Category: Offshore Investments

Canada’s BMO to boost trade finance capabilities in Hong Kong

Nov 18 (Reuters) – BMO Capital Markets, the investment and corporate banking arm of Bank of Montreal Financial Group, said on Tuesday that it would add trade finance booking capabilities in Hong Kong as it moves to facilitate more business in Asia. The move comes just days after the central… – Continue reading

Irish Finance Bill 2014- FDI Focus

The Finance Bill 2014 (the “Bill”), which was published 23 October 2014, proposes a package of measures which focuses on Ireland’s tax rate, regime and reputation. The changes seek to reinforce Ireland’s position as a top destination for multinational companies and emphasise the importance of real and substantive foreign direct… – Continue reading

Russia Readies for Showdown Over Taxing Offshore Companies

Russia’s lower house of parliament on Tuesday took aim at the offshore holdings that have become ubiquitous in Russian business, passing in its final reading a bill that will make Russian taxpayers declare and pay taxes on their assets abroad. But once signed into law, this product of President Vladimir… – Continue reading

International Collection Efforts by the IRS – Expanding the Number of Treaties in which We Have Collection Language

The United States has treaty language that allows us to work with the taxing authorities in other countries to collect U.S. taxes owed from U.S. Citizens or their property located in those countries and to allow those countries to have IRS collect from their citizens or property located in the… – Continue reading

China central bank approves offshore yuan investment programme

SHANGHAI: China’s central bank has approved a pilot programme allowing some domestic institutional investors to buy offshore yuan products, the official Shanghai Securities News said, as Beijing pushes ahead in internationalizing its currency. The People’s Bank of China (PBOC) has recently approved the so-called Renminbi Qualified Domestic Institutional Investor (RQDII)… – Continue reading

US Corporate Giants Pay More to CEOs than in Federal Taxes

Seven of the biggest U.S. corporations received billions of dollars in tax refunds from the Internal Revenue Service, while dolling out an average of US$17.3 million to CEOs. While Congress is set to renew a slew of corporate tax breaks, new research published Tuesday found some of United States’ biggest… – Continue reading

Puerto Rico – Online reporting, payment of use tax by bonded importers reinstated and effective today

November 18:  A requirement for bonded importers to declare and pay use tax on goods imported into Puerto Rico has been reinstated and is effective today, November 18, 2014. These rules were reinstated by Administrative Determination No. 14-27 (November 6, 2014) as issued by the Puerto Rico Treasury Department. Background… – Continue reading

Final regulations – Failure to satisfy gain recognition agreements (GRAs) reporting requirements

November 18:  The Treasury Department and IRS today released for publication in the Federal Register final and temporary regulations (T.D. 9704) concerning the treatment of U.S. and foreign persons that fail to file gain recognition agreements (GRAs) or that fail to satisfy other reporting requirements associated with transfers of property… – Continue reading

29% Of Largest Corporations Pay More To CEO Than Uncle Sam

CEG says the U.S. corporate tax system is in desperate need of reform A recent report from the Center for Effective Government (Fleecing Uncle Sam) highlights that many large U.S. companies pay little to no corporate taxes, and a few even get tax rebates from the federal government. Moreover, in… – Continue reading

FATCA: Are Transnational Criminal Networks Influencing US Policy?

The New York Times’ report on prominent American think tanks receiving some $92 million from a minimum of 63 governments since 2011, prompted Rep. Frank Wolf (R-Va.) to ask Attorney General Eric Holder, a long overdue question: “Should think tanks be allowed to take undisclosed donations from foreign governments?” According… – Continue reading

Jean-Claude Juncker faces censure vote over Luxembourg tax schemes

Eureopean Union chief’s actions as prime minister of Luxembourg attacked over alleged role in creation of tax haven Jean-Claude Juncker is facing a vote in the European parliament to declare him unfit for his post as head of the EU executive because of his alleged role in turning Luxembourg into… – Continue reading

Cyprus: Cyprus India Relations – Cyprus May No Longer Be A Tax Haven For Funds Or May It?

A publication in the Economic Times has caused much debate in India since after blacklisting Cyprus for not sharing information on tax evaders, India is now looking to take away the favourable tax treatment available to investors from the European tax heaven under the bilateral tax treaty between the two… – Continue reading

Swiss Seek Better Image in Germany After Tax-Cheat Cases

Switzerland’s ambassador to Germany said his country is working to improve its image after years of revelations that Germans used Swiss banks to avoid taxes. Ambassador Tim Guldimann pointed to Switzerland’s support of an international agreement on automatic tax-data sharing in Berlin in October as a sign of his country’s… – Continue reading

Barbados and US sign FATCA agreement

THE GOVERNMENT of Barbados is committed to the implementation of global standards for the supervision and regulation of the international business and financial services sector. This affirmation came today from Minister of Industry, International Business, Commerce and Small Business Development, Donville Inniss, prior to signing a Foreign Account Tax Compliance… – Continue reading

France, a Tax Haven? Yes, for Companies From Microsoft to Huawei

Move over, Ireland. Companies from Microsoft Corp. (MSFT) to China’s Huawei Technologies Co. scouring Europe for fiscally attractive shores are turning to an unlikely country: France. As a base for research and development teams, that is. Tax breaks for R&D, 5.6 billion euros ($7 billion) this year alone, combined with… – Continue reading

Taxman’s new take on transfer pricing will attract foreign investments

In today’s global economy, where multinational companies do business in different geographical and tax jurisdictions, the need for arm’s length pricing of related party transactions is a growing concern for revenue authorities. Tax bodies are increasingly requiring multinationals to document their related party transactions. Where these transactions are not well… – 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

Beijing’s Interest in Offshore Tax Evasion Limited to Corrupt Officials

Fifty-one countries signed the Multilateral Competent Authority Agreement in Berlin on Oct. 29 to fight offshore tax fraud and evasion. The agreement aims to put an end to banking secrecy by sharing tax-related information with member states. Missing from the signatory list are the United States and China. China’s absence… – Continue reading

Reliance Jio Ties Up With Lenders for $1.5 Billion Loan Facility

New Delhi: Telecom operator Reliance Jio Infocomm has arranged credit facilities worth $1.5 billion with lenders, including Bank of America and Barclays, to refinance existing loans. Mukesh Ambani-led RJio would utilise the latest credit arrangements to re-finance debt tied up by it in 2010. The new loan facilities are guaranteed… – Continue reading

Businesswoman contests release of Cayman bank records

A high-profile businesswoman accused of using Cayman Islands bank accounts to dodge more than $7 million in taxes is seeking to challenge the use of information obtained by the U.S. Internal Revenue Service through a tax information exchange request. Cheryl Womack, a Kansas City businesswoman who has a home and… – Continue reading

Nigeria: Still On the Taxation of Foreign Companies Operating in Nigeria

IN July 2014, the Federal Inland Revenue Service (FIRS) sent letters to some tax consultants requesting their non-resident clients operating in Nigeria to file complete tax returns effective from 2014 tax year. In practice, non-resident companies file their tax returns on the deemed profit basis. Following an initial period of… – Continue reading

Benelux-China legal update

Recent months saw various important developments that are relevant to Sino-European trade and investment. These include (i) changes to the EU Parent-Subsidiary Directive, (ii) the entry into force of the double tax treaty between Luxembourg and Taiwan, and (iii) proposed changes to China’s Foreign Investment Catalogue and the Governmental Verifications… – Continue reading

Bill Gates commit money to Unitus’ offshore fund; Rupee fund bags $4M more

The venture seed fund has already announced 14 investments in India. Impact investor Unitus Seed Fund (USF) has announced that its India-focused offshore fund vehicle has received commitments from Microsoft co-founder Bill Gates, besides Concur Technologies’ CEO Steve Singh and Diego Piacentini, SVP (international consumer business) at Amazon.com Inc. It… – Continue reading

Chevron’s multi-billion tax dodging: We don’t agree

You know those annoying “We Agree” television ads by the fossil fuel corporate giant Chevron? The ones where an actor playing a student or a concerned member of a community “agrees” with supposedly noble objectives of this multinational? Those ads make me feel like puking. The objective of this campaign… – Continue reading

Cost-benefit analysis puts corporate tax avoidance in perspective

The growing crackdown on tax avoidance risks ushering in a broader suppression of international tax competition, harming the interests of all taxpayers. An inevitable consequence of economic globalisation is that supply chains and financial linkages have become dispersed across geographic space, and producers now strive to provide customers with quality… – Continue reading

Which offshore financial centre is the best?

Expats have a range of choices – so how do they find a safe home for their assets? The traditional use of offshore centres as a way of enabling better tax planning – and even tax evasion – has all but fallen away. An increasing desire for countries to share… – Continue reading

German Federal Fiscal Court decides on treatment of hybrid entities under the German-US double taxation treaty 14 November 2014

Hybrid entities have long been a tool for corporate tax planning. While tax authorities have fought the use of such hybrid mismatches for tax planning purposes, national efforts to prevent the use of hybrid mismatches have not proven to be very efficient, explain Michael Graf and Timothy Santoli, of Dentons… – Continue reading

US gains info on bank details of 4,273 under FATCA

TAIPEI, Taiwan — The Financial Supervisory Commission’s (FSC, 金管會) chairman Tseng Ming-chung (曾銘宗) met with the U.S. treasury from Nov. 2 till Nov. 5 and signed an Intergovernmental Agreement (IGA) under the Foreign Account Tax Compliance Act (FATCA) that will see Taiwanese financial institutions directly providing 4,273 Taiwanese green-card holders… – Continue reading

Ansbacher showed that in Ireland taxes were just for the ‘little people’

This offshore illegal scam showed that, in Ireland as elsewhere, taxes really were for the “little people”. The facts emerged as a by-product of the tribunal directed by Mr Justice Brian McCracken in 1997. It was set up to trace payments by supermarket magnate Ben Dunne to Fianna Fail’s Charlie… – Continue reading

PD link to tax dodge dossier alleged in Dail showdown

A WHISTLEBLOWER claimed former Tanaiste Mary Harney “shut down” his investigation into allegations of offshore tax evasion after he uncovered the names of senior politicians in the Progressive Democrats, Fianna Fail and Fine Gael, the Dail has heard. It is the first time Ms Harney’s party, the now defunct PDs,… – Continue reading

Should you stash cash in the Caymans?

The Cayman Islands is touted as one of the world’s top 10 finance hubs. The chief reason that the Caribbean hotspot holds such cachet is an epic perk it provides – freedom from income tax. twitter To get more Money more often, why not follow us on Twitter? We’re @FairfaxMoney… – Continue reading

No WHT exemption to foreign institutional investors: FBR

The Federal Board of Revenue (FBR) has proposed that no exemption whatsoever from withholding tax under Eighth Schedule (Capital Gains Tax) of the Income Tax Ordinance 2001 is available to foreign institutional investors either on the basis of avoidance of double taxation treaties or for any other reason. Through an… – Continue reading

PwC in secret tax deals while advising ATO

NEIL CHENOWETH Global accounting firm PwC was advising the Australian Taxation Office how to run its transfer pricing unit at the same time that its Luxembourg office was cutting favourable tax agreements for Australian companies. Luxembourg documents show PwC obtained secret tax agreements for more than 30 Australian companies in… – Continue reading

India signs tax info exchange pact with Saint Kitts & NevisNITED NATIONS:

To help in its efforts to crack down on suspected black money stashed abroad, India has entered into an information exchange pact with Saint Kitts and Nevis, a two-island Carribean country, perceived as a safe haven for offshore funds. The agreement was signed by India’s Permanent Representative to the UN… – Continue reading

The ‘Sonic’ boom: How Alberta became an ‘Offshore Business’ in the pathology market

Why does Stephen Mandel, the newly minted Minister of Health, think it’s a good idea for Alberta taxpayers to support the lifestyles of wealthy Australian businessmen who earn more than $13 million a year; their executive teams who get ridiculous bonuses and stock options; and the Australian economy as a… – Continue reading

Facing up to tax challenges in the age of digital economy

THE WORLDWIDE increase in digital commerce has alerted many countries to the unique tax challenges it presents. Facing up to tax challenges in the age of digital economy THE WORLDWIDE increase in digital commerce has alerted many countries to the unique tax challenges it presents. There is now a common… – Continue reading

G20 Brisbane: Five corporate tax havens around the world and how the summit can crack down on them

Prime Minister Tony Abbott has nominated global tax avoidance as one of the key issues on the agenda for this weekend’s G20 summit in Brisbane. Major companies including Google and Apple have faced strong criticism over their efforts to lower their tax bills by shifting profits to jurisdictions with low… – Continue reading

Costello defends Future Fund tax bill

Future Fund chairman Peter Costello has defended the amount of tax the sovereign wealth fund pays, saying it has ‘sovereign immunity’ when it invests overseas. The government-owned Fund was named along with other Australian companies for using Luxembourg as a base in which to lower global taxes in one of… – Continue reading

HMRC’s Yield From Specialist Investigations Rises

New research from international law firm Pinsent Masons has shown that the compliance yield from HM Revenue and Customs’ (HMRC’s) “Specialist Investigations” team rose by 23 percent last year to hit a record GBP3.65bn (USD5.79bn). 2013-14 was the team’s most successful year to date, according to Pinsent Masons. The GBP3.65bn… – Continue reading

Swiss Banker Faces Charges of Conspiring to Hide Hundreds of Millions

Preet Bharara, the United States Attorney for the Southern District of New York, and Shantelle P. Kitchen, Acting Special Agent in Charge of the New York Field Office of the Internal Revenue Service, Criminal Investigation (“IRS-CI”), announced today the indictment of MARTIN DUNKI, a former client advisor and Senior Vice… – Continue reading

US FATCA Registration Deadline Approaching: 31 December 2014

The British Virgin Islands (the “BVI”) has now enacted legislation which allows for the implementation of its commitments under the Model 1B (i.e. non-reciprocal) intergovernmental agreements with the United States, signed on 30 June 2014, (the “US IGA”) and with the United Kingdom, signed on 28 November 2013, (the “UK… – Continue reading

More than 4,000 Taiwan bank accounts affected by FATCA

Taipei, Nov. 13 (CNA) Taiwan’s financial authorities have found that there are 4,273 bank accounts in Taiwan whose holders are obligated to report assets to the United States tax authorities, Taiwan’s top financial regulator said Thursday. Tseng Ming-chung, chairman of the Financial Supervisory Commission, said most of the account holders… – Continue reading