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
When Burger King’s owners first announced last summer’s mega-deal to gobble up Tim Hortons, the fast-food firm’s executives downplayed a key reason why they were acquiring the Canadian coffee chain and relocating corporate HQ to Canada: to cut its taxes. “Tax wasn’t really the driver of this,” Daniel Schwartz, the… – Continue reading
On 3 April 2015, Uzbekistan and the United States signed a Foreign Account Tax Compliance Act (FATCA) Agreement. FATCA seeks to obtain information on accounts held by U.S. taxpayers in other countries. It requires U.S. financial institutions to withhold a portion of certain payments made to Foreign Financial Institutions (FFIs)… – Continue reading
Americans have overcome oligarchy before — and there’s no reason we can’t do it again. Rising inequality seems to pose an insurmountable political problem. If the underlying causes are technological change and globalization, the forces appear to be unstoppable. Alternatively, if the causes are primarily political and involve the power… – Continue reading
MUMBAI: The 1607-point decline on the Sensex in the past two weeks has unnerved many investors, but there could be more pain in store. May has historically been a bad month for stocks -in the past 24 years, the average monthly return of the Sensex has been a niggardly 0.24%…. – Continue reading
Tim Thornton, Chief Data Officer, Mitsubishi UFJ Fund Services comments on the upcoming deadline for registration on the Cayman FATCA portal… The upcoming 30 April deadline for registration on the Cayman FATCA portal is another milestone in the implementation of FATCA. The relatively short window from the portal being available,… – Continue reading
The Luxembourg Intellectual Property (IP) tax regime will be aligned to the “modified nexus approach”, as per Pierre Gramegna, Luxembourg’s Finance Minister. The IP regime is expected to be modified in 2015 and to be in force no later than 30 June 2016. This is driven by the OECD’s Base… – Continue reading
KELLY NJOMBO, Lusaka THE Jesuit Centre for Theological Reflection (JCTR) says Government’s discussion to approve changes to the mineral royalty tax regime will result in the increase in primary budget deficit and possible limiting of expenditure. JCTR says the threat of job losses, placing the mines under care and maintenance… – Continue reading
THE REVENUE Commissioner’s large cases division is investigating almost 100 schemes it suspects were designed by companies and wealthy individuals to avoid paying capital gains tax. The taxman is enquiring into 89 cases which used sophisticated financial instruments known as contracts for difference to generate artificial losses. The schemes avoided… – Continue reading
Lahore – Pakistan Tanners Association has said that exporters are paying full tax to the government and there is no chance of evasion of income tax on exports. “Exporters, whether making profit or loss, will have to pay 1% income tax on the value of each export consignment while 1%… – Continue reading
The world’s high and ultrahigh net worth families are run much like businesses these days, with family governance in place as well as fund structures in favourable tax jurisdictions that allow for consolidated reporting across diversified assets. That is the way the world is moving, with global tax authorities grouping… – 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
Benchmarks are poised just above their 200-day moving average — a long-term support April 25, 2015: Both the Sensex and the Nifty are very tantalizingly poised just above a long-term support level. This adds zing to next week’s trading that is expected to be full of action thanks to the… – Continue reading
Li Keqiang warns banks that he will use the country’s FTZs to help bring down borrowing costs and force lenders to change their ways Premier Li Keqiang has sent a clear message to the mainland’s commercial banks: he will use free-trade zones to ratchet up pressure on the lenders to… – Continue reading
SCOTTISH Nationalist MPs could help force up taxes at English airports unless their Westminster voting rights are curbed, David Cameron claimed yesterday (Friday, April 24). The prime minister raised the prospect of the Edinburgh Parliament slashing air passenger duty (APD) in Scotland, then its MPs voting with Labour to widen… – 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
Mumbai, April 25 (IANS): The capital gains tax claims on foreign funds with retrospective effect and worries over similar notices ahead hit the marked mood during the week ended Friday, sending a key index down to its lowest level in three-and-a-half months. The mixed corporate results for the last quarter… – Continue reading
NUMBER OF THE WEEK: 6.5 percent The tax rate at which companies could voluntarily repatriate their foreign earnings under the Invest in Transportation Act of 2015 ( S. 981). Senators Barbara Boxer (D-CA) and Rand Paul (R-KY) introduced the bipartisan proposal, offering ways to save the Highway Trust Fund. Funding… – Continue reading
Trade in today’s global era visualizes significant number of international transactions in form of transfer of goods, services, capital and intangibles. International transfers arise within the Multinational Enterprise group entities and are called intra-group transfer. What is actually paid by one entity to another entity in the intra-group transfer is… – Continue reading
Offshore investors look to New Zealand property markets New Zealand is emerging as one of the preferred property markets for global investors. This is a key finding in Colliers Internationals’ Capital Markets Report where prime average commercial, retail and industrial yields in Auckland and Wellington proved higher than their global… – Continue reading
India’s stand will show many nations in Asia and Africa the way to regain ill-gotten wealth stashed outside their countries “We have no information on any accounts held by Indian citizens in banks in Switzerland, Liechtenstein, Dubai or any other country. We have no information on the names of persons… – 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
However, OECD being persuasive may not help funds based out of nations whose treaties do not give specific exemption The Indian government’s clarification that it would honour tax treaties while making a demand of Minimum Alternate Tax (MAT) at the effective rate of 20 per cent came as a relief… – 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 20 March 2015, the British Virgin Islands Government issued revised guidance notes regarding the Intergovernmental Agreements between the British Virgin Islands (“BVI”) and the United States of America (the “US”) and the United Kingdom (the “UK”) to improve international tax compliance (the “Guidance Notes”). The Guidance Notes confirm that… – 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
“There have been times,” Hervé Falciani tells me, “when I’ve wondered if I was losing touch with reality. Could I really have seen what I saw, and revealed the things that I did, while the financial world continued as if nothing had happened?” Falciani, sometimes called “the Ed Snowden of… – Continue reading
Greece’s desperate bid to fund debt repayments by clamping down on tax evaders is doomed to fail, according to analysts. Leonidas Bobolas, the head of Greece’s largest construction firm was arrested on Wednesday and not released until after he had paid €1.8m in back taxes, despite the fact he had… – Continue reading
The U.S. Treasury Department has released proposed rules aimed at limiting theability of hedge funds to delay or lower their taxes by funneling investments through offshore reinsurance companies. The draft IRS regulations, which will not take effect until after a public comment period and any subsequent revisions, are aimed at… – Continue reading
Multinationals play such a large role in many nations’ budgets that effective control is crucial. Business Tax-base erosion cripples Africa 24 Apr 2015 00:00 Lisa Steyn Multinationals play such a large role in many nations’ budgets that effective control is crucial. Finance Minister Nhlanhla Nene says practices such as incorrect… – 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
Hong Kong (HKSAR) – The Government today (April 24) launched a consultation exercise to gauge views on proposals to apply, with adaptations for Hong Kong, the prevailing international standards on the automatic exchange of financial account information in tax matters (AEOI). On the basis of the Organisation for Economic Cooperation… – Continue reading
Arris stock on Thursday rose over 22 percent—leading the Nasdaq Composite index. The gain was due to an announcement that the company would acquire Pace, a U.K.-based telecommunications company. The deal will allow Arris to change its domicile to the United Kingdom, where it will enjoy a 21 percent tax… – Continue reading
PANAMA CITY (AP) — – Panama took a major step in an effort to clean up its reputation as Latin America’s premier hub for money laundering. The nation’s legislature late Wednesday unanimously approved a proposed law that will toughen supervision of more than a dozen non-financial sectors where illicit proceeds… – Continue reading
Registration is open for the Organisation for Economic Co-operation and Development’s (OECD’s) latest webcast, which will update stakeholders on progress towards the conclusion of its base erosion and profit shifting (BEPS) work. The webcast will last for one hour on June 8, 2015, beginning at 15:00 Central European Time (CET)… – Continue reading
Tax evasion overseas has been further targeted by authorities as HM Revenue and Customs (HMRC) implements tougher penalties for those who hide assets and income abroad. The maximum penalty for offshore evasion of income and capital gains tax has doubled to 200 per cent of the tax due, but can… – Continue reading
Chinese investors in Kenya have asked the East African Community to implement a double taxation agreement (DTA), saying the current regime has hurt their expansion plans. The investors with interests in construction, trade, service industry, manufacturing and real estate sectors said they currently face a heavy burden paying the same… – Continue reading
Panama took a major step in an effort to clean up its reputation as Latin America’s premier hub for money laundering, reports the AP. The nation’s legislature late Wednesday unanimously approved a proposed law that will toughen supervision of more than a dozen non-financial sectors where illicit proceeds from 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
Political activists gatecrashed Barclay’s AGM in Central London on Thursday to highlight the role of private finance initiatives (PFI) in “killing off” Britain’s public services, racking up unsustainable debt, dodging tax and funneling profits offshore. Thursday’s demonstration marks the first of three planned days of protest to raise awareness about… – 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
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
On Oct. 14, 1960, President John F. Kennedy made an impassioned plea to University of Michigan students, exhorting them to move abroad and assist nations struggling under the weight of underdeveloped economies. Kennedy was convinced American talent is a unique, effective export commodity. That speech laid the foundation for the… – Continue reading
The Foreign Account Tax Compliance Act (FACTA) has created a global impact on tax policy and how international investors run their financial lives. Should investors be worried that 50% of their portfolios will be seized as a fine? Or is it even worse. How many will go to jail because… – 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
A property investment company does not believe its advert selling Auckland property as a cash cow for offshore landlords is exploiting New Zealanders. The radio advert has been on air in Singapore since Monday for Property Solutions Singapore, which is a subsidiary of Dunedin-based company Australian Property Solutions. It said… – Continue reading
Athens: The head of one of Greece`s largest construction companies was arrested Wednesday on charges of tax evasion and ordered to pay the state 1.8 million euros ($1.9 million), the first such action since the radical left government came to power. Leonidas Bobolas, CEO of the Ellaktor group, was brought… – Continue reading
