Category: Legislation

American expats in Canada who sell their house might face IRS taxes

Americans residing in Canada may not realize the extent to which the U.S. government’s tax-filing rules for non-resident citizens hit home. There’s been a lot of attention in recent years on how U.S. citizens in Canada are being targeted by the Internal Revenue Service. Lost in all the commotion is… – Continue reading

American Business Problems with Hong Kong Bank Accounts? Singapore as an Answer

CDE Op-Ed CommentaryGiven the recent problems American trading companies are having in establishing bank accounts in Hong Kong, viable alternatives need to be found. These issues, which are directly related to the American IRS carrying out extensive investigations in Hong Kong concerning breaches of the new FATCA regulations, have made… – Continue reading

Switzerland, Italy Treaty Announcement ‘Imminent’

An announcement is expected imminently on the terms of the long-awaited revised tax treaty between Italy and Switzerland, reports say. According to a report from the ANSA news agency, the push to complete the treaty follows the parliamentary approval of Italy’s new voluntary disclosure program, which allows Italian residents to… – Continue reading

Business > America’s Shrinking Corporate Sector

SPECIAL REPORT:  IS AMERICA LOSING IT’S CORPORATE SECTOR? Corporate inversions have been the dominant tax issue over the last year and have forced a serious evaluation of the U.S. corporate tax system. While there is widespread agreement that the U.S. corporate tax code is out of step with our global… – Continue reading

What’s in store for the business world in 2015?

Business editor Duncan Foulkes quizzes three prominent Isle of Man businessmen on their thoughts ——————– Chris Eaton, Chief Executive Officer, The ILS Group There is no one major issue or initiative that faces the CSP and TSP sectors in 2015. Rather, they face more of a continued barrage of supra… – Continue reading

A two-minute nutshell on the UK’s proposed “Google Tax” – the “diverted profits tax” or “DPT”

The UK is proposing to introduce a unilateral, non-OECD co-ordinated anti-BEPS provision, referred to in the media as the “Google Tax”, with effect from 1 April 2015. The draft provision is very complex, and it will be time consuming to assess its potential impact on many common cross-border business structures…. – Continue reading

Should You Participate in the IRS Offshore Voluntary Disclosure Program?

2014 marked a significant increase in the enforcement efforts by the IRS and Department of Justice against non-compliant U.S. taxpayers who failed to report their off-shore bank accounts and earnings.  Grand Jury proceedings have been in full force and various criminal proceedings have been instituted.  IRS investigations continue to increase… – Continue reading

A Guide to India’s Transfer Pricing Law and Practice – Part 1

India enacted transfer pricing rules in 2001, which require companies to conclude international transactions with associated enterprises at an arm’s length. The legislation is primarily targeted at large business groups who engage in base erosion and profit shifting to avoid paying corporate income tax in India. This article is the… – Continue reading

Public consultation rejects beneficial ownership registry

The Cayman Islands government announced it will not implement a central register of beneficial ownership information, but will continue its current method of providing this type of information to law enforcement, tax and regulatory authorities. At the same time, government proposes to enact new legislation that will improve access to… – Continue reading

TAX: India considers removing Cyprus from blacklist

India is considering removing Cyprus from the blacklist of countries that do not share details about tax evaders after examining information given the island nation, reports from New Delhi have suggested. India had blacklisted Cyprus in 2013 for not sharing information about tax evaders. “They (Cyprus) have given some information…. – Continue reading

Launch of electronic certificates in BVI

On 8th December 2014, the British Virgin Islands Financial Services Commission (FSC) launched the electronic delivery of certificates of good standing for the benefit of users. The digital certificates will have the same security features as the original hard copy and issuers can authenticate these directly via the authentication service… – Continue reading

German Estate Tax, Credit Raters, HFT Study: Compliance

The German government must revise rules that allow families to transfer companies from one generation to the next without paying estate tax after the country’s top court ruled the current exemption is unconstitutional. The inheritance law gives an unfair advantage to family-owned businesses over individuals passing on non-company assets, the… – Continue reading

Shell Companies Face Disclosure in EU Anti-Tax-Dodge Deal

Companies will be forced to disclose their ultimate owners on national registers in European Union nations as the bloc seeks to clamp down on tax dodging, money laundering and terrorism financing. European Parliament legislators and representatives of 28 EU national governments struck a deal late yesterday to upgrade the bloc’s… – Continue reading

Bermuda snubs Cameron’s plan for company registry

Bermuda’s Minister of Finance, Bob Richards, has snubbed the UK Prime Minister David Cameron’s plan to create public registers of beneficial owners of companies incorporated in Bermuda. His reasoning behind this update was that this move would be damaging to the economy as Bermuda would lose it’s competitive advantage. He… – Continue reading

ACCA raises concerns with Diverted Profits Tax

The government’s plans to implement a Diverted Profits Tax (DPT) have been questioned by the Association of Chartered Certified Accountants (ACCA). Chas Roy-Chowdhury, head of taxation at the body, said nobody wants profits that should be subject to UK tax “escape the net”. As a result, he believes it is… – Continue reading

Gov’t drops plans to make offshore tax evasion a criminal offence

HM Revenue & Customs’ (HMRC) plan to make undeclared taxable offshore income a criminal offence has suffered a blow as it has been omitted from draft legislation. The draft Financial Bill, published earlier this week, extended the scope of civil penalties for tax evasion but there was no reference to… – 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

Parent-subsidiary directive: Council agrees to add anti-abuse clause against corporate tax avoidance

Padoan : “it will enable member states to better fight aggressive tax planning by groups of companies” The Council approved an amendment to an EU directive with the aim of preventing tax avoidance and aggressive tax planning by corporate groups. To this end, it agreed that it would introduce a… – Continue reading

North America leads global increase in MAP uptake

The US and Canada are at the forefront of a global increase in new mutual agreement procedures (MAPs) being initiated, OECD figures show. There were 1,910 new MAPs in 2013, a 14% increase from 2012, when there were 1,678 new MAPs. North America accounted for most of this growth, with… – Continue reading

Putin: Russian Business Should Be Freed From Obsessive Contro

During his address to the General Assembly on Wednesday Russian President Vladimir Putin stated that Russian business should be freed from obsessive control. MOSCOW, December 4 (Sputnik) — Russian President Vladimir Putin stated Thursday that it is necessary to lift restrictions for Russian business, freeing it from obsessive control. “As… – 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

British Virgin Islands: Record Keeping Obligations For BVI Companies, Partnerships, Trusts And Other Organisations

BVI Business Companies A1. What is the law on keeping and retaining records? Section 98 of the BVI Business Companies Act 2004 (BCA) has always provided that a BVI business company must keep records that: are sufficient to show and explain the company’s transactions; and will, at any time, enable… – Continue reading

Transfer Pricing: A Developing Area in Slovak Tax Law

Transfer pricing can be identified as an area of tax law that continues to attract the attention of both tax authorities and businesses worldwide. The growing importance of transfer pricing can be observed in the Slovak Republic as well, as it has become one of the dominant tax issues addressed… – Continue reading

Ex-Billionaire Wyly Bankruptcy Pits Church Against State

Former billionaire Samuel Wyly’s Dallas church is taking on the might of the U.S. government for a scrap of the businessman’s remaining fortune. Wyly, who filed for bankruptcy after losing a fraud lawsuit by the Securities and Exchange Commission, owes $20,000 to the Third Church of Christ, Scientist, under a… – Continue reading

Westpac closes door on money transfer operators as terror laws bite

Westpac will shut down the accounts of money transfer operators on November 24, due to growing fears about breaching strict terrorism financing and anti-money laundering laws, leaving hundreds of legitimate remitters to developing countries in the lurch. Westpac is the last of the four major banks to withdraw from servicing… – Continue reading

MLPs Can Generate Tax Bills In Retirement Accounts

It’s a surprise to many people that MLPs generate taxable income in retirement plans requiring a tax filing and payment of taxes. Traders and investors are interested in using their IRA and other retirement plan accounts (collectively referred to as “retirement plans”) for making “alternative investments” in publicly traded master… – Continue reading

Firms issuing offshore bonds hit a company law hurdle

NEW DELHI, SEPTEMBER 11:   Indian companies looking to raise money abroad through offshore bond issuances to overseas investors are in a bind, thanks to the new company law requirement around private placement of securities. They are now looking up to the Corporate Affairs Ministry (MCA) to provide clarity on whether… – Continue reading

Pfizer refuses to rule out tax inversion deals

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. Emailftsales.support@ft.com to buy additional rights. http://www.ft.com/cms/s/0/b494286e-171e-11e4-b0d7-00144feabdc0.html#ixzz393LkTft5 Pfizer refuses to rule out tax inversion deals By Andrew Ward, Pharmaceuticals CorrespondentAuthor alerts… – Continue reading

Offshore participants in government procurements ought to reveal their owners

YEREVAN, July 17. /ARKA/. Russia’s government has approved the package of legislative changes which make offshore companies’ access to the state’s money more complicated. They no longer will be provided by guarantees and they will be obliged to reveal beneficial owners in government procurement auctions. The demands turned out to… – Continue reading

Ireland: FATCA Update

On Friday, 27 June 2014, the Irish Revenue Commissioners (in conjunction with the Department of Finance) finalised the relevant Regulations with respect to FATCA. These Regulations will come into operation on 1 July 2014. As readers will be aware, the Irish and US Governments signed an intergovernmental agreement (“Irish IGA”)… – Continue reading

Azerbaijani banks permitted to make reports to other states about their customers directly or through mediators

Baku, Fineko/abc.az. Azerbaijan de facto joined the American tax reporting system FATCA (Foreign Account Tax Compliance Act): on July 8 President Ilham Aliyev sanctioned the Azerbaijani banks to report to other states about their customers directly or through mediators. The President of Azerbaijan approved the relevant amendments to the law… – Continue reading

Seychelles: Seychelles Company Incorporation

The Seychelles offer a wide variety of financial services, including offshore banking, investments and insurance. The inexpensive International Business Company (IBC) is the most popular corporate entity and can be used for many purposes with few limitations. The International Business Company IBC is the most widely used vehicle for offshore… – Continue reading

Dropped plans on tax avoidance could have affected legitimate charities, says Treasury minister Nicky Morgan

HMRC and Morgan both say the proposals, announced last year in the Autumn Statement, will not be included in the Finance Bill 2014 The government has abandoned plans to introduce legislation that would make it tougher to set up a charity for tax-avoidance purposes because it would have had a… – Continue reading

Obama signs bill with hidden provisions affecting non-US financial institutions

President Obama yesterday signed into law a bill which contains little-publicised elements that are expected to impact non-US financial institutions, funds and collective investment structures. The bill’s passage on 8 March 2010 represents a success for certain US lawmakers who have been seeking to crack down on Americans who have… – Continue reading

Russia Approves Direct Information Exchange on US Taxpayers

MOSCOW, June 25 (RIA Novosti) – Russia’s upper house of parliament, the Federation Council, on Wednesday authorized the direct exchange of information between Russian banks and US tax authorities on US taxpayers. The US Foreign Account Tax Compliance Act (FATCA) requires foreign banks to supply the Internal Revenue Service (IRS)… – Continue reading

Canadian industry claims win in long fight over U.S. crackdown on tax evasion

Canada’s investment and banking industries hailed a key victory Tuesday in five-year fight to dull the impact of onerous new U.S. tax rules expected to affect about a million Canadian residents and dual citizens. A newly ratified inter-governmental agreement with the United States excludes registered accounts for education, retirement, and… – Continue reading