The Obama Administration, along with a couple senators, have been leading a campaign of moral indignation against “inversions.” In tax terms, inversions are a U.S. incorporated company changing its residence to a lower tax country to reduce the tax burden on its income. Because U.S. companies are taxed in the… – Continue reading
Criminal fines imposed on corporations should not be tax deductible, but tax rebates could be claimed on illegally gained profits that a court has ordered a company to pay back, the Swiss government advised on Friday. The cabinet was responding to a parliamentary motion to clarify the situation in light of a… – Continue reading
Although the Foreign Account Tax Compliance Act (FATCA) went “live” July 1, 2014, guidance continues to fall into place. On July 16, the IRS issued instructions for the requester of various Forms W-8 and continues to update its FAQ website. The Cayman Islands Tax Information Authorityissued regulations effective July 4, 2014 addressing the… – Continue reading
The French and Luxembourg Finance Ministers signed, on 5 September 2014, a Protocol amending Article 3 (the “Protocol”) of the France-Luxembourg double tax treaty for the avoidance of double taxation and the establishment of rules of reciprocal administrative assistance with respect to taxes on income and fortune (the “Tax Treaty”)…. – Continue reading
A political advisor for the government of the former Vanuatu Prime Minister Moana Carcasses, French national Gilles Daniel, has had his Vanuatu citizenship revoked. Mr Daniel has already been deported from Vanuatu in 2005, but challenged his deportation, with the court ruling in his favour. The secretary of the Vanuatu… – Continue reading
Withholding on US source income under FATCA started on 1 July 2014. The withholding will apply to gross “proceeds of sale” of securities bearing US source income (which includes repayment of principal on a loan to a US borrower) and, potentially, to “foreign passthru payments” from January 2017. Now that… – Continue reading
London and Singapore are fast closing the gap on Hong Kong in the race to become centres for offshore renminbi business and capitalise on Beijing’s ambition to make the RMB a global currency. Fred DiCocco, Asia-Pacific head of sales & relationship management for BNY Mellon’s Treasury Services business, says London… – Continue reading
High quality global journalism requires investment. Please share this article with others using the link below, do not cut & paste the article. See our Ts&Cs and Copyright Policy for more detail. High quality global journalism requires investment. Please share this article with others using the link below, do not… – Continue reading
Rep. Mark Pocan, D-Wis., has introduced three pieces of legislation to close tax breaks that enable U.S. multinational corporations to use so-called “inversions” in which they merge with a foreign company and move their tax domicile abroad to a low-tax country to reduce corporate taxes. Corporate inversions are used by… – Continue reading
A contingent of so-called “corrupt clients” from Canada have been caught in the net of a massive fraud investigation by the FBI and the U.S. Attorney, a source close to the investigation told CBC. CBC News reported Wednesday that two Canadians, along with four others, were indicted in the U.S…. – Continue reading
The offshore tax affairs of a company previously headed by the economics minister are to be re-examined by the finance department of canton Bern. The move comes after Swiss Public Television, SRF, published a memo written by the Federal Tax Authorities (FTA) which raised questions about the previous investigation. The… – Continue reading
On 5 September 2014, the Governments of France and Luxembourg signed an amendment to the France-Luxembourg treaty dated 1 April 1958 (the “Treaty”), which will have an impact in the future for certain investments in French real estate. Indeed, the amendment introduces new provisions under Article 3 paragraph 4, allocating… – Continue reading
Outsourcing the responsible officer (RO) function under the Foreign Account Tax Compliance Act (FATCA) offers limited value to Cayman-Islands’ domiciled fund managers.The Model one Intergovernmental Agreement (IGA) between the Cayman Islands and the US does not stipulate that a responsible officer is required. The responsible officer title is a feature… – Continue reading
EVEN MORE Philippine companies have complied with a US tax law since a July 1 deadline, after which foreign financial institutions (FFIs) not yet registered with the US Internal Revenue Service (IRS) faced penalties. A list published by the IRS earlier this month showed that a total of 197 Philippine-based… – Continue reading
Washington, DC—(ENEWSPF)—September 5, 2014. Joshua Vandyk, an investment advisor, was sentenced today to serve 30 months in prison for conspiring to launder monetary instruments, the Justice Department and Internal Revenue Service (IRS) announced. Vandyk, a U.S. citizen, and Eric St-Cyr and Patrick Poulin, Canadian citizens, were indicted by a grand… – Continue reading
MINNEAPOLIS (WCCO) — A 43-year-old Vadnais Heights investment advisor pleaded guilty to accusations that he spent clients’ money on personal items instead of investing their funds, the United States Attorney’s Office announced Wednesday. Joel William Carlson, who was charged on Aug. 4, pleaded guilty Wednesday to two counts of tax evasion… – Continue reading
The tax authorities of the United Kingdom and Canada are to deepen cooperation to establish a stronger mutually beneficial relationship, senior officials from both Government have said. Canada’s Revenue Minister, Kerry-Lynne D. Findlay, met with David Gauke, the UK’s Financial Secretary to the Treasury, in London on September 8. Findlay… – Continue reading
Sen. Charles Schumer (D-N.Y.) released legislation Wednesday seeking to roll back the tax benefits for companies that reincorporate abroad. Schumer’s bill takes aim at a maneuver known as earnings stripping, a process by which U.S. subsidiaries can take tax deductions on interest stemming from loans from a foreign parent. The… – Continue reading
Retroactive legislation curtails tax-avoidance schemes but undermines faith in a government that changes the rules of game after an investment is made The temperature is rising in the United States over corporate inversions. U.S. Treasurer Jacob Lew is looking to pass retroactive law to undo recent corporate restructurings and, with… – Continue reading
On 1 August 2014, the “Provisional Measures on the Collection of Tax on Non-Resident Taxpayers Engaged in International Transportation Business” (2014 No.37 Notice, the “New Regulations”) came into force. The New Regulations could have a significant impact on owners as they seek to streamline and tighten up the regulations in respect of… – Continue reading
The Federal Court has handed down its decision in the case of Task Technology v Commissioner of Taxation in relation to the tax treatment of specific software payments. The case related to payments made by Task to CaseWare International Inc (CWI) for the right to market and distribute CWI software to end users… – Continue reading
Now that we have new cabinet ministers to drive the economy forward, the next expectation is for martial law to be lifted so that foreign investors and tourists can feel more comfortable about returning to Thailand. Meanwhile, the junta is determined to quickly show the people some signs of genuine… – Continue reading
Minister of National Revenue concludes two days of meetings in London LONDON, ENGLAND–(Marketwired – Sept. 9, 2014) – Canada Revenue Agency The Honourable Kerry-Lynne D. Findlay, P.C., Q.C., M.P., Minister of National Revenue, today wrapped up a successful two-day trip to London, England. During her visit, Minister Findlay met with David… – Continue reading
The DTA between Cyprus and United Arab Emirates took effect on 1 January 2014 The double taxation agreement between Cyprus and the United Arab Emirates took effect on 1 January 2014. For a detailed analysis of the new agreement, the first between the two countries, please follow this link. The… – Continue reading
Johannesburg – More than 260 cases of tax evasion were successfully prosecuted by the National Prosecuting Authority during the last financial year. Sars spokeswoman Marika Muller said about 330 tax-related criminal cases were finalised during the 2013/14 financial year, of which 267 were successfully prosecuted. Muller said to deter non-compliance, Sars… – Continue reading
Scandal Is an Embarrassment to Separatists Planning Independence Referendum BARCELONA— Jordi Pujol often said he discovered his mission for Catalonia while climbing a mountain as a boy and seeing the destruction wrought by the Spanish Civil War of the 1930s. Decades later, as Catalonia’s long-serving leader, Mr. Pujol presided over… – Continue reading
Noble Energy and Jordan recently signed a nonbinding agreement for the sale of 8.5% of Leviathan’s gas over the course of 15 years, for as much as $15 billion. By Avi Bar-Eli | Sep. 9, 2014 | 2:47 AM The preliminary deal for the sale of gas to Jordan from… – Continue reading
UBS AG (UBSN) asked a Paris appeals court to overturn a $1.4 billion bail looming over the Swiss bank as France steps up a two-year-old tax evasion probe. The hearing dragged on for nearly three hours as the parties argued the case. The court said it would decide on the… – Continue reading
A retired businessman from Northern Ireland has made a 13.5 million euro (£10.8m) settlement with the tax man in the Republic – one of the largest ever. Anthony Cafferkey, from Lisnarick Road, Irvinestown, Co Fermanagh has been named and shamed on the latest defaulters’ list over his tax affairs. Listed… – Continue reading
A former Chinese citizen, Ruihua Yau, has been declared stateless by the Vanuatu government. The Secretary General of the Citizenship Commission, John Enock Ware, has confirmed that the agency revoked Mr Yau’s certificate of Vanuatu citizenship last month. Mr Ware says the Commission found Mr Yau got Vanuatu citizenship after… – Continue reading
A multi-count indictment was unsealed this morning in federal court in Brooklyn, New York, against six individual defendants: Robert Bandfield, a U.S. citizen; Andrew Godfrey, a citizen of Belize; Kelvin Leach, a citizen of the Bahamas; Rohn Knowles, a citizen of the Bahamas; Brian De Wit, a citizen of Canada;… – Continue reading
According to the data obtained by investigators, the bank’s executives evaded paying taxes amounting to over 380 million rubles ($10.2 million) in 2011 MOSCOW, September 9. /ITAR-TASS/. Russian police have been conducting searches in the Moscow office of National Reserve Bank (NRB) belonging to businessman Alexander Lebedev for the first… – Continue reading
On Tuesday, the SEC and the Justice Department charged several companies claiming to be located on the same floor of an office building in Belize City with fraud and conspiracy. We may not have heard the last from Cynk Technology. On Tuesday, the Securities and Exchange Commission and the Department… – Continue reading
The Irish tax authority, the Revenue Commissioners, has released eBrief No. 75/14 on double tax relief for individuals subject to the High Earners Restriction, following changes in the Finance (No. 2) Act 2013. The 2006 and 2007 Finance Acts introduced, with effect from January 1, 2007, measures to limit the… – Continue reading
Principal source of information for Israel Tax Authority probe comes from someone who obtained information from foreign tax authorities and handed it over to Israeli officials. A gag order is expected to be lifted in the next few days on a major investigation of tax evasion by scores of Israelis… – Continue reading
U.S. companies are shifting their addresses abroad to reduce their taxes Treasury Secretary Jacob Lew said Monday the Obama administration will decide “in the very near future” what actions it can take to make it less profitable for U.S. companies to shift their legal addresses to other countries. A growing… – Continue reading
HM Revenue & Customs has established a taskforce to deal specifically with people trying to dodge property tax in the south west of England and in south Wales. The taskforce will target those who have sold one or more properties and haven’t paid capital gains tax or disclosed rental income…. – Continue reading
Minister, Embassy of Japan Mr. Isomata Akio asked India to exempt Japanese manufacturers, operating in India from withholding tax and Minimum Alternate Tax (MAT) so that these do not evolve into being one of the trade barriers and stagger Japan from becoming India’s largest trade partner in times to come. Japan investments and technology… – Continue reading
The Irish tax authority, the Revenue Commissioners, has released eBrief No. 75/14 on double tax relief for individuals subject to the High Earners Restriction, following changes in the Finance (No. 2) Act 2013. The 2006 and 2007 Finance Acts introduced, with effect from January 1, 2007, measures to limit the… – Continue reading
On July 21, the Organisation for Economic Co-operation and Development (OECD) published its Standard for Automatic Exchange of Financial Account Information in Tax Matters. The report contains the OECD’s model competent authority agreement (CAA), the common standard on reporting and due diligence for financial account information (CRS) and commentaries on both the CAA and CRS.The… – Continue reading
A recent Tax Court decision1 addressed the tax consequences to a Finnish citizen of wages she received while working as an employee in the United States on behalf of her country’s Permanent Mission to the United Nations. The case involves Sole Abrahamsen, a Finnish citizen, who began working at Finland’s Permanent… – Continue reading
The Commodity Futures Trading Commission (CFTC) is wary of banks invoking guarantees on foreign swap deals, and is taking steps to scrutinize such activity. The Commodity Futures Trading Commission (CFTC) is wary of US banks shifting their trading activities offshore and has urged other regulators to scrutinize banks involved in… – Continue reading
MONTREAL – The disclosure by Valeant Pharmaceuticals International Inc. that it is under audit by the U.S. Internal Revenue Service is raising further doubts among tax specialists about the future of the Quebec-based drug company’s tax strategies. Valeant estimates it has achieved US$2.5-billion in tax and other “corporate structure” savings… – Continue reading
The American Chamber of Commerce Ireland chief says ‘can-do attitude’ of Irish workforce is key ingredient for multinationals In the global tax game, Ireland is a mere pawn, powerless in the face of big corporations and their aggressive tax avoidance schemes. It’s no secret that these firms inhabit a parallel… – Continue reading
From 6 April 2013 an individual’s residence status for UK tax is determined using the statutory residence test (SRT). The SRT flowchart overleaf is designed to assist in determining the residence status of individuals. The legislation and guidance is lengthy and the flowchart and notes can only give a brief… – Continue reading
The police conducted on Monday morning, September 8, searches at several companies in Romania in a case of tax evasion in the sale of software. The searches took place at 7 places in Bucharest and Ilfov and Giurgiu counties, targeting the suspects’ homes and several companies. According to sources quoted by… – Continue reading
The Isle of Man has signed a Tax Information Exchange Agreement (TIEA) with the Kingdom of Swaziland.The TIEA was signed by Eddie Teare MHK, the Isle of Man’s Treasury Minister, in the Isle of Man, and by Senator Martin G. Dlamini, Swaziland’s Minister for Finance, in Swaziland, and exchanged by… – Continue reading
With the Canadian government’s decision to comply in July with a Washington tax crackdown on “U.S. persons” around the world, many Ameri-Canadians are feeling rising anger, fear and even hatred toward their powerful country of origin. That said, the self-identities of Americans in Canada have been more ambiguous than they… – Continue reading
High quality global journalism requires investment. Please share this article with others using the link below, do not cut & paste the article. See our Ts&Cs and Copyright Policy for more detail. C Three US companies seeking to use controversial takeovers to cut their US tax bills hold at least… – Continue reading
The verdict serves as reference for invoking treaty abuse provisions in the absence of General Anti-Avoidance Rules Mukesh Butani September 7, 2014 Last Updated at 22:33 IST In a ruling demonstrating wise judicial discipline, the Delhi High Court (HC) recently upheld non-taxability of sale of shares in an offshore company… – Continue reading
