying registered overseas schemes, after a deal forged last week between the country’s financial regulator, reports the FT Adviser. One provider, TMF Group, has announced it has reached agreement with the Malta Financial… – Continue reading

Asia / Australia / Double Tax Treaty / OECD / Profit Shifting / Rio Tinto / Singapore / Transfer pricing

Singapore doesn’t condone tax abuse, MOF says

Posted On: April 8, 2015

Singapore does not condone any abuse of its tax system, a Ministry of Finance (MOF) spokesman said on Tuesday, in response to a Straits Times query following media reports that the Australian government is pursuing global miners BHP Billiton and Rio Tinto for channelling billions of dollars in iron ore… – Continue reading

Apple / Australia / Fairfax Media / Glencore / Google / Investments / Microsoft / Offshore Companies / Profit Shifting / Research and Development (R&D) / Rio Tinto / Singapore / Tax Laws / Tax treaties

Google says give R&D tax breaks to small techies, not big guys

Posted On: April 8, 2015

Tax breaks for research and development should be targeted to smaller technology start-ups, rather than big companies that will most likely make the investments regardless of incentives, Google Australia will tell the senate inquiry into corporate tax avoidance. Google Australia’s managing director, Maile Carnegie, will be appearing before the inquiry… – Continue reading

Double Taxation / EU / FATCA / Fees / Forms / Legislation / Malta / Residency / United Kingdom / USA

QROPS for US Residents – FATCA & IRS Compliant

Posted On: April 7, 2015

For British pension holders in the US, transferring into a Qualifying Recognised Overseas Pension Scheme (QROPS) is now commonplace. These pension solutions are widely accessible to all US residents or nationals who have accrued pensions from their time working in the UK, and are an invaluable aspect of financial planning… – Continue reading

Australia / G20 / Legislation / OECD / Offshore Companies / Profit Shifting

Corporate tax avoidance inquiry to begin this week, examining some of Australia’s biggest companies

Posted On: April 7, 2015

The financial arrangements of some of Australia’s biggest companies will be in the spotlight this week with a Senate inquiry taking evidence on corporate tax avoidance. The inquiry was initiated by the Greens leader Christine Milne and supported by the Federal Opposition. “We have to actually start really pushing on… – Continue reading

Automatic Exchange of Information / Cairn / Corruption / G20 / India / Legislation / Legislation

Legitimate demands not tax terrorism: FM

Posted On: April 7, 2015

Says India not a tax haven, dues have to be paid if demands are right Finance Minister Arun Jaitley on Monday said India’s tax regime wasn’t confrontational, but added legitimate demands by the Income Tax Department had to be paid. He said there were challenges on the road towards reforms… – Continue reading

Anti money laundering / Asia / Bank of China / Canada / China / Corruption / Directors / Offshore Companies / Offshore Investments / Real Estate / Warnings

Property sales spike sparks money laundering fears

Posted On: April 7, 2015

Suspicions rising that ‘hot money’ is being washed through Vancouver real estate As affluent Chinese buyers – spurred by relaxed regulations and a lower Canadian dollar – flood into British Columbia’s real estate market, warnings are rising that some cash deals may contravene federal money laundering rules. A 2015 report… – Continue reading

Asia / Beneficial Ownership / Brazil / Capital gains / Cyprus / Deloitte / Europe / Hong Kong / Loans / Luxembourg / Monaco / New York / Offshore Companies / Real Estate / Russia / Singapore / Switzerland

Art: A market laid bare

Posted On: April 7, 2015

An arrest over allegations of price fixing has increased calls for tighter regulation of the booming sector On a late February morning, Yves Bouvier arrived at the Monaco home of one of his best clients. He expected Dmitry Rybolovlev, the Russian billionaire owner of AS Monaco football club, to pay… – Continue reading

Double Taxation / Finland / Nokia / OECD / Russia / Tax Laws / Transfer pricing

Board of Adjustment Annulled the Reassessment Decision against Nokian Tyres Plc Concerning Tax Years 2007-2010

Posted On: April 7, 2015

HELSINKI–(BUSINESS WIRE)–Regulatory News: Nokian Tyres plc (HEX:NRE1V) Stock Exchange Release 7 April 2015 3:15 p.m. Board of Adjustment annulled the reassessment decision against Nokian Tyres plc concerning tax years 2007-2010 The Board of Adjustment annulled the reassessment decision from the Tax Administration, according to which the Company was obliged to… – Continue reading

Australia / Brazil / Canada / Cyprus / Double Tax Treaty / Europe / France / Legislation / Monaco / New Zealand / Portugal / PWC / Residence / Spain / Tax treaties / United Kingdom

The ultimate pension freedom: Retire in Portugal and reduce your tax

Posted On: April 7, 2015

New freedoms mean you can move your pension abroad. We show you where you’ll pay the least tax It is the ultimate dream for many people – to work hard, build up a nest egg and retire abroad to a climate with year-round sunshine. Now there is an added financial… – Continue reading

Legislation / Offshore Tax Evasion

New offence risks penalising careless mistakes

Posted On: April 7, 2015

The Chartered Institute of Taxation (CIOT) has criticised the Government’s decision that it will be pressing ahead with the introduction of a new ‘strict liability’ offence for offshore tax evasion. The tax body is opposed to the creation of a criminal offence which will require no proof of intention. Patrick… – Continue reading

DTA / EU / Europe / Greece / Italy / Portugal / Spain / State Aid / Tax Credit

EU studies four countries over banks’ deferred tax assets

Posted On: April 7, 2015

(Reuters) – European Union regulators are scrutinizing four EU countries’ treatment of banks’ deferred tax assets (DTAs) to see if they constitute potentially illegal state aid, the European Commission said on Tuesday. The EU executive said it had contacted authorities in Spain, Italy, Portugal and Greece following requests from some… – Continue reading

Double Taxation / EU / Europe / Greece / Macedonia

MACEDONIA AND GREECE TO START BUILDING TRUST VIA MARKOVA NOGA

Posted On: April 7, 2015

The Markova Noga border crossing in Prespa could be the first project to be carried out of the series of trust-building measures between Macedonia and Greece, sources from the Ministries of Foreign Affairs of both countries have told Dnevnik off the record. The opening of this border crossing, according to… – Continue reading

Europe / Google / Luxembourg / OECD / Profit Shifting / Tax Credit / Tax Laws

UPDATE: Kellogg plays down UK tax concerns

Posted On: April 7, 2015

Kellogg has insisted there is “no link” between its tax situation in the UK and a warning in its annual report changes to tax regulations in international markets could hit profits. A spokesperson for the company told just-food: “The comment in our annual report about potential changes in US tax… – Continue reading

Alki / EU / Europe / Intellectual Property / Netherlands / OECD / Starbucks / State Aid / Switzerland

Starbucks ‘used UK firm’ to cut European tax bill: Coffee chain under investigation after ‘using company to hide millions from Dutch authorities’

Posted On: April 7, 2015

• Starbucks ran its European business – including UK – through Holland • But Dutch division paid just £1.9million tax on profits of £300million • Now details of UK company at heart of new probe have started to emerge • A Starbucks spokesman said it complies ‘with all relevant tax… – Continue reading

Apple / Capital gains / Dividends / FATCA / Ireland / Legislation / Legislation / Tax cheats

Rand Paul’s Record Shows He’s a Champion for Tax Cheats and the Wealthy

Posted On: April 7, 2015

No member of Congress has been more active in the cause of protecting tax cheaters and tax avoidance by our nation’s wealthiest individuals and corporations than Sen.(now presidential candidate) Rand Paul. While Paul is a standard bearer of anti-tax conservatives through his advocacy of radical policies such as the flat… – Continue reading

Legislation

Gaming industry comes out swinging at Assembly tax plan

Posted On: April 7, 2015

A major tax plan proposed by Assembly Republicans — that features an expansion of the Modified Business Tax as a main component — met its major adversary Tuesday at the Legislature. And that is the gaming industry — Nevada’s largest taxpayer and employer. The Nevada Resort Association made its opposition… – Continue reading

EU / Europe / Greece / Italy / Portugal / Spain / State Aid / Tax Credit

EU considers probe into unfair state aid for south European banks

Posted On: April 7, 2015

The EU is collecting evidence to determine if Greece, Portugal, Spain and Italy should face an investigation into whether they are illegally underwriting banks, reports the Irish Times. The EU is collecting evidence to determine if Greece, Portugal, Spain and Italy should face an investigation into whether they are illegally… – Continue reading

Dividends / Double Taxation / Shares / Tax Credit

Australian Foundation Investment Company gives tax grab warning over dividends

Posted On: April 7, 2015

MANY retirees could be forced on to age pensions if they lose tax credits on dividends, Australia’s biggest listed investment company has warned. Australian Foundation Investment Company general manager Geoff Driver says retirees would have less income if the dividend imputation system were scrapped. Higher demand for age pensions would… – Continue reading

Capital gains / Residence

Ways to ensure a great divide

Posted On: April 7, 2015

To reduce the growing urban sprawl most levels of government are allowing higher density housing in the suburbs. This means people with larger residential blocks are presented with an opportunity to subdivide and increase the value of their home. However if the correct steps are not taken when subdividing a… – Continue reading

Directors / India / SEBI

Deadline is over, half of listed PSUs do not have woman directors

Posted On: April 7, 2015

Nearly every second listed state-owned company is yet to comply with the regulatory requirement of appointing a woman director on its board, well after the March 31 deadline announced by market regulator Sebi has passed. Those in violation of the norm are bluechip public sector firms that include ONGC, NTPC… – Continue reading

Apple / Australia / G20 / Google / Microsoft / News Corporation / Profit Shifting

Profit shifting under microscope in senate inquiry

Posted On: April 7, 2015

A SENATE inquiry will examine the tax arrangements of the biggest technology companies in the world today. The tactics used by companies to minimise their Australian tax bills will be under the spotlight, as well as what more could be done to ensure multinationals pay their way. After Treasurer Joe… – Continue reading

Australia / Legislation / Profit Shifting / Tax evasion investigations / Tax Laws

Big business set to face Senate tax avoidance inquiry

Posted On: April 7, 2015

Tax avoidance takes centre stage this week with a parliamentary inquiry due to hold its first public hearings. The Senate inquiry into Tax Avoidance and Profit Shifting will start taking evidence from major technology and mining companies. The inquiry was prompted by a report which found tax minimisation strategies employed… – Continue reading

Category: Regulatory

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