Ukrainian President Petro Poroshenko hopes that the signing of the revamped intergovernmental agreement to avoid double taxation would facilitate the development of economic relations between Ukraine and Cyprus. “Following the negotiations, the parties signed 4 documents, inter alia, those allowing the avoidance of double taxation. The head of state expressed… – Continue reading
Something unusual is happening with the Irish corporation tax in 2015 — so unusual that Ireland’s top tax man felt obliged to write to the parliament to explain what is going on. But the explanation left a lot to be desired. According to government data, Ireland received 57.7 percent more… – Continue reading
The Cayman Islands Tax Information Authority (“TIA“) has issued an advisory addressing several points of note regarding the Common Reporting Standard (“CRS“) in the Cayman Islands. Updated Self-Certification Forms The TIA has published new entity and individual self-certification forms which address the account holder disclosure requirements under each of CRS,… – Continue reading
FATCA requires sponsored entities (including those governed by an IGA) to have their own Global Intermediary Identification Number (GIIN) for FATCA reporting and withholding purposes by 31 December, 2016. Under a transitional rule, it is possible for one FFI to act as a sponsor for a number of other FFIs…. – Continue reading
Providenciales, 08 Dec 2015 – Since December of 2014, the Turks and Caicos signed an Intergovernmental agreement or IGA so that the laws of the US FATCA or Foreign Accounts Tax Compliance Act and the UK equivalent could have force in these islands. Last month, the Ministry of Finance issued… – Continue reading
Indian entities will do a reciprocal information sharing about Americans The Finance Ministry today said it has received information from the US under the financial information exchange pact FATCA in the last two months and it is being analysed. The Foreign Account Tax Compliance Act (FATCA) came into effect from… – Continue reading
Right to levy capital gains tax by India is also part discussions, he said India is engaged in “positive talks” with Mauritius on revision of bilateral tax treaty as some issues still need to be sorted out, an official said today. “Negotiations have been going on. Talks with Mauritius have… – Continue reading
On 23 November 2015 Guernsey issued regulations to implement the Common Reporting Standard (“CRS”) under Guernsey’s domestic law. The regulations follow on from the commitment made on 29 October 2014 by Guernsey, along with the other Crown Dependencies and a number of other jurisdictions, to start exchanging information under the… – Continue reading
The reporting deadline for Portuguese financial institutions to communicate information required under the FATCA regime to the Portuguese tax authorities has been extended to 31 December 2015. The FATCA deadline was extended by a 30 November 2015 order. This is the second time that the FATCA reporting deadline has been… – Continue reading
KUWAIT CITY, Nov 29: “The world of taxation has changed tremendously impacted by FATCA, transfer pricing, Base Erosion and Profit Sharing, and others which require dramatic changes in existing operating models and structures,” remarked Fouad Douglas, PwC Country Senior partner, at a tax seminar organised by the PwC in conjunction… – Continue reading
Final regulations implementing the common reporting standard (CRS) have been published in the Isle of Man. In addition, it has been announced that the existing intergovernmental agreement (IGA) between the Isle of Man and the UK will be superseded by CRS, and that 2016 will be a transitional year. Read… – Continue reading
Over 90 jurisdictions have committed to the OECD’s Common Reporting Standard (CRS), creating comprehensive global automatic information exchange for financial assets and the entities through which such assets may be held. Over 70 jurisdictions have signed the OECD’s Multilateral Competent Authority Agreement, which implements the CRS. The CRS is scheduled… – Continue reading
The IRS has upgraded the Foreign Account Tax Compliance Act (FATCA) Online Registration System, enabling sponsoring entities to register their sponsored entities to obtain a global intermediary identification number. The upgraded system also will allow users to update their information, download registration tables and change their financial institution type. The… – Continue reading
THE United States of America (USA) wants all companies of US origin, individuals and body corporates that are resident in Swaziland to report their financial information in their home country, the USA. This development is a result of Swaziland government announcing that it will implement the United States Foreign Account… – Continue reading
PRESS RELEASE – On November 19, the government of St. Lucia signed an agreement with the Government of the United States of America to implement the U.S. Foreign Account Tax Compliance Act (FATCA). Enacted by the U.S. Congress in 2010, FATCAtargets non-compliance by U.S. taxpayers using foreign accounts. FATCA requires… – Continue reading
BearingPoint’s FiTAX catches on while a FATCA critic says that more Americans are renouncing their citizenship because of the controversial tax law. While controversy swirls around the Foreign Account Tax Compliance Act (FATCA), management and technology consultancy BearingPoint reports that between March and August 2015, more than 2,000 financial institutions… – Continue reading
Draft regulations in Guernsey for implementing the common reporting standard (CRS) for the automatic exchange of information are expected to be published in final form in early 2016. Guernsey has indicated its commitment for adopting the CRS, with effect from 1 January 2016, so that the first reporting would take… – Continue reading
Some time ago we wrote an article on the Foreign Account Tax Compliance Act (‘FATCA’) which says that although the FATCA tentacles are fairly intrusive, at the end of the day, it represents just another form for tax payers to complete. Rather to my surprise this article elicited a threat… – Continue reading
Thanks to the FiTAX tax reporting solution, some 2,000 financial institutions successfully met the reporting requirements of tax authorities. FiTAX FATCA covers more than 45 countries. ZURICH, SWITZERLAND—(Marketwired – Nov. 12, 2015) – 2015 marks a turning point in the FATCA timeline: for the first time, Financial Foreign Institutions (FFIs)… – Continue reading
Hyderabad: Customers of several public and private sector banks across the Telangana and Andhra Pradesh are finding fault with their bankers for asking to fill up more forms under Foreign Account Tax Compliance Act (FATCA), and Common Reporting Standard (CRS). The new rules have come into effect from November 1,… – Continue reading
The implementation of the Foreign Account Tax Compliant Act is showing consistent progress with thousands of banks in over 150 countries agreeing to share financial accounts data of their US clientele with US taxation authorities. This clearly indicates the firm resolve of the US administration to make this initiative a… – Continue reading
Luanda — A substantially Intergovernmental Agreement under the Foreign Account Tax Compliance Act (FATCA) was signed Monday in Luanda between the Ministry of Finance and the government of the United States of America, represented by its ambassador to Angola. According to the Internal Revenue Service (IRS), the US tax authority,… – Continue reading
United States taxpayers using foreign accounts in the United Arab Emirates may see more rigorous enforcement of the Foreign Account Tax Compliance Act, or FATCA, in the UAE, as obligations for UAE financial institutions have been ramped up under a new intergovernmental FATCA Agreement between the U.S. and the UAE,… – Continue reading
On September 18, 2015, the Internal Revenue Service (IRS) released Notice 2015-66 announcing its intention to amend certain of the regulations under Chapter 4 of the Code (the “FATCA regulations”), to extend the period of time that certain of the Foreign Account Tax Compliance Act (FATCA) transitional rules will apply,… – Continue reading
Germany’s Federal Ministry of Finance on 3 November 2015 released final guidance notes for implementation of the FATCA regime. An intergovernmental agreement (IGA) signed by Germany and the United States follows the Model 1 IGA. Accordingly, financial institutions in Germany are required to report information concerning assets held by U.S…. – Continue reading
ABSTRACT This paper provides analysis of one of the foundational elements of the Foreign Account Tax Compliance Act (FATCA) and various intergovernmental agreements (IGAs): an unambiguous place of U.S. birth and the ability to cure (Cure) this element, thereby rendering the account nonreportable. The IGAs generally allow the individual to… – Continue reading
On August 4 and 5, 2015, the FC heard oral arguments in a lawsuit—commenced on August 11, 2014 by two Canada-US citizens—that challenges the law implementing the Canada- US intergovernmental agreement (IGA) relating to FATCA (Virginia Hillis et al. v. The Attorney General of Canada et al., court file no…. – Continue reading
BACKGROUND The IRS recently released IR-2015-116 announcing its offshore compliance programs have generated $8 Billion. More than 54,000 taxpayers subject to U.S. worldwide income and disclosure requirements have come in from the cold to participate in IRS offshore remediation disclosure programs since 2009. The IRS also urged taxpayers with non-compliant… – Continue reading
As noted in our previous updates on the Foreign Account Tax Compliance Act (FATCA) and the related intergovernmental agreement between Canada and the United States for the enhanced exchange of tax information (the IGA), many Canadian financial institutions such as IFMs, portfolio managers, exempt market dealers and investment funds were… – Continue reading
(MENAFN – Arab Times) The US Foreign Account Tax Compliance Act (FATCA) model has spurred the rise of a global automatic exchange of information, informed Hannah Shipley, Director at Ernst & Young, while speaking about FATCA and its implications during a business panel discussion held at the Kuwait Chamber of… – Continue reading
Republican and Democratic lawmakers vowed on Thursday to push for the ratification of eight tax treaties which have been held up for years because of one Republican senator’s objections, despite support from companies that want consistency in rules for how to do international business. U.S. Senator Rand Paul of Kentucky… – Continue reading
You must have received an email or a letter from your mutual fund (MF), if you have been investing in MFs, asking for some details. If you haven’t yet received such communication, you might receive a letter or email shortly. Your fund house wants to know if you pay taxes… – Continue reading
“He hath founded it upon the seas…” Psalm 24:2 From an ancient decree The motto on the Cayman Islands flag has profound meaning for all residents, whether indigenous or not. At 3:00am on 7 February 1794 the Royal Navy Frigate HMS Convert and its convoy of nine merchant ships were… – Continue reading
KEY POINTS What is the issue? Guernsey will be required to gather data for the calendar year 2016 for reporting under the Common Reporting Standard (CRS) in 2017. What does it mean for me? Practitioners should be aware that due diligence and reporting procedures are set to be amended and… – Continue reading
Just one day after the October 15 deadline for filing personal income tax returns on extension, the Internal Revenue Service issued a strongly-worded warning to non-compliant taxpayers: take action now to fix your problem, or face serious consequences. At the same time, the IRS revealed, for the first time, that… – Continue reading
With more than 54,000 taxpayers coming in to participate in offshore disclosure programs since 2009, the Internal Revenue Service is reminding U.S. taxpayers with undisclosed offshore accounts that they should strongly consider existing paths established to come into full compliance with their federal tax obligations. Both the Offshore Voluntary Disclosure… – Continue reading
In a summary judgment released on September 16, 2015, the Federal Court of Canada examined and disposed of the non-constitutional arguments in the Hillis and Deegancase[1] generally finding that the automatic data collection and disclosure of taxpayer information to the United States by Canada pursuant to the Canada-U.S. Intergovernmental Agreement… – Continue reading
FATCA was passed to prevent U.S. citizens from evading tax by focusing primarily on foreign financial institutions with U.S. account holders. The Foreign Account Tax Compliance Act (FATCA) was enacted as part of the 2010 Hiring Incentives to Restore Employment Act, and its provisions became effective as of 7/1/14. FATCA… – Continue reading
To facilitate the exchange of Foreign Account Tax Compliance Act (FATCA) data under the intergovernmental agreements (IGAs) with Australia and the U.K., the U.S. Competent Authority has signed Competent Authority Arrangements (CAAs) with the Competent Authority of each country, announced IRS officials on September 24. The CAAs are the first… – Continue reading
The Government of India, Ministry of Finance had on August 7, 2015, in order to comply with the information reporting requirements of the US’ Foreign Account Tax Compliance Act (hereinafter referred to as ‘FATCA’), made amendments in the Income-tax Rules, 1962. WHAT IS FATCA’S BACKGROUND? FATCA is a broad set… – Continue reading
At a recent tax conference a senior Justice Department official reaffirmed the commitment of the U.S. Department of Justice to continue offshore enforcement efforts. As is widely reported the official stated: “We are well beyond Switzerland at this point,” she said, citing enforcement announcements concerning India, Israel, Liechtenstein, Panama, the… – Continue reading
On October 2, 2015, the U.S. Internal Revenue Service (IRS) announced the exchange of financial account information with certain foreign tax administrations in compliance with their obligations under various intergovernmental agreements (IGAs) put in place to implement the Foreign Account Tax Compliance Act (FATCA). IRS Commissioner John Koskinen stated that… – Continue reading
The IRS has posted text of a Competent Authority arrangement (CAA) between the United States and Hungary, pursuant to the intergovernmental agreement (IGA) signed in 2014 to implement the FATCA regime. The CCA with Hungary follows CAAs that were signed by the United States in September 2015 with both the… – Continue reading
In 2016, hundreds of directors, managers, principal points of contact (PPCs), compliance officers, administrators, and Money Laundering Reporting Officers (MLROs) serving Cayman Islands funds, banks, trust companies and other Reporting Financial Institutions (RFIs) will start to feel the full force of ‘a great wind’: global tax transparency. If you are… – Continue reading
Guidance issued by the French tax administration sets forth instructions for French “reporting financial institutions” to follow in order to comply with the Model 1 intergovernmental agreement (Model 1 IGA), signed between France and the United States, for purposes of implementing the FATCA regime. The guidance, a set of four… – Continue reading
In an affidavit that was filed with the Federal Court of Appeal on September 25, 2015 in support of the government’s response to block a motion for injunctive relief that had been brought by the plaintiffs, Sue Murray, Director of the Canada Revenue Agency’s Competent Authority Services Division, International and… – Continue reading
PRESS RELEASE – The Caribbean Association of Banks Inc. (CAB) is once more forced to express its deep concern over yet another “tax-haven” list which includes 15 Commonwealth Caribbean countries. The referred list appears within the District of Columbia’s 2015 Budget Support Act which expands the definition of “tax haven”… – Continue reading
In a move which is likely to be of interest to those organisations who put systems and procedures in place to comply, the US has recently announced (September 2015) that information on US persons does not now need to be exchanged for certain jurisdictions until September 2016. In Notice 2015-66… – Continue reading
On October 2, 2015, the Internal Revenue Service announced that it had achieved a key milestone in implementation of the Foreign Account Tax Compliance Act (FATCA), a critical anti-tax evasion law passed by Congress in 2010 but not fully implemented until July 2014. The milestone announced by the IRS was… – Continue reading
The United States has included India in a list of 34 countries with which the US administration would automatically share information under the Foreign Account Tax Compliance Act (FATCA) regulations. The US Treasury Department has now added 16 new countries, including India, to an original list with which the US… – Continue reading
