Category: Activity

FATCA documentation for disregarded entities

Introduction The Foreign Account Tax Compliance Act (FATCA) requires entity account holders to document their status for US withholding tax purposes (Chapter 3 status) and their status for FATCA due diligence purposes (Chapter 4 status). In the case of a non-US entity account holder that has made an entity classification… – Continue reading

Pressure for tax reform building as corporate ‘inversions’ continue, says expert

The reported resurgence of cross-border mergers involving US companies that then move their corporate headquarters abroad shows that anti-tax avoidance measures passed last year were “a sticking plaster rather than a long-term solution”, an expert has said17 Jun 2015 The Financial Times reported (registration required) that demand for corporate ‘inversion’… – Continue reading

Swiss attorney general cites 53 possible money-laundering incidents in FIFA World Cup probe

BERN, Switzerland – Reeling from an American federal investigation of bribery in soccer, FIFA was put under more pressure Wednesday as the scale of a separate Swiss investigation of suspected money laundering was revealed. Banks in Switzerland have flagged up 53 possible acts of money-laundering that could be linked to… – Continue reading

FATCA reporting deadline nears

The 30th June 2015 deadline for Isle of Man Reporting Financial Institutions to submit their first US FATCA reports to the Income Tax Division is now less than two weeks away. The reports, in respect of the 2014 reporting year, can only be accepted by the Assessor in the prescribed… – Continue reading

Proposed U.S. Model Treaty Provisions May Dramatically Alter International Tax Landscape

The U.S. Model Income Tax Treaty (the U.S. Model Treaty) generally represents the United States’ opening position in treaty negotiations. As a result, when changes to the treaty are proposed, international tax practitioners should be aware of the potential impact those changes can have on their existing inbound U.S. structures…. – Continue reading

Disgraced Fifa Boss Stashed $1m At Cibc Bahamas

A disgraced senior FIFA official has agreed to forfeit 50 per cent of the $1 million he had stashed away in a secret CIBC FirstCaribbean International Bank (Bahamas) account, court documents have revealed. The plea agreement between the US federal authorities and Charles (Chuck) Blazer, which was unsealed late on… – Continue reading

Bahamas: Financial Industry fears FATCA start with no legislation

The Bahamian financial industry is concerned it will have to start reporting information for the US Foreign Account Tax Compliance Act (FATCA) without the necessary legislation being in place, Tribune Business can reveal, reports the Bahamas Tribune. Lawrence Lewis, a Deloitte & Touche (Bahamas) partner and accountant, confirmed to Tribune… – Continue reading

Vietnam: Refinancing A Domestic Loan With An Offshore Loan?

Vietnamese regulations and policy are certainly not in favor of using foreign loans to refinance existing domestic loan debts. However, the State Bank of Vietnam (SBV) could feasibly exercise its discretion to permit such loans if applicants made a compelling case. Prudent cross-border lenders will require Vietnam borrowers to disclose… – Continue reading

LPC-Turkish borrowers target Asian loan investors

Turkish banks and companies are trying to sell syndicated loans to Asian investors after a drop in Asian lending but investors are wary of increasing Turkish exposure due to political instability following June’s elections, bankers said. Turkish borrowers are targeting Asian investors in a bid to extend loan maturities after… – Continue reading

Maximise tax revenues

Britain’s taxing question is whether to maximise revenues or face more austerity. Given the scale of state spending that’s the stark choice facing chancellor George Osborne if he wants to balance the books in this parliament, says James Sproule We are once again considering the tax options facing the chancellor… – Continue reading

New transfer pricing law aims to counter tax planning

Tax avoidance can be defined as aggressive tax-planning strategies and structures by multinational companies that take advantage of the gaps or mismatches in tax rules to shift profits to low-tax locations. While many countries around the world have either general or specific anti-avoidance legislation to tackle this problem, the current… – Continue reading

The Fifa scandal and money laundering laws

Blatt’s all folks!’ was probably the pick of the tabloid headlines following the announcement that Sepp Blatter intends (finally) to step down as president of Fifa. Over the course of the next few months, he won’t be the only person anxiously awaiting the outcome of the current investigations into alleged… – Continue reading

New tax treaty with Mauritius may affect cross-border investment

THE new double-tax treaty between SA and Mauritius is set to come into force in January next year, following a controversial renegotiation to better protect the South African tax base. However, tax experts have warned that sweeping changes to the treaty, including withholding taxes for interest (10%) and royalties (5%)… – Continue reading

Julius Baer Starts Probe Amid FIFA Corruption Allegations

Julius Baer of Switzerland became the latest bank to start an internal probe of money transfers linked to an investigation of FIFA, world soccer’s ruling body. Julius Baer joined banks including the U.K.’s Standard Chartered Plc in reporting that it began an inquiry. The Zurich-based firm was named as one… – Continue reading

Hypocrisy of EU Tax Avoidance Plan Exposed

The European Commission is set to adopt an Action Plan to tackle corporate tax avoidance and promote growth-friendly taxation in the Single Market despite an uphill battle against global giants such as Apple and Starbucks, as well as some hypocritical member states. The European Commission’s plans unveiled Wednesday include a… – Continue reading

ZRA grants tax deferment

Zambia Revenue Authority -ZRA- Commissioner General Berlin Msiska says the authority has granted tax deferment to some mining firms following cash flow challenges in the sector. Mr. Msiska says the deferment was given after the said firms applied because of challenges facing the sector and was granted in accordance with… – Continue reading

Wal-Mart Has $76 Billion in Overseas Tax Havens, Report Says

Wal-Mart Stores Inc. owns more than $76 billion of assets through a web of units in offshore tax havens around the world, though you wouldn’t know it from reading the giant retailer’s annual report. A new study has found Wal-Mart has at least 78 offshore subsidiaries and branches, more than… – Continue reading

Inland Revenue confirms transfer pricing unit

Windhoek Namibia’s Inland Revenue has established a transfer pricing unit. “We will be asking you for transfer pricing supporting documents soon,” said Acting Commissioner for Inland Revenue, Justus Mwafongwe, at the recent annual tax symposium hosted by the PwC’s Namibia Business School. Mwafongwe confirmed that the draft amendment bills to… – Continue reading

IBFD holds first-ever Africa tax symposium

Bring together an impressive group of respected tax professionals from all over Africa, International Bureau of Fiscal Documentation (IBFD) is set to hold “Africa Tax Symposium, Trends in International Taxation: An African Perspective,” from June 18-19, 2015 in Livingstone, Zambia. IBFD announces that its inaugural The two-day event will present… – Continue reading

US companies regain their appetite for tax inversion deals

US companies have regained their appetite for controversial foreign takeovers that allow them to move overseas and escape US taxes, in spite of a White House crackdown to restrict so-called tax inversions last year, reports the Financial Times. According to several senior corporate advisers in the US and Europe, demand… – Continue reading

United States: KMT’s David Klein Considers Pennsylvania’s New Online Gambling Bill

Odds improve for online gaming Regulate or delegate — that’s the question facing Pennsylvania legislators as bills to legalize online gambling gain traction. A new bill in the state Senate — SB 900, allows the state, among other things, to license operators to conduct Internet gaming. It’s a practice many… – Continue reading

Can The United States Kill BEPS?

The United States is through trying to needle the OECD’s base erosion and profit-shifting project with pinpricks. Last week, Robert Stack, U.S. Treasury deputy assistant secretary (international tax affairs), abandoned the subtle digs Treasury had been using to attack BEPS and flat-out said the United States is extremely disappointed in… – Continue reading

Financial Industry Fears Fatca Start With No Legislation

The Bahamian financial industry is concerned it will have to start reporting information for the US Foreign Account Tax Compliance Act (FATCA) without the necessary legislation being in place, Tribune Business can reveal. Lawrence Lewis, a Deloitte & Touche (Bahamas) partner and accountant, confirmed to Tribune Business that there was… – Continue reading

HMRC Welcomes New Tax Avoidance Ruling

HM Revenue and Customs (HMRC) has welcomed a court ruling against an avoidance scheme that enabled two banks to avoid corporate income tax on interest on floating loan rate notes. In this type of loan, the interest rate (and therefore the installment amount) fluctuates according to the rise or fall… – Continue reading

Brussels to announce measures against corporations’ ‘sweetheart’ tax deals

Politically incendiary proposals will set sights on multinationals’ tax planning with EU states and 30 worst offending havens could be officially blacklisted Officials in Brussels will on Wednesday announce a series of measures designed to stamp out the toxic culture of secret, sweetheart tax deals for multinationals which prevails in… – Continue reading

Fund administration – opportunities for offshore and alternative investment funds

Following the implementation of the EU Alternative Investment Fund Managers (AIFM) Directive (2011/61/EC) and associated legislation, Cyprus now lays claim to being a growth jurisdiction within the European Union for the establishment and servicing of boutique and low cost alternative investment funds based locally or offshore. The choice of fund… – Continue reading

Airbnb, Amazon Land on French Senators’ Tax Radar as Sales Soar

France is trying to squeeze more out of web businesses like EBay Inc., Amazon.com Inc. and Airbnb Inc. Soaring online sales and the use of the Internet giants by smaller businessses as a marketplace for goods and services is prompting the French Senate to look for ways to collect more… – Continue reading

‘Zero tolerance’ for tax evasion, Ottawa claims

Report on ‘poor’ neighborhoods full of mansions sparks calls for tax enforcement, residency documentation OTTAWA — The Canadian government takes a “zero tolerance” stand on tax evaders and is currently conducting audits on property owners in B.C., according to the Canada Revenue Agency. But Vancouver immigration lawyer Samuel Hyman said… – Continue reading

Birth of a New Era in Private Wealth

As the financial world continues its march towards a more transparent and open environment, regulations governing private wealth are under scrutiny. The traditional is changing for good while new players emerge. Once was a time, not too long ago, the words “Swiss bank” conjured up evocative imagery: secret deals; bank… – Continue reading

TAXE – a fundamental shift in ruling practice?

The LuxLeaks financial scandal, which entailed disclosure by the International Consortium of Investigative Journalists of tax rulings, galvanized public opinion and gave rise to the creation of TAXE, the European Parliament’s special committee on tax rulings. This article explains why TAXE was created and shares with you highlights from the… – Continue reading

Divisions in US over OECD corporate tax proposals

Senior Republicans voice concerns over Obama administration’s response to plan Political divisions are opening up in Washington over the US response to the overhaul of international tax rules by the global powers, an initiative with big implications for Ireland’s corporate tax regime. The Republican leaders of the two tax-writing committees… – Continue reading

Nigeria Sends Clear Signal of Getting Serious on Tax Evasion, Avoidance

With revenue from petroleum taxes at its lowest point in fifteen years, Nigeria is under even more pressure to tackle tax evasion and pursue other revenue enhancing initiatives. Indeed, experts have found that tax evasion plays a significant part in the over $50 billion that the continent loses every year… – Continue reading

Treaties likely on exchange of tax information

ISLAMABAD: Several amendments have been proposed to the tax laws in the Finance Bill 2015-16 to empower the federal government to enter into agreements for exchange of tax-related information with provinces and other countries. The new sections proposed to be inserted in the Finance Bill will empower Islamabad to enter… – Continue reading

Frustrated by Rs 20,495-crore tax demand on Cairn: Vedanta

MUMBAI: With its subsidiary Cairn India facing Rs 20,495-crore tax notice, billionaire Anil Agarwal-led Vedanta Group today said it is “frustrated” by the tax demand raised on it using retrospective legislation. The Income Tax Department had in March slapped a Rs 20,495 crore tax demand on Cairn India for failing… – Continue reading

Malta:FATCA Reporting Deadline Extended Again

The Maltese Commissioner for Revenue has announced a further extension in relation to the deadline on reporting for FATCA purposes from 15 June 2015 to 3 July 2015. The FATCA reporting deadline in Malta is normally 30 April. The Commissioner has confirmed that this exception will apply for reporting in… – Continue reading