IT’S BECOMING increasingly apparent that the OECD’s plan to reduce tax base erosion and profit-shifting, as laudable as it is, is hugely reliant on the US making significant and drastic alterations to its corporate regime if it is to be successful. The cases of Starbucks and Google have shown us… – Continue reading
A decision from the U.S. to recognize those with agreements “in substance” changes the number of countries with IGAs from 22 to 48. Jeffrey S. Freeman, J.D., LL.M If you notice money missing from your bank account you start asking questions and find a way to get that money back…. – Continue reading
ZAMBIA is reviewing its tax treaty with the Netherlands and Ireland to allow the incorporation of anti-abuse clauses where necessary, a senior government official said.The move, according to tax justice advocates, marks a turning point for Zambia, which has been a key victim to tax avoidance by multinational corporations that… – Continue reading
Switzerland has recently joined a number of nations in the fight against tax evasion by pledging to minimize bank secrecy. This pledge took the form of an accord, signed by 47 nations, under the supervision of the Organisation for Economic Cooperation and Development (OECD). Switzerland, along with countries such as… – Continue reading
More than three quarters of American expats and green card holders who have taken out a supplementary overseas pension contract are able to mitigate the effects of the Foreign Account Tax Compliance Act, it is claimed. The FATCA created controversy when it was announced, as it appeared that people would… – Continue reading
Credit Suisse is pleading guilty to criminal charges and paying a $2.6 billion fine for helping American clients cheat on their taxes over the past decade. The firm helped tens of thousands of Americans hide their wealth, kept lists of companies and accountants who could facilitate tax evasion for clients, and actively recruited U.S…. – Continue reading
While U.S. Attorney General Eric Holder has become synonymous with the belief that some banks are simply “too big to jail”, he can now hang his hat on the fact that under his watch a bank has been found guilty of criminal practices during his watch. A Virginia federal court… – Continue reading
Swiss banking firm Credit Suisse this week pleaded guilty to U.S. tax evasion charges. According to the U.S. Department of Justice, Credit Suisse is the largest bank to plead guilty to such charges in over two decades. The case surrounds a years-long investigation by the U.S. government into a conspiracy to aid… – Continue reading
In a landmark settlement, Credit Suisse Group has agreed to pay $2.6 billion and pleaded guilty to criminal charges that it helped U.S. taxpayers to hide money abroad in the decades leading up to 2009. The outcome of the long-running case has many implications for Credit Suisse account holders. As… – Continue reading
BASSETERRE, St. Kitts, May 21st 2014 (CUOPM) – The St. Kitts and Nevis Federal Cabinet has paved the way for the signing of Tax Information Exchange Agreements (TIEAs) with Ireland and South Africa. Cabinet has approved the draft agreements between officials of the respective countries. “Those negotiation exercises have since… – Continue reading
Efforts to sign new DTAs and update existing DTAs in the first five months of the year will promote tax transparency and facilitate investments, sustaining Singapore’s position as a preferred destination for doing business, says SingaporeCompanyIncorporation.sgSingapore, in a bid to further strengthen its Avoidance of Double Taxation Agreements (DTA) network, has seen new… – Continue reading
The Inland Revenue Department of the Republic of Cyprus is expected to sign the Model 1 InterGovernmental Agreement (“IGA”) with the US Treasury in accordance with the provisions of the Foreign Account Tax Compliance Act (FATCA). FATCA is a US tax legislation that was enacted in March 2010 in order… – Continue reading
On October 13, 2009, the government of Georgia and the government of the State of Kuwait have signed an Agreement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital. The treaty entered into force on April 14, 2013,… – Continue reading
Robert Stack, deputy assistant secretary for international tax affairs with the U.S. Treasury, gave an update on several items in the OECD’s project to combat base erosion and profit shifting at the American Bar Association Section of Taxation’s May meeting. As reported more fully by Transfer Pricing Report’s Kevin Bell, Stack,… – Continue reading
In an effort to tighten rules on corporate tax avoidance through “inversions,” U.S. Senator Tim Kaine joined a group of 13 Senators today to introduce The Stop Corporate Inversions Act of 2014, legislation to address the practice of reincorporating offshore to avoid paying U.S. taxes. The bill is designed to prevent… – Continue reading
If you have clients who own Greek bonds (government or corporate), they may have immediate tax-filing concerns. A PwC notice explains that investors not resident in Greece who realized gains between February 29, 2012 and December 31, 2013 owe the Greek government 20% in taxes. It’s due June 25, and… – Continue reading
Macquarie Group has acknowledged that a revised tax bill following a full-scale audit by Tax Office investigators may be market sensitive and could move its share price. The information, which relates to three years of additional tax, has never been disclosed by the homegrown investment bank to the sharemarket. Macquarie’s… – Continue reading
With the recent passing of the 5 May 2014 registration deadline to be included in the first IRS GIIN list on 2 June 2014, and the 3 June 2014 registration deadline for the 1 July 2014 GIIN list imminent, this update outlines the practical implications for CLO issuers incorporated in… – Continue reading
With any opportunity that seems too good to be true, there is often a fatal flaw. That is the case with The Partnership to Build America Act, introduced by U.S. Rep. John Delaney, D-Md., and U.S. Sen. Michael Bennet, D-Colo. The bill offers a way for multinational corporations to bring… – Continue reading
MILAN — Fiat Chrysler Automobiles’ new London headquarters will have a staff of about 50 people, most of whom will have a finance background, said two people familiar with the details of the automaker’s plan to shift its tax residency to the UK. Fiat Chrysler CEO Sergio Marchionne and Fiat… – Continue reading
Many share my concern that, if information is held by a tax agency in virtually any country, there is no confidence it could not be transferred to a different agency of that country, says Martyn Gowar A PROBLEM SHARED The pragmatic bullying of the United States has reached a new… – Continue reading
Alliance Boots has challenged claims of tax avoidance regarding its diminutive £2m corporation tax bill, as boss Stefano Pessina stated the group was fully tax compliant and should not have to justify its tax affairs. The pharmacy giant had reported a 31% surge in net profits to £971m. However, it… – Continue reading
GlaxoSmithKline Plc (GSK)’s China unit was accused by a government-run legal newspaper of failing to pay more than 100 million yuan ($16 million) in import duties and taxes for its HIV treatment. The company evaded the taxes from 2005 to 2008, China’s Legal Daily newspaper reported May 16 on its… – Continue reading
On May 9, 2014, the U.S. Treasury announced that Hong Kong had agreed in substance on a Model 2 FATCA IGA. Under the IGA, Hong Kong financial institutions will report information on financial accounts held by U.S. persons directly to the Internal Revenue Service. Hong Kong is only the seventh country… – Continue reading
A criminal case has been opened in Portugal against Brazil’s football coach Luiz Felipe Scolari weeks before Brazil hosts the World Cup. He has been named as a formal suspect in a tax fraud investigation but he has not been arrested or charged. Mr Scolari, 65, was Portugal’s head coach… – Continue reading
Liechtenstein said Friday that it has signed a anti-tax fraud pact with Washington that requires banks in the principality to provide information about accounts held abroad by US taxpayers to US authorities. Under the agreement, Liechtenstein would implement the Foreign Account Tax Compliance Act (FATCA), which came into effect on… – Continue reading
Credit Suisse Group is close to reaching an agreement to plead guilty and pay about US$2.5 billion to the US Department of Justice and regulators to resolve investigations into whether it helped Americans evade taxes. The Zurich-based bank would pay about US$1.7 billion to the justice department, at least US$600… – Continue reading
The Financial Services Authority (OJK) has proposed that the government demand reciprocal cooperation with the US regarding the latter’s request to apply its Foreign Account Tax Compliance Act (FATCA) in the country. FATCA is a law that the US has unilaterally imposed on the rest of the world to prevent… – Continue reading
First Minister Alex Salmond has refused to back calls for a boycott of Amazon after reports the company is engaging in large-scale tax avoidance. During First Minister’s Questions on Thursday afternoon, Scottish Green MSP Patrick Harvie cited concern over “further revelations about the scale of the scandal of tax avoidance… – Continue reading
CARACAS, May 17, 2014 – (WAFA) – President Mamhoud Abbas signed Saturday energy and double taxation avoidance agreements with his Venezuelan counterpart Nicolas Maduro at Miraflores presidential palace in Caracas. Abbas started Friday a three-day official visit to the Caracas, where he was received by Maduro. They exchanged views on the peace process as well… – Continue reading
Residential property owners need to be aware of some proposed changes, which will have a significant impact on their CGT liabilities. Final period exemption reduced If a property has, at any point, qualified as an individual’s main residence then the final 36 months would have been covered by relief from… – Continue reading
The new Mexican Income Tax Law (“MITL”) that entered into force on January 1 modified the so-called procedural provisions concerning the application by multinational companies of benefits set forth under tax treaties negotiated and executed by Mexico. Accordingly, foreign residents claiming tax treaty benefits (either for a tax exemption or… – Continue reading
NEW DELHI, MAY 14: With tax authorities pressing with over Rs 21,000 crore in unpaid dues, Finnish telecom major Nokia has invoked the Bilateral Investment Promotion and Protection Agreement (BIPA) India has with Finland to resolve the dispute. Nokia late last month wrote to Prime Minister invoking dispute settlement clause… – Continue reading
Corporate Tax Avoidance: Last week the news that Apple is considering buying Beats Electronics, a maker of expensive headphones that was founded by record mogul Jimmy Iovine and rap artist Dr Dre, for $3.2bn, got a lot of media attention. Dr Dre must have pissed-off Apple when he bragged on… – Continue reading
Caterpillar, industrial and construction equipment manufacturing Goliath, has been avoiding or deferring paying U.S. taxes for at least 13 years to the tune of approximately $2.4 billion, according to a report from the Homeland Security & Government Affairs Permanent Subcommittee on Investigations. “Tax evasion schemes rob the system of billions of… – Continue reading
The head of US bank Goldman Sachs has warned that guilty pleas from rivals BNP Paribas and Credit Suisse, under legal proceedings in the United States, could hurt the financial system. The two European banks, under probes for violating US sanctions and abetting tax evasion, are potentially facing very heavy… – Continue reading
Credit Suisse Group AG (CS – Snapshot Report) may shell out around $2.5 billion as settlement charges and is expected to plead guilty related to an ongoing tax probe by the United States Department of Justice (:DOJ). The Swiss banking giant is alleged to have deliberately helped its clients in… – Continue reading
On 28 April 2014, the Australian Government signed an agreement (the intergovernmental agreement) with their U.S. counterparts that will greatly assist Australian financial institutions that must comply with the requirements of the Foreign Account Tax Compliance Act (FATCA) legislation, enacted by the U.S. Government. The FATCA regime is, at its core,… – Continue reading
Hong Kong and the United States have concluded their discussions on the implementation of the Foreign Account Tax Compliance Act, with Hong Kong expected to sign a model 2 intergovernmental agreement later this year. Under the model 2 agreement, financial institutions in Hong Kong will need to register and conclude… – Continue reading
Despite a push to obtain agreements with foreign governments through April, the US Treasury’s own website notes the large number of outstanding Intergovernmental Agreements yet to be implemented fully around the Foreign Account Tax Compliance Act (Fatca). So-called IGAs are critical for the success of the US Foreign Account Tax… – Continue reading
NEW YORK/ WASHINGTON New York state’s banking regulator is seeking hundreds of millions of dollars from Credit Suisse in its probe of potential tax evasion involving the Swiss bank, according to sources close to the matter, which could push an eventual settlement with US authorities over $2 billion.The New York… – Continue reading
A £100m charity tax avoidance scheme similar to the Cup Trust has been defeated at a tax tribunal by HM Revenue & Customs.According to the judgment handed down this week by the first tier of the tax tribunal, the Bluebox scheme used a method where government bonds were given to… – Continue reading
A decision to drop tax and money laundering charges against three high-profile Sydney businessmen is ”another humiliating defeat for the Project Wickenby Keystone Cops”, according to a lawyer close to the trio. Charges attracting jail of up to 25 years, laid against former CVC Limited chairman Vanda Gould, former Sunland… – Continue reading
Azerbaijan and Saudi Arabia plan to sign an agreement on the avoidance of double taxation, as well as tax evasion, the ambassador of Saudi Arabia Musaid bin Ibrahim bin Abdullah Al-Salim told a press conference. The ambassador said the agreement is expected to be signed during the Azerbaijani foreign minister… – Continue reading
The head of Canada’s investment industry association is urging the federal government not to defer legislation that will facilitate handing tax information of U.S. citizens living in Canada to authorities in the United States. Ian Russell, chief executive of the Investment Industry Association of Canada, made his pitch to the… – Continue reading
World Cup presenter Gabby Logan invested in the tax avoidance scheme used by Gary Barlow and two Take That bandmates. Gabby, who is on the BBC’s frontline team for Brazil, ploughed cash into part of a £12.3million partnership which aimed to shelter earnings from the taxman. The TV star, who… – Continue reading
Puerto Rico’s tax incentive acts are tailor-made for traders, investors, investment managers and financial institutions. Enacted in 2012, Puerto Rico’s Act 22 allows investors and traders with bona fide residence in Puerto Rico to exclude 100% of all short-term and long-term capital gains from the sale of personal property accrued… – Continue reading
Hong Kong and the United States have substantially concluded discussions on an inter-governmental agreement (IGA) to simplify Hong Kong financial institutions’ compliance with the Foreign Account Tax Compliance Act. The Financial Services and the Treasury Bureau (FSTB) said that the IGA “will reduce Hong Kong financial institutions’ reporting burden and… – Continue reading
Taiwan’s Financial Supervisory Commission (FSC) has confirmed that it expects to conclude an intergovernmental agreement (IGA) with the United States regarding the Foreign Account Tax Compliance Act (FATCA) by the end of June this year. FATCA, enacted by the US Congress in 2010 and due to take effect on July… – Continue reading
The tax probe causing grief to Credit Suisse is demonstrating a break from legal precedent. Despite the case being compared to the UBS scandal, it seems to be courting a more costly and punitive outcome. UBS eventually resolved claims that it systematically helped clients evade taxes in a $780m deferred… – Continue reading
