Investors in a financing scheme aimed at helping the UK film industry are being asked to repay “multiple millions of pounds” following a court ruling. HMRC is pursuing investors in the Eclipse scheme, including celebrities, financiers and sports stars, for up to 20 times their original investment. Courts ruled that… – Continue reading
Following British Prime Minister Theresa May’s visit to India last week, Patricia Hewitt, chair of the UK-India Business Council, said that Britain is looking to re-balance its commercial links with countries like India post-Brexit. She suggested that the two governments should look at a bilateral tax treaty to boost trade…. – Continue reading
‘Multinational corporations complain all the time of excessive demand about excessive taxation, but it is also true that MNCs across the world tend to find tax avoidance and sometimes tax evasion as an appropriate technique’ Blaming multinational corporations squarely for tax controversies, Reserve Bank Governor Raghuram Rajan has said their… – Continue reading
Here’s a transaction that did the rounds some years ago. If I wanted some foreign exchange in the future I could enter into a contract with a bank by which it would sell me some. Assume that, in order to get a bank to promise to give me $2bn in… – Continue reading
A Sacramento federal judge on Thursday sentenced a former West Sacramento attorney to two years in prison for a “sophisticated” tax-evasion scheme. According to prosecutors, James Stewart Richards, 69, owed federal income taxes between 1994 and 2003 totaling $170,000. Not only did he not pay taxes, but he went to… – Continue reading
Wherever you and your clients stand on the ethics of tax avoidance – and on offers of 70% commission – moral considerations are now being superseded by more practical concerns of the personal damage attempting to avoid tax can cause, writes Laura Miller… There are many reasons to avoid tax… – Continue reading
Wherever you and your clients stand on the ethics of tax avoidance – and on offers of 70% commission – moral considerations are now being superseded by more practical concerns of the personal damage attempting to avoid tax can cause, writes Laura Miller… There are many reasons to avoid tax… – Continue reading
A web of offshore companies was used to shield controversial builder Tom McFeely’s ownership of an apartment building close to London’s Olympic stadium, an Insolvency Service official has claimed. The allegation was one of several levelled against the Priory Hall developer as part of proceedings issued by official assignee Christopher… – Continue reading
A lawyer for the Internal Revenue Service on Monday disclosed a series of emails and legal memos from 2004 apparently showing that Dallas entrepreneur Sam Wyly was interested in knowing the legal and financial ramifications if he renounced his U.S. citizenship. The IRS also introduced testimony from previous court proceedings… – Continue reading
(Reuters) – Texas tycoon Sam Wyly is set to face off against the Internal Revenue Service at trial on Wednesday over more than $2 billion the agency says he owes for using offshore trusts to engage in one of the largest tax frauds in U.S. history. The trial in federal… – Continue reading
Indian equity markets trimmed their losses and continue to trade weak in late morning session on account of selling in frontline blue chip counters. Sentiments remained down-beat with the repot that the Finance Ministry has cut its ambitious disinvestment revenue target by 57% to Rs 30,000 crore for the current… – Continue reading
Most people with undisclosed Swiss bank accounts have, by definition, something to hide. Secrets, however, sometimes don’t remain secret, especially when they involve someone else’s money. While disclosing the names and financial details of Swiss bank account holders has recently come into vogue, a whistleblower may have just as murky… – Continue reading
European evaluators urged Vatican prosecutors on Tuesday to move ahead and bring charges in some of the 25 money-laundering investigations they have opened over the past few years as part of beefed-up measures to prevent illicit activity at the Vatican’s scandal-marred bank. The Council of Europe’s Moneyval committee issued the… – Continue reading
There are two things that offshore fund managers and their advisors should remember about income that is effectively connected with a United States trade or business (ECI): It is easy to have ECI; and, It is bad to have ECI. By way of background – U.S. non-residents that are not… – Continue reading
What is abundantly clear to anyone who has a passing interest in the manner in which tax disputes are dealt with in the UK is that the legislation in Finance Act 2014, concerning accelerated and partner payment notices (the APN legislation), marks a significant shift in the rules of engagement… – Continue reading
In our previous columns, we tackled some of the recommendations from the Organisation for Economic Co-operation and Development (OECD) on how to address the issue of Base Erosion and Profit Shifting (BEPS) in international tax systems. We will now focus on the topic of transfer pricing (TP) of intangibles as… – Continue reading
Within days, the IRS will be able to revoke your passport for unpaid taxes. This bad idea has been kicking around for several years. This time, it is buried within 1300 pages of highway legislation. The government will surely see it as a nice complement to FATCA, the Foreign Account… – Continue reading
The World Bank has placed India twelve notches higher than last year in its Ease of Doing Business rankings for 2016. This comes close on the heels of the country’s sixteen place leap on the World Economic Forum’s Global Competitiveness index. These rankings underline the impact of the recent spate… – Continue reading
“What’s the best way to rob a bank? Start one.” Many people have heard that old saw. But it’s no longer accurate. The best way to rob a bank is to control a government … any old government will do these days. It wasn’t always like that. You see, for… – Continue reading
The widow of Texas billionaire Charles Wyly told a judge the IRS wrongly accused her of a “sinister” tax-avoidance plot to bolster the agency’s $1.2 billion claim in her bankruptcy case. Caroline “Dee” Wyly, who is in her early 80s, asked the U.S. Bankruptcy Court in Dallas to toss out… – Continue reading
Law firm RPC has called on the UK tax authority, HM Revenue and Customs, to confirm that it will not force individuals into bankruptcy through the use of Accelerated Payment Notices. HMRC began sending APNs to UK users of certain tax avoidance schemes in August 2014. The notices give recipients… – Continue reading
The company at the centre of the revelations denied any wrongdoing Some of the best-known names in British football face losing millions of pounds after being allegedly advised to invest in “risky” projects that have subsequently failed or were hit with tax bills. Rio Ferdinand and Andy Cole, both former… – Continue reading
Paul Singer has a good track record as a money manager. In 1995, he bought $20 million worth of Peruvian debt at a discounted price of $11.4 million, then forced Peru’s government, through lawsuits, to eventually pay nearly five times his initial investment — some $58 million. In 2002 and… – Continue reading
Over the past decade, many Indian business families have organised themselves under trusts — a bankruptcy remote structure — to preserve wealth, protect the rights of various members, and plan for the next generation. Now, this arrangement is coming under strain for families with members staying in the US, the… – Continue reading
MUMBAI: Over the past decade, many Indian business families have organised themselves under trusts — a bankruptcy remote structure — to preserve wealth, protect the rights of various members, and plan for the next generation. Now, this arrangement is coming under strain for families with members staying in the US…. – Continue reading
A company controlled by Mayor of Belgrade Sinisa Mali and his family obtained more than 10 hectares of agricultural land worth anywhere from €123,000 to € 250,000 (US$140,000 to US$290,000) for free from a privatized state company. Problem is, the land wasn’t the company’s to give, but was still owned… – Continue reading
On June 16 of this year, the California Department of Business Oversight issued a desist and refrain order to Encinitas’s Lawrence (Larry) Freeman and two of his many now-defunct companies, Yeshilkoy Insurance Services and Structured Marketing. In peddling financial products, Freeman made “an untrue statement of material fact to investors,”… – Continue reading
The Government has expressed a commitment to improving levels of UK corporate transparency but a recent Private Eye article [1], documenting the extent of ownership of British Land through offshore entities, shows just how far there is to go. By far the most common reason for owning UK property through… – Continue reading
Using companies incorporated in international financial centres (IFCs) in structuring financial transactions, capital raisings and corporate structures has long been popular in Asia, particularly Hong Kong (itself an IFC). Following the energetic expansion of the PRC economy and assisted in part by the relaxation of PRC regulations in relation to… – Continue reading
A small office shared with three other companies deep in the bowels of the Outsource IT Tower on Auckland’s Khyber Pass Road opposite a reservoir isn’t necessarily where you’d expect to find the global headquarters of a financial service provider that claims to be following in the footsteps of three… – Continue reading
LAND including Riverside Retail Park, the Cockhedge Centre and the former site of Mr. Smith’s is owned by companies based in offshore tax havens it has been revealed. Companies are often based offshore to gain from three tax loopholes, including no capital gains tax, no inheritance tax and no stamp… – Continue reading
Japan has just embarked on the 2015 Tax Reform to be more growth-oriented with the aim of a reduction in the effective corporate tax rates to allow corporations to pay higher wages to existing employees as well as increase overall employment thereby increasing economic consumption and investment. On 31 March… – Continue reading
Over the past year, a number of legislative measures have been adopted to ensure that the Cayman Islands remains the leading jurisdiction of choice for structured finance and capital markets transactions and for secured lending transactions generally. This article focuses on two recent key legislative developments. The first is the… – Continue reading
Over the past year, a number of legislative measures have been adopted to ensure that the Cayman Islands remains the leading jurisdiction of choice for structured finance and capital markets transactions and for secured lending transactions generally. This article focuses on two recent key legislative developments. The first is the… – Continue reading
Bahamas Supreme Court rejects Baha Mar’s Delaware chapter 11 application In a ruling by Justice Ian Winder on Wednesday of this week, The Bahamas Supreme Court Denied Baha Mar’s Chapter 11 Bankruptcy Recognition Petition. This paves the way for the Supreme Court to appoint a provisional liquidator on the 31st… – Continue reading
A third of local authorities used Bankruptcy Orders last year to recover council tax arrears, new research has revealed. Figures obtained by Moore Stephens show that 32% of local authorities took bankruptcy actions against council tax defaulters, making more than 1,000 tax defaulters bankrupt in 2013/14. Nearly half (48%) of… – Continue reading
The children of craft store kingpins Charles and Sam Wyly say they shouldn’t suffer for their fathers’ transgressions. The U.S. Securities & Exchange Commission says they shouldn’t be allowed to spend the proceeds of the brothers’ fraud. The Wyly brothers used gains from secret, illegal, offshore transactions “as their own… – Continue reading
Greek Finance Minister Yanis Varoufakis has taken a swipe at Switzerland for providing only limited information about wealthy tax evaders from cash-strapped Greece who are believed to have stashed billions of euros in Swiss banks. In an interview on Wednesday with Rundschau, a current affairs programme from state broadcaster SRF,… – Continue reading
DRESDEN — Finance chiefs from the Group of Seven (G-7) economic powers met on Thursday to discuss how to revive a faltering global recovery, with the US leaning on Europe to reach a deal to avert a Greek bankruptcy. The threat of a Greek default, rising oil prices and bond… – Continue reading
K+, a television joint venture between Vietnam and France, well-known as the exclusive broadcaster of the British Premier League in Vietnam, has reported an accumulative loss of VND1.9 trillion after five years of operation. Since 2009, when it made its debut, K+, the television corporation to which the French Canal+… – Continue reading
Bankrupt ex-billionaire Samuel Wyly won a judge’s approval to sell his family’s Colorado ranch, the site of six custom-built homes. The bankruptcy judge in Dallas Wednesday also said Wyly could provide a loan to pay for the ranch’s upkeep before it’s sold. The property will be listed for $50 million,… – 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
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
The U.S. Securities and Exchange Commission and the IRS are opposing bankrupt billionaire Samuel Wyly’s motion to sell his Woody Creek ranch because they believe he would hide sales proceeds in offshore accounts, according to court filings made earlier this month. Wyly, who filed for Chapter 11 bankruptcy Oct. 19… – 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
1. NON-TAX ISSUES 1.1 Domestic law 1.1.1 Briefly describe your legal system and its origins The legal system of the Republic of Ireland is a common law system. In order to ensure consistency, a legal principle developed whereby courts were generally required to follow earlier relevant decisions. This doctrine of… – Continue reading
Bankrupt ex-billionaire Samuel Wyly told a judge it’s too soon for regulators to fret over what he’ll do with as much as $50 million from the planned sale of his family’s Colorado ranch, the site of six custom-built mansions. The U.S. Securities and Exchange Commission and the Internal Revenue Service,… – Continue reading
The Internal Revenue Service (IRS) is seeking to recoup $2.03 billion from Texas businessman Samuel Wyly and $1.19 billion from his brother’s estate. The massive bill owed by Sam Wyly and the estate of Charles Wyly is believed to be the biggest in history. Brothers used trusts to avoid taxes… – Continue reading
Bankrupt ex-billionaire Samuel Wyly was accused by regulators of hiding the ownership of a luxury Colorado ranch in a possible bid to avoid paying creditors as much as $50 million in future sale proceeds. Wyly’s proposed plan to sell the 244-acre property — the site of several mansions used by… – Continue reading
DALLAS (AP) — The IRS wants $3.2 billion to cover back taxes that it says are owed by a prominent Texas businessman and his late brother who the IRS says hid income by setting up overseas trust funds. The Internal Revenue Service detailed its claim in documents filed Wednesday in… – Continue reading
