Category: Residency

New FATCA requirements apply to U.S. and non-U.S. insurers and insurance brokers on January 1, 2015

Summary New FATCA requirements that apply to U.S. and non-U.S. insurance brokers and insurance companies will take effect on January 1, 2015. Those requirements impose new information gathering and reporting rules when U.S. insurance and reinsurance premiums are sent outside the U.S. Background The Foreign Account Tax Compliance Act (FATCA)1… – Continue reading

South Africa urged to finalise renegotation of Mauritius tax treaty

CAPE TOWN — South Africa needs to finalise the renegotiation of its tax treaty with Mauritius as soon as possible to prevent the loss of large sums of money through “treaty shopping” the Davis tax committee has urged. The committee released its interim report on ways to prevent base erosion… – Continue reading

Ingersoll-Rand Cleared for U.S. Contracts Despite Inversion

In August, President Barack Obama pledged to use the powers of his office to discourage the corporate tax-avoidance technique known as inversion, in which U.S. companies claim foreign tax addresses. Four months earlier, according to a previously unreported legal document, his Department of Homeland Security did just the opposite. It… – Continue reading

The Year of Transparency’s Tipping Point

More countries are requiring an exchange of client information In 2014, we saw a marked increase in transparency regarding foreign assets. The United States took the lead, and other countries followed suit. It looks like we’ve reached the tipping point, that is, “the magic moment when an idea, trend, or… – Continue reading

New UK Capital Gains Tax

KOTA KINABALU: For Malaysian property investors, especially in the London property market where some Malaysian developers, welcomed by Mayor Boris Johnson are active in projects, the United Kingdom Government will introduce new Capital Gains Tax (CGT) on the sale of UK residential property with effect from April 6, 2015. Following… – Continue reading

Capital Gains Tax Changes for Expat Property Owners

Rules relating to the payment of CGT by non-resident UK property owners will change in April and expats will be affected. Significantly sneaky draft legislation was published last week that will affect the way capital gains tax (CGT) is charged on the sale of UK property assets owed by expats. … – Continue reading

Ranking Facebook, Boris Johnson, Google On Taxes (Diplomatically Please)

Ambassadors are supposed to be diplomatic and suave. Yet even those of the diplomatic corp may occasionally get tongue-tied or utter ill-timed statements. Take U.S. Ambassador to Britain Matthew Barzun. He recently sounded not all that diplomatic about duty, compliance with law, and yes, even taxes. Lee Rigby was a… – Continue reading

Luxembourg budget 2015 – main tax measures at a glance

Advance Agreements The so-called tax rulings and advance pricing agreements will be formalised by the introduction of appropriate provisions in the Luxembourg tax laws. By this means, Luxembourg will be able to offer as from 1 January 2015 a unified system providing taxpayers with legal certainty and a consistent and egalitarian… – Continue reading

ATO chief identified tax ‘abuse’ by multinationals before Joe Hockey backed away from reform pledge

The head of the Australian Tax Office, Chris Jordan, has described a tax lurk for multinational companies that is being retained by the Abbott government as having been “abused” by foreign corporations at a cost of “hundreds of millions of dollars” a year to the Commonwealth. As revealed by Fairfax… – Continue reading

Finance: Out of Control? Beneficial ownership registers in EU states won’t be made completely public

Last March MEPs voted overwhelmingly to introduce a new transparency disclosure rule that would compel all 28 European states to make publicly accessible the real owners of companies and trusts. The decision was hailed as a major breakthrough by anti-corruption campaigners fighting financial crime and tax abuse. Lawyers working for… – Continue reading

Cyprus: Signature Of Cyprus – USA Inter-Governmental Agreement Under The American Foreign Account Tax Compliance Act

On 2 December 2014 the Cyprus finance minister and the American ambassador to Cyprus formally signed the intergovernmental agreement (“IGA”) between Cyprus and the USA under the Foreign Account Tax Compliance Act (“FATCA”), an American tax measure enacted in 2010 with the purpose of implementing mechanisms designed  to prevent and… – Continue reading

United States: Foreign Entity Payees Of U.S. Source Income: Learn How To Fill Out IRS Form W-8BEN-E

In prior advisories, we have discussed the new withholding tax law commonly known as “FATCA” (standing for “Foreign Account Tax Compliance Act”). (See “FATCA’s July 1 Effective Date Has Arrived; Last-Minute Guidance Has Been Issued” and “Last Substantial Package of FATCA Regulations Released; Deadlines Approaching”.) To help implement FATCA, the… – Continue reading

Passport-buyers’ ‘genuine links’ to Malta? A couple of weekends a year

After multiple revisions of a controversial law, the government is adamant that its citizenship-by-investment programme only provides Maltese nationality to people who establish a genuine link to the country. But there may be hundreds of thousands of tourists in any given year who establish stronger links to Malta than many… – Continue reading

MotoGP » Emotional Marquez responds to Andorra critics

MotoGP champion Marc Marquez hit hard by criticism of a planned move to Andorra, will continue to pay tax in Spain. MotoGP champion Marc Marquez gave an emotional response to the criticism he has received within Spain over a reported move to Andorra. Speaking during Friday’s preview for the Superprestigio… – Continue reading

Burger King will avoid $117m in tax from Tim Hortons merger, activists say

Findings from Americans for Tax Fairness directly contradict Burger King’s earlier insistence that the merger would create ‘no tax benefit’ Burger King acquires Tim Hortons and calls Obama’s bluff on tax Burger King stands to avoid paying hundreds of millions of dollars in US taxes if it completes its pending… – Continue reading

Ferrari Said to Weigh Moving Fiscal Base Outside Italy

Ferrari SpA is considering moving its fiscal residence outside Italy to save on corporate taxes as the supercar maker prepares for its spinoff from Fiat Chrysler Automobiles NV (FCAU), people familiar with the matter said. The manufacturer, which uses the colors of the Italian flag in its logo, may follow… – Continue reading

MotoGP: Marc Marquez rumoured to have moved to Andorra for tax reasons

TWICE-WORLD champion in MotoGP Marc Márquez is reported to have moved to Andorra to reduce his taxes. The 21-year-old, who scooped up the top title in his rookie year, 2013, and repeated the performance the following season, is said to be earning around 10 million euros a year – but… – Continue reading

Ireland: Property Investment Structures In Ireland: Irish Investment Opportunities

In recent times there has been a welcome return to activity in the Irish real estate market. Overseas investors have been circling and private equity groups have started investing heavily in Irish real estate amid confidence that the Irish economy has stabilised and is returning to growth. In this briefing… – Continue reading

UK: Moving to the UK from France

Some statistics rank London as the fourth largest ‘French’ city by population, and the number of French individuals moving to the UK is growing. This is not surprising – the UK offers a highly favourable tax regime for ‘non-domiciled’ individuals moving to the UK, while entrepreneurs, professionals and high net… – Continue reading

American citizens like Boris must pay more tax, says US ambassador to UK (but Google and Amazon are doing nothing wrong)

Ambassador to London Matthew Barzun says US citizens must pay up Boris Johnson was born in New York so faces a tax bill in America London Mayor has branded the Transatlantic rules ‘outrageous’ Barzun defends US firms like Amazon and Google over tax dodging Insists they are just playing by… – Continue reading

US Anti-Inversion Bill ‘Could Save More Revenue’

The Joint Committee on Taxation has increased, from USD19.5bn to more than USD33.5bn, its estimate of tax revenue that could be saved over a ten-year period from legislation to restrict corporate inversions introduced by Democrat lawmakers in the United States House of Representatives in May this year. A recent letter… – Continue reading

A palace fit for the king of tennis: Roger Federer to move into £6.5million GLASS mansion in Swiss tax haven on banks of Lake Zurich – complete with separate apartment for his parents

Tennis legend Roger Federer is set to move into a 6.5million glass mansion in a Swiss tax-haven Wollerau Three-storey building comes with floor-to-ceiling windows, a swimming pool and view across Lake Zurich Wollerau is one of the lowest tax municipalities in Europe and has attracted other multi-millionaires Tennis ace Roger… – Continue reading

Property Council Pushes for Tax Reform

The Property Council of Australia has joined efforts by the broader business community to lobby the federal government to implement significant tax reforms next year. Members of the Business Coalition for Tax Reform (BCTR) will meet with the Australian Council of Social Service (ACOSS) on December 15 to commence discussions… – Continue reading

Two Years of Magnitsky Act: Facts and Details

The factbox devoted to two years of the so-called Magnitsky Act passed by US Senate. This act allows Washington to deny visas and freeze assets of Russian officials allegedly involved in the death of Russian lawyer Sergei Magnitsky. Five years ago, on November 16, 2009, Sergei Magnitsky, a tax and… – Continue reading

UK: Switzerland UK Autumn Statement 2014 Analysis

In yesterday’s Autumn Statement, the UK Chancellor announced several measures that will directly affect non-UK individuals who live or own property in or are considering moving to the UK. Although in many cases the measures will mean that such individuals are liable to pay more tax in the UK than… – Continue reading

Taxing system drives Germans into arms of advisers

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. Business has never been better at Knappworst and Partner, a tax advisory firm in Potsdam, a leafy city… – Continue reading

Mauritius Overtakes Singapore as India’s Top Source of FDI

DELHI – Mauritius has overtaken Singapore as the largest source of foreign direct investment (FDI) in India, it was announced earlier this week. During the April-September period, Mauritius emerged as the strongest contributor of investment with an inflow of $4.19 billion. During the same period, Singapore provided $2.41 billion in… – Continue reading

Dechert OnPoint: Georgian Law Developments – Talking Taxes

Dechert Georgia, through the contribution of partners Archil Giorgadze and Nicola Mariani joined by senior associates, Ruslan Akhalaia and Irakli Sokolovski, is partnering with Georgia Today on a regular section of the paper which will provide updated information regarding significant legal changes and developments in Georgia. In particular, we will… – Continue reading

UK: Capital Gains Tax On Non-UK Residents

Late yesterday afternoon the Government published its response to the consultation on extending Capital Gains Tax (CGT) to non-UK resident owners of UK residential property.  This is the latest step in a series of significant changes in the last couple of years to the tax treatment of UK residential property…. – Continue reading

Medtronic Takes On Debt For Covidien Inversion

The medical device manufacturer Medtronic has launched a USD17bn bond to finance part of its USD43bn corporate inversion acquisition of Ireland-based Covidien, in replacement of the cash held by its foreign subsidiaries that it was prevented from using following the United States Department of Treasury’s announcement of anti-inversion measures in… – Continue reading

UK: Deloitte Preview of Autumn Statement 2014

Bill Dodwell comments: “Chancellor George Osborne will deliver the final Autumn Statement of this parliament. We expect that most of the announcements will concentrate on the outcomes from proposals launched at earlier Budgets, together with some technical changes. There will also be the first consultation on how the UK should… – Continue reading

UK loses top spot in league table of company tax regimes

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. Email ftsales.support@ft.com to buy additional rights. The UK has lost its top slot in a league table of multinational companies’… – Continue reading

London Mayor Boris Johnson makes ‘brave’ stand against American taxes

The refusal by the Mayor of London to pay his American taxes has been hailed as “noble” and “brave” by the CEO of independent financial advisor, deVere Group. The comments from Nigel Green, founder and chief executive of deVere Group, which operates in 100 countries and has $10 billion under… – Continue reading