Category: Activity

Tax Directors Expect Their Companies to Expand

Tax directors at many organizations anticipate their companies will grow by entering into new domestic and international markets in the years ahead, according to a new survey by BDO USA. In a sign of an improving economy, 50 percent of the 100 tax directors at $1billion-plus public companies surveyed by… – Continue reading

Administration Proposes to Repeal Deferral, Haircut the Foreign Tax Credit and Interest Expense Deductions, Override Treaties, and Abandon Arm’s-Length Transfer Pricing for Intangibles

As the above title indicates (it is only a modest exaggeration), the Treasury Greenbook regarding the FY 2016 budget proposes a radical restructuring of the system for U.S. taxation of foreign income of U.S. multinational enterprises (MNEs). Some Congressional players have suggested that these proposals are an opening bid in… – Continue reading

One-Third of Americans Living Abroad Have Thought Actively About Renouncing Citizenship Due to Tax-Filing Requirements

It’s not just fatcats feeling the pain of FATCA Tax Day is particularly bittersweet for the estimated 7-8 million American citizens living outside the United States. Not necessarily because they have to pay taxes, but that they have to deliver microscopic filings of all their overseas bank accounts and financial… – Continue reading

Canada: Increasing Corporate Penalties And Risk Management (Update To “Seven Corporate Sins As A Source Of Government Revenue And Economic Stimulus”)

Introduction Soft commodity prices, divergent monetary policies across major economies, high unemployment rates and weak world trade have all conspired to slow down global economic recovery over the past seven years. Consequently, governments have had to cut spending as future revenues remain uncertain. This has led governments to look for… – Continue reading

Syndicated loan borrowings abroad fall as companies tap bonds for expansion

MUMBAI: India’s syndicated loan borrowing in overseas markets has collapsed in the January-March quarter as Indian companies have taken the bond route to fund their expansions, and investments are yet to pick up. Loans denominated in US dollar, Japanese yen or euro dropped 75 per cent year-on-year. India G3 syndicated… – Continue reading

PwC among auditors enlisted by China to probe state firms’ offshore assets

Beijing enlists seven firms, including PwC, to investigate projects and holdings this year Beijing has appointed seven audit companies, including international firm PwC, to look into the overseas assets of major state-owned enterprises as it tightens the reins on the business giants. The State-owned Assets Supervision and Administration Commission (Sasac)… – Continue reading

Beneficial Ownership and AML, Sanctions and Anti-Corruption Compliance

Sometimes compliance realities outpace enforcement and regulatory requirements. When it comes to FinCEN’s proposal to implement a beneficial ownership rule for financial institutions (see Here), global financial institutions do not need to worry about the outcome of the FinCEN regulations. Global financial institutions already have to know their (your) customer… – Continue reading

Guernsey presence felt at US estate planning conference

Guernsey’s fiduciary sector was represented at a prominent international estate planning conference in the United States. Three representatives of Trust Corporation International attended the 11th annual International Estate Planning Institute event in Times Square, New York, where the firm was also a gold sponsor. A distinguished panel of experts debated… – Continue reading

European Union: European Competition Law Newsletter – April 2015

EU’s Highest Court Rules on Information Exchange On 19 March 2015, the European Court of Justice (ECJ) handed down a significant judgment on the application of EU competition law to information exchange between competitors. The case was an appeal from the European Commission’s 2008 decision to fine banana importers Dole,… – Continue reading

OFFSHORE TAX HAVENS COST SMALL BUSINESSES $3,244 A YEAR

Washington, D.C. – As tax day approaches, it’s important to remember that small businesses end up picking up the tab for offshore tax loopholes used by many large multinational corporations. U.S. PIRG joined Senator Bernie Sanders, Bryan McGannon of the American Sustainable Business Council, and Bob McIntyre of Citizens for… – Continue reading

Broadscope Releases Timely White Paper Regarding US and UK FATCA Reporting Obligations for Cayman Islands Domiciled Private Equity Funds

PARAMUS, N.J., April 13, 2015 /PRNewswire/ — Broadscope Fund Administrators, an independent private equity fund administration firm, released a white paper outlining key US FATCA and UK FATCA reporting and registration deadlines for Cayman Islands private equity firms. The paper, US and UK FATCA Reporting Obligations for Cayman Islands Domiciled… – Continue reading

Twenty-eight English clubs are now owned overseas, increasing the risk of tax avoidance

Research by the Guardian and the Tax Justice Network reveals 28 English clubs with substantial shareholdings overseas, opening up the football leagues to criticism for allowing ownership structures that could be used for tax avoidance Almost one in three of the 92 Premier and Football League clubs are now substantially… – Continue reading

Shire share price movement suggests pharmco is better off on its own

Analysts upbeat on the company’s standalone prospects The recent share price performance of Shire Plc (LON:SHP), the London-listed drugmaker left at the altar by US pharma giant AbbVie (NYSE:ABBV) last year, suggests that the company will continue to thrive on its own, a view supported by recent analyst comments on… – Continue reading

Ten Percent of S&P 500 Companies Avoid Paying U.S. Taxes

When it comes to taxes, corporate America is getting a bit less corporate. And a bit less American. Fueled by a wave of inversions, a record 54 companies in the Standard & Poor’s 500 Index of leading U.S. firms are now at least partially exempt from the corporate income tax…. – Continue reading

Tax Directors Anticipate Domestic and Cross-Border Growth Over The Next Three Years, According To The Inaugural BDO Tax Outlook Survey

– Rising Cost of Compliance Within The Tax And Financial Regulatory Environment Creates Opportunities For Increased Efficiency – CHICAGO–(BUSINESS WIRE)–As the economy continues to accelerate, many organizations plan to grow by entering into new markets in the years ahead, reveals the first ever BDO USA, LLP Tax Outlook Survey. Fifty… – Continue reading

Canada: Private Client Tax, Third Edition – Chapter: Canada

1. NON-TAX ISSUES 1.1 Domestic law 1.1.1 Briefly describe your legal system and its origins Canada is a federal state, with legislative powers divided between the federal and provincial governments. The federal government has legislative jurisdiction over issues concerning Canada as a whole, including foreign affairs, international trade, banking, telecommunications,… – Continue reading

Social networking sites to become work places

The Revenue Office will take steps to tax social networking sites and implement other regulations related to e-commerce. After the implementation of this regulation, all such virtual sites will be deemed as “work places” and the advertisers of social networking sites will also be deemed as “electronic tax payers.” Moreover,… – Continue reading

10 Notorious Tax Cheats: Billionaire Olenicoff Still Battling UBS Over $200 Million Offshore Stash

His softball sentence of two years probation ended five years ago. But billionaire real estate developer Igor Olenicoff still can’t put behind him his December 2007 guilty plea to lying on his federal tax return about some $200 million he kept offshore. For that, he can blame his own litigiousness… – Continue reading

PICKING UP THE TAB 2015: SMALL BUSINESSES PAY THE PRICE FOR OFFSHORE TAX HAVENS

Every year, corporations and wealthy individuals use complicated gimmicks to shift U.S. earnings to subsidiaries in offshore tax havens – countries with minimal or no taxes – in order to reduce their federal and state income tax liabilities by billions of dollars. While tax haven abusers benefit from America’s markets,… – Continue reading

UAE MoF and UAQ FTZ sign MoU on international OECD tax regulations

The Ministry of Finance (MoF) recently signed a memorandum of understanding (MoU) with Umm Al Quwain Free Trade Zone Authority (UAQ FTZ). This agreement has been signed to ensure international standards of transparency in the exchange of information for tax purposes, as per Organisation for Economic Cooperation and Development (OECD)… – Continue reading

New tax treaty between Hong Kong and mainland China which has consequences for shipping, airline and securities trading companies

This is relevant mainly for (1) Hong Kong companies or investment funds selling securities in Chinese listed companies and (2) ship or aircraft leasing companies resident in Hong Kong who (finance) lease vessels and aircraft to lessees in mainland China. On 1 April 2015, Hong Kong and mainland China signed… – Continue reading

Legal flash – Shanghai office – March 2015 – Announcement of the State Administration of Taxes concerning enterprise income tax on fees resident enterprises pay to overseas related parties

In recent years, the State Administration of Taxes (“SAT”) has paid closer attention to fees resident enterprises pay their overseas related parties, concerned that multinational groups have shifted profits away from China through aggressive tax planning and by paying unreasonable service fees and royalties overseas. Following PRC’s active participation in… – Continue reading

Indian banks make a beeline for space in Gujarat’s Gift City

Bank of India, Bank of Baroda, Corporation Bank, Punjab & Sind Bank, HDFC Bank and many others have signed up for space in Gujarat’s International Finance Tec-City (also known as Gift City). In fact, banks are expected to be the first to kick off operations in 2016/17, when the International… – Continue reading

Central Bank Governor of the Year 2015, Asia Pacific

The ‘Green Governor’ has a reputation for innovative thinking and problem solving. He is renowned for his support of the agriculture sector and his focus on SME as well as green banking. As one of the most progressive and well-respected Central Bank Governors in the world, United World discusses Bangladesh’s… – Continue reading

UK: Tax Issues Update – April 2015 – IP Profit And Protection: Techniques For Future Success

Historically taxpayers have faced difficulty overcoming a presumption against a change in domicile to a foreign jurisdiction. Intellectual property generally will be the most valuable asset held by technology companies and, in fact, many other business entities across all sectors of the economy. A recent analysis of S&P 500 companies… – Continue reading

Dubai Judicial Institute holds joint workshop with US Department of Justice

International and local experts discuss best judicial solutions for intellectual property and money laundering crimes UAE – Dubai Judicial Institute (DJI), in partnership with the Office of Overseas Prosecutorial Development, Assistance and Training (OPDAT) of the U.S. Department of Justice, held a special joint workshop designed to raise more awareness… – Continue reading

Cayman Islands: Don’t Get Snowed In By GATCA

Offshore investment entities in the Cayman Islands and many other international financial centers should now start turning their attention to compliance with the Common Reporting Standard (“CRS”) promulgated by GATCA – Global FATCA. They must document all account holders existing on December 31, 2015, with the exception of entities with… – Continue reading

Worldwide: Protecting Yourself From International Tax Investigations

Who Will Be Next? How To Respond To A Tax Investigation The international political community continues to make the most threatening noises about those who they believe do not pay enough tax. Long gone it seems are the days where it was accepted that a person could properly organise his… – Continue reading

Europe slow to adopt new accounting standard despite Greek crisis

In the five years since the eurozone crisis exploded, the European Union has adopted a great number of measures to improve its fiscal governance. Yet amazingly, it still does not have a robust, harmonized way of measuring and monitoring the financial activities of its member states, reports the Wall Street… – Continue reading

FATCA List – March 01, 2015

The list of international financial institutions signing up to comply with the US Foreign Account Tax Compliance Act (FATCA) is still growing. Another 3,734 registered as FATCA compliant during March, taking the total number to 160,010 from 227 financial jurisdictions – up from 156,276 in February. Every organisation listed has… – Continue reading

The Baltic States and Greece: Divergent Crises

It has become increasingly fashionable to compare the results of Greece and the Baltic States’ response to the financial crisis of 2008, most recently last month with the Financial Times’ column with John Dizard. This, however, is a classic textbook case of comparing apples to oranges. Greece’s crisis was chiefly… – Continue reading