International investors are finding the compliance around qualified foreign institutional investor (QFII) licences burdensome as they prepare to file their tax returns before the July deadline. The QFII program, and its renminbi equivalent (RQFII), allows institutional investors – like non-resident Chinese fund managers – to invest in Chinese A-shares. The… – Continue reading
Although you may be working in China, does the ATO still consider you an Australian resident? It’s just one of the things you need to get absolutely right. The tax requirements for Aussies working overseas vary from region to region. Aussies working in Hong Kong will find last month’s tax… – Continue reading
The April 21, 2015 Federal budget released by the Conservative Government includes updates on Canada’s involvement in the BEPS project and how Canada intends to fulfill its obligations to implement an automatic exchange of tax information with the G-20. Notably (with the exception of the common reporting standard discussed below),… – Continue reading
The Shareholders Association is making “strenuous representations” to the Inland Revenue Department over what it says is an unfair tax facing possibly thousands of New Zealand investors as a result of a proposed demerger of Anglo-Australian mining giant BHP Billiton. In an effort to simplify its business, Melbourne-based BHP is… – Continue reading
(Reuters) – Some of Britain’s biggest political donors, including a dozen senior lawmakers, have benefited from a little-noticed loophole that lets them avoid tax on millions of pounds in donations to political parties, a Reuters analysis has found. Reuters is the first to measure the loophole, which offers political parties… – Continue reading
NEW DELHI: India may set up a panel to resolve legacy tax cases that have revived allegations of ‘tax terrorism’, making it difficult for the government to meet its pledge to boost investor sentiment. “I am considering a high-level committee to explore what can be done to resolve the past,… – Continue reading
They are even engaging in strong-arm tactics with US account holders Swiss banks, for decades the bastions of secrecy, are preaching the virtue of transparency to their US clients as they try to head off billions of dollars in potential fines for helping Americans evade taxes. Faced with the threat… – Continue reading
Section 55 of the Income Tax Act (Canada) (the “Tax Act”) contains an anti-avoidance rule that prevents a corporation from converting what would otherwise be a taxable capital gain into a tax-free intercorporate dividend. Section 55 deems a dividend not to be a dividend, but rather a capital gain, where… – Continue reading
The former head of parliament’s public accounts committee – and a fierce critic of tax avoidance and “secretive” offshore funds – has received more than £1.5m in shares from the tax haven of Liechtenstein, according to a report. The money came through a controversial scheme that lets wealthy Britons move… – Continue reading
LONDON (Reuters) – HSBC shares have rallied after the bank said it was reviewing whether to move its headquarters out of Britain and potentially back to its former home in Hong Kong. The following are some of the regulatory issues raised if Europe’s biggest bank were to relocate to Hong… – Continue reading
One million American citizens in Canada face double tax troubles. Max Reed explores these challenges in a spring series. The United States has two tools with which to collect information on accounts held by its citizens, FATCA and FBAR. Lots of attention has been paid to FATCA, less so to… – Continue reading
NEW YORK — Introduced in the 1920s to ease the tax burden of farmers who wanted to swap property, it soon became a tool for real estate investors flipping, say, office buildings for shopping malls. Now, this little-known provision in the tax code, known as a like-kind exchange, has become… – Continue reading
When should the beneficiaries of an IRS-targeted tax shelter be allowed to sue their enablers? That’s the question the federal appellate court in Atlanta posed to the Florida Supreme Court April 17 in an ongoing bankruptcy-related case. The answer, which turns on statutes of limitations, probably will boil down to… – Continue reading
Earlier, SEBI also beefed up norms for defaulters trying to raise fresh money. The Reserve Bank of India (RBI) has clarified that only nominee and independent directors who are not whole-time board members of a firm deemed as a ‘wilful defaulter’ would be excluded from being labelled as a party… – Continue reading
On Saturday 25 April, at the second session of the informal meeting of the Economic and Financial Affairs Council (ECOFIN), one of most important issues on the agenda was the further development of the Capital Markets Union concept, which was broadly supported by the ministers and Governors of central banks…. – Continue reading
With the Transcontinental Trusts Bermuda Forum taking place next week, it is timely to reflect on some of the attractive features and structuring alternatives that Bermuda’s trusts and related law provides and to consider some recent exciting developments. Bermuda provides a flexible, cost effective regime for the formation and administration… – Continue reading
International finance centres (IFCs) are frequently used to structure Russian inward and outward investment and it has been observed that in 2012, 11 of the 40 main recipients of Russian FDI were IFCs1. The BVI is at the forefront of offshore investment into Russia, and the share of outward FDI… – Continue reading
What exactly is the point of a Coalition government if it offers the same sort of tax increases as voters expect from Labor and the Greens? It’s disturbing how quickly the Abbott government has turned its attention to boosting government revenue rather than reducing government spending. It’s only been in… – Continue reading
Neil Saunders, whose wife is the Director of Public Prosecutions, is a member of a controversial scheme being investigated by the taxman, The Telegraph can disclose The Director of Public Prosecutions’ husband is a member of a controversial “tax loophole” scheme that has been investigated by the taxman, it can… – Continue reading
The trio have NOT appealed against a tax tribunal ruling from last May that the Icebreaker scheme they poured millions into was designed to exploit legal loopholes TV sports presenter Gabby Logan has kept her promise to pay back all the money she owed from a controversial “tax shelter” scheme…. – Continue reading
The federal government has published the results of the consultation on the Financial Services Act and the Financial Institutions Act (for further details please see “Federal Financial Services Act and Federal Financial Institutions Act”). The Financial Services Act governs the prerequisites for providing financial services and offering financial instruments and… – Continue reading
FPIs are battling it out with the income-tax department, which has issued notices demanding that they pay MAT to the tune of Rs40,000 crore New Delhi/Mumbai: Despite the government affirming that foreign portfolio investors (FPIs) can use tax treaties to fight tax demands on past capital gains, a majority of… – Continue reading
Company accounts provide insight into Parlesse Investments A Larry Goodman company based in Luxembourg made a profit of €52.6 million in 2013 and paid just 0.4 per cent tax, according to accounts in the tiny EU member state. The company, Parlesse Investments Sarl, began operations in 2010 and had accumulated… – Continue reading
On March 30, 2015, the U.S. Department of Justice announced that it had entered into a nonprosecution agreement with BSI SA, the first Swiss bank to reach resolution with the U.S. government as to its potential criminal exposure for assisting its U.S. clients in engaging in tax evasion.[1] As part… – Continue reading
If you have been running your small business happily and without incident as a sole proprietorship, general partnership, or limited liability company (LLC), why would you want to incorporate? The answer could be that you do not want to incorporate, but there are valid reasons for you at least to… – Continue reading
Britons overseas are now subject to CGT when selling UK properties, but this straightforward advice could help minimise the impact Expats who have kept a house or flat in Britain need to act now to avoid being stung by a hefty capital gains tax (CGT) bill in the future. Since… – Continue reading
In what is becoming an increasingly used attack vehicle, the Department of Justice (DoJ) is using the “required records doctrine” to compel taxpayer’s to produce what may be incriminating evidence of ownership or control of foreign financial accounts. The DoJ process involves the issuance of a Grand Jury subpoena for… – Continue reading
A company announcement on the Malta Stock Exchange website announced on Tuesday that Arun Shankardass and Oumeshing Sookdawoor have tendered their resignation from the office of director of the company with effect from 17 April. Mr Shankardass will also be stepping down as chairman of the Audit Committee of the… – Continue reading
Moves to create a supposed level playing field for succession issues in Europe, along with more established themes around automatic exchange of information and US extra-territorial tax powers make their appearance in a major Geneva-based conference later in April. Figures from the world of wealth management will gather at the… – Continue reading
The “Hound of Hounslow” day trader accused of helping trigger a Wall Street “flash crash” made more than £30 million profit dealing from his parents’ home in four years, the Evening Standard can reveal. FBI agents are investigating claims that Navinder Sarao, 36, transferred as much as £26 million to… – Continue reading
Georgia and Belarus are stepping up their bilateral cooperation in taxation, customs affairs, and a number of other avenues. Representatives of both countries today signed a cooperation agreement on avoidance of double taxation, prevention of evasion of income and capital taxes, which would act as a basis for further talks…. – Continue reading
Switzerland is to amend federal tax legislation to prevent the double taxation of certain permanent establishments (PEs) located in the country. The planned reform is the result of a consultation on the application of the flat-rate tax credit. It will affect PEs in Switzerland that have their registered office in… – Continue reading
The true cost of the debt that China’s real estate developers peddled to eager international investors during a five-year property boom is now becoming clear. Having found themselves shut out of local bond and loan markets seven years ago, a band of developers began looking elsewhere for funds. First an… – Continue reading
Investment vehicles set up by Paulson & Co. and Highbridge Capital Management in tax-friendly Bermuda may be under threat from the U.S. Internal Revenue Service. The IRS, in proposed rules published Thursday, said that the favorable treatment enjoyed by insurers under the tax code shouldn’t extend to companies that borrow… – Continue reading
The Federal Court has found that copyright does not exist in a digital data signal (Seven Network Limited v Commissioner of Taxation [2014] FCA 1411). Clayton Utz acted for Seven in the proceedings. The rights to broadcast the Olympic Games Seven Network Limited held the exclusive rights to broadcast certain… – Continue reading
Mumbai: The equity markets snapped their five-day losing streak following a late hour surge in buying of blue-chip stocks on reports that the minimum alternate tax (MAT) would not be levied on overseas investors coming through those jurisdictions with which India has a double taxation avoidance agreement (DTAA). After trading… – Continue reading
MUMBAI: In a bid to attract investments into Luxembourg, once seen as a “tax haven”, its ambassador today assured industrialists and investors that his government “does not encourage money laundering.” “We do not encourage dirty money. It is a misconception that the Luxembourg is a tax haven,” the alpine nation’s… – Continue reading
Arris Group Inc. agreed to buy British set-top box maker Pace Plc for about $2.1 billion and incorporate in the U.K. in a deal designed to save on taxes. Shares in Pace, one of Britain’s few global technology companies, rose as much as 44 percent. The acquisition will combine two… – Continue reading
While the government has stood its ground on the applicability of minimum alternate tax (MAT), saying that foreign institutional investors (FPIs) ought to consider judicial appeal for the retrospective tax demand, increasing number of foreign brokerages are red flagging the issue as a risk for the Indian equity market. Even… – Continue reading
FATCA 1. New FATCA IGA guidance notes On 3 February 2015, the Jersey Chief Minister’s Department published the latest version of the Guidance Notes on the Taxation (International Tax Compliance) (Jersey) Regulations 2014 in relation to the implementation of obligations arising under the intergovernmental agreements (IGAs) with the US and… – Continue reading
1 General news 1.1 HMRC organisation chart HMRC has published its latest organisation chart showing the names of senior management. One point to note is the number of senior people now in roles such as change management as opposed to being in pure technical roles. This clearly demonstrates the direction… – Continue reading
MPs say transfer pricing, though legal, presents challenges when determining if firms have evaded taxation and they want the practice criminalised. The portfolio committee on trade and industry has heard calls for the criminalisation of transfer pricing – a practice that, when abused, results in large corporations shifting profits offshore… – Continue reading
The Minister of Finance (Canada), the Honourable Joe Oliver, presented the Government of Canada’s 2015 Federal Budget (“Budget 2015”) on April 21, 2015 (“Budget Day”). Budget 2015 contains several significant proposals to amend the Income Tax Act (Canada) (the “ITA”) while also providing updates on previously announced tax measures and… – Continue reading
In This Issue: • It’s Stifling in Here! SEC Rules That Companies Can’t Put Restrictive Language in Confidentiality Agreements That Could Potentially Stifle Whistleblowers • An Opinion on Opinions: U.S. Supreme Court Decision in Omnicare • Is OFAC the New Black? Schlumberger and PayPal—The Rise in the Enforcement of Sanctions… – Continue reading
Minister of Finance Joe Oliver today tabled the 2015 Federal Budget (the “Budget”), his first budget as Minister of Finance, entitled “Strong Leadership: A Balanced-Budget, Low-Tax Plan for Jobs, Growth and Security”. We are pleased to provide our summary of tax measures contained in the Budget. The Budget proposed no… – Continue reading
As has been widely predicted, today’s federal budget (Budget 2015) delivered a handful of tax “goodies” in the lead-up to the coming election. It also includes a number of important proposed changes to the corporate tax rules. They are noteworthy, although not as extensive as the corporate tax changes proposed… – Continue reading
The Cyprus Investment Promotion Agency (CIPA) is urging parliament to expedite a batch of bills aimed at facilitating much-needed foreign investment in Cyprus. Chief among the proposals are the establishment of foreign leasing companies and cell companies, opening up the professional provident fund business to foreign concerns, and updating company… – Continue reading
[HONG KONG] China is set to enhance the convertibility of its yuan currency by allowing capital to be taken out on a daily basis from the largest investment scheme open to foreign investors, people with knowledge of the plans told Reuters. This could strengthen the global standing of the yuan… – Continue reading
Finance Minister Joe Oliver faced formidable challenges, both economic and political, in delivering his first Budget. In a time of depressed oil prices, and mere months ahead of the next federal election, it appears he felt it was imperative to follow through with prior commitments to balance the budget, provide… – Continue reading
Commissioner Chris Jordan delivers rebuke to multinational tech giants contesting evidence they gave to a Senate inquiry into corporate tax avoidance The tax commissioner, Chris Jordan, has delivered a public rebuke to multinational tech giants Apple, Google and Microsoft, vigorously contesting evidence they gave to a recent Senate inquiry hearing… – Continue reading
