Category: Activity

No Agreement On BEPS Foreign Company Income Definition

Law360, New York (April 06, 2015, 3:10 PM ET) — A draft report released Friday by the Organization for Economic Cooperation and Development on strengthening controlled foreign-company rules to crack down on tax evasion said there are substantial disagreements among member states about how to best define CFC income. The… – Continue reading

Bad for business? Experts, industry insiders say part of Bentley tax plan will hurt job creation

This week, the Alabama Legislature approved the centerpiece of the Made in Alabama Job Incentive Package, which the Department of Commerce, Gov. Robert Bentley and the state’s economic developers hope will attract new companies and expansions of existing industry in Alabama. But lawmakers will soon debate another package of bills… – Continue reading

European Banking Weekly Notes: HSBC, RBS and Barclays

European bank shares showed notable improvements in prices last week, benefiting from hopes of Greece evading a crisis coupled with continued strength in the U.S. dollar. Reports that Germany is looking to adopt a new law that will boost the capital position of the country’s banks helped Deutsche Bank (NYSE:DB)… – Continue reading

New Russian CFC Rules Will Impact Inbound U.S. Tax Planning

According to recent estimates, the number of wealthy Russians investing in the United States ballooned in 2014 as a result of political turmoil and a disintegrating ruble causing Russians to seek a safe haven for their wealth abroad. The amount of private net capital flowing out of Russia hit $120… – Continue reading

Rupert Murdoch’s US empire siphons $4.5b from Australian business virtually tax-free

Rupert Murdoch’s media empire in the US has siphoned off $4.5 billion of cash and shares from his Australian media businesses in the past two years, virtually tax free. According to calculations by University of NSW accounting academic, Jeffrey Knapp, over the past 10 years, Mr Murdoch’s companies here have… – Continue reading

Valeant Finally Bags Salix for $11 Billion

After much of a clout about who will acquire Salix Pharmaceuticals (SLXP), Canadian Drug maker Valeant Pharmaceuticals International Ltd (VRX) completed the purchase for $11 billion last Wednesday. Salix Pharmaceuticals works in gastro instrumental drugs and it will provide Valeant with new therapeutic business. This is Valeant’s biggest buy so… – Continue reading

OECD discussion draft considers Controlled Foreign Corporation Rules

On April 3, 2015, as part of its Action Plan on Base Erosion and Profit Shifting (BEPS), the OECD released a discussion draft entitled “BEPS Action 3: Strengthening CFC Rules” (the Draft) for comments. The Draft stresses the importance of CFC rules in countering base erosion and profit shifting, and… – Continue reading

India sends out nearly $6-billion worth of tax notices to foreign funds

Till March 31, close to 100 FIIs got notices from the Tax Department for a controversial Minimum Alternate Tax (MAT) of 20 per cent, while they are now being followed up with Assessment Orders. In the biggest-ever tax demand slapped on them, nearly 100 foreign funds have been asked to… – Continue reading

Tax Pros Wary After IRS Hires Quinn Emanuel Litigators

Law360, New York (April 06, 2015, 4:47 PM ET) — Microsoft Corp. recently brought to light the IRS’ hiring of litigators from Quinn Emanuel Urquhart & Sullivan LLP to assist with examining the tech company’s transfer pricing activities, and some tax professionals say the agency’s unprecedented move is troubling. In… – Continue reading

Africa loses $528.9 billion to illicit transfers in a decade

It has been revealed that illicit financial transfers are draining Africa of massive resources needed to uplift its majority poor from the claws of poverty and provide both productive and social infrastructure for development. The African Civil Society Circle, a group of nine civil society organizations and think tanks from… – Continue reading

The outlook for BEPS in 2015

National tax laws are struggling to keep pace with the rise of the digital economy and the progress of multinational companies. These factors leave gaps that are susceptible to misuse and lead to cases of double non-taxation, which undermine the integrity and fairness of tax systems around the world. The… – Continue reading

Kellogg’s says tax clampdown will harm profits

Warning from Corn Flakes maker comes amid international pressure to close tax loopholes Kellogg’s has warned that its profits could be hurt by the international drive against tax avoidance, which is targeting structures that benefit multinationals. The US-based maker of Corn Flakes, Rice Krispies and Coco Pops is worried that… – Continue reading

100 foreign funds get tax demands; total bill may hit $10 bn

New Delhi/Mumbai: In the biggest-ever tax demand slapped on them, nearly 100 foreign funds have been asked to cough up an estimated USD 5-6 billion for ‘untaxed gains’ made by them in the Indian markets over the past years. The number of affected investors can rise substantially as assessments are… – Continue reading

Australia: US Citizens and Green Card Holders – the long arm of the IRS

You may be forgiven for thinking that once you no longer live in the United States, that your ongoing US tax obligations may be relatively simple or even non-existent, particularly if you have never held a US Passport or lived in the US. However the definition of US citizen is… – Continue reading

UFIA Bill could impact Make in India policy: Sonu Iyer

Interview with Partner and National Leader, Human Capital Services, EY India The Undisclosed Foreign Income and Assets (Imposition of Tax) Bill, 2015, popularly called the “anti-black money bill” has been in the news for its stringent and sweeping provisions. Sonu Iyer, partner and national leader, human capital services, EY India,… – Continue reading

Energy company’s $11 billion transfer to Singapore rings tax avoidance alarm bells

An energy company operating in Australia transferred more than $11 billion to the low-tax jurisdiction of Singapore in a single year, heightening concerns that Australia is being duped by tax-minimising multinationals. The extraordinary scale of funds being moved out of the country by individual companies is revealed in an internal… – Continue reading

More profit-shifting to Singapore: report

Internal documents from the Australian Taxation Office indicate an energy company operating in Australia transferred more than $11 billion to low-taxing Singapore, according to Fairfax Media. The report says the documents, secured under freedom of information, underline concerns that multi-nationals operating in Australia are dodging their tax obligations. The document… – Continue reading

425 tax offenders blacklisted

BEIJING, April 3 (Xinhua) — The State Administration of Taxation (SAT) has blacklisted 425 companies for tax offences, it announced on Friday, as the government aims to get tough on tax offenders. The offences took place between the start of 2013 and the end of 2014 and involved 553 corporate… – Continue reading

FATCA Repeal is Dead

Last month US Senator Roger Wicker (R-Miss.) introduced a budget amendment SA 621 to repeal the Foreign Account Tax Compliance Act (FATCA) FATCA requires foreign financial institutions to disclose to the IRS about their U.S. customers’ accounts. The U.S. loses an estimated $150 billion in tax revenue each year to… – Continue reading

No hiding place for expat tax evaders

New rules mean that almost 100 governments around the world will exchange information about bank accounts Expat tax dodgers are running out of places to hide, as information about their bank accounts and assets will soon be exchanged between 93 governments globally. At present, if tax authorities suspect people of… – Continue reading

The Knowledge Congress Has Scheduled a Live Webcast on Emerging Issues: FATCA Goes Global Live Webcast

New York, NY, April 03, 2015 –(PR.com)– The Knowledge Group/The Knowledge Congress Live Webcast Series, brings together the world’s leading authorities and industry participants through informative two -hour webcasts. It has scheduled a live webcast entitled: “Emerging Issues: FATCA Goes Global LIVE Webcast” This two-hour event is scheduled on April… – Continue reading

$32 Trillion Stashed in Offshore Bank Accounts – Asset Protection Planners Examine the Facts

More and more Americans are opening offshore bank accounts. This article provides statistical details about why this is so, that offshore banking can be safe and legal and which banking jurisdictions are safest. Apr. 3, 2015 / PRZen / VALENCIA, Calif. — Offshore banking is growing in leaps and bounds… – Continue reading

Weak tax systems, evasion behind 60% of global illicit money transfers — Report

Governments in resource-rich African countries must effectively negotiate the terms of operational contracts with mining companies and their affiliates if they are to avoid revenue losses that reduce their capacity to finance development, the African Civil Society Circle has said. The Circle is a coalition of nine civil society groups… – Continue reading

Joe Hockey’s Google tax could derail international tax treaties: Budget Office

The likely centrepiece of Treasurer Joe Hockey’s assault on multinational profit-shifting – a so-called “Google tax” – risks breaking Australia’s international tax treaties, the Parliamentary Budget Office has found. The independent adviser warned that the unilateral introduction of a “diverted profits tax” like ones being considered by Australia and Britain… – Continue reading

Designer names attract Miami home buyers

SUNNY ISLES BEACH, Florida — The wow factor for Miami’s skyscraper condos no longer comes from a dazzling Atlantic Ocean view. It takes something more audacious to sell beachfront property these days to the global ultra-wealthy who arrive in Miami with millions to spend on second or third homes. It… – Continue reading

Future Fund refuses to appear before Senate tax avoidance inquiry

Inquiry sparked by leaked Luxembourg files naming the sovereign wealth fund among dozens of Australian companies using elaborate structures to cut tax bills The $100bn Future Fund has refused to give evidence to a Senate inquiry into corporate tax avoidance despite being named in leaked documents last year among scores… – Continue reading

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

Pensions, Taxes & Fatca: Finance Tips for British (& Other) Expats in the U.S.

We asked Vincenzo Villamena, a New York-based international tax adviser and certified public accountant with Online Taxman, and his British-expat client Ed Zitron of San Francisco, to share personal finance tips for expats, particularly those hailing from the U.K. Here are their top tips: 1. Mind your pensions & QROPS!… – Continue reading

Google, Apple tax crackdown will fail without US support

Jurisdictional issues will limit success. It’s no secret that companies including Apple, Google and Amazon, seem to pay less than their fair share of tax in Australia. Despite booking huge revenues from sales to Australian customers they are able to reduce their profits in this country by shifting profits to… – Continue reading

Shome, Senapaty, Pai and Bala set up tax think-tank

BENGALURU: Parthasarathi Shome, who is chairman of the Tax Administration Reforms Commission (TARC) of the Union finance ministry, together with and former Wipro CFO Suresh Senapaty, has formed a taxation think-tank that will be based in Bengaluru.  Called International Tax Research Foundation (ITRF), the think-tank will study and understand the… – Continue reading

HMRC Welcomes Three New Anti-Avoidance Victories

The UK’s Upper Tribunal has ruled in HM Revenue and Customs’s (HMRC’s) favor in three tax avoidance cases. The Department said that the judgments protected over GBP260m (USD385m) in tax. All three rulings upheld earlier First-Tier Tribunal judgments in HMRC’s favor. In one case, the Upper Tribunal dismissed an appeal… – Continue reading

Africa: Weak Tax Systems, Evasion Behind 60 Percent of Global Illicit Money Transfers – Report

Governments in resource-rich African countries must effectively negotiate the terms of operational contracts with mining companies and their affiliates if they are to avoid revenue losses that reduce their capacity to finance development, the African Civil Society Circle has said. The Circle is a coalition of nine civil society groups… – Continue reading

Vietnam – FATCA reporting guidance

April 2: Guidance from the State Bank of Vietnam provides financial institutions and branches an automatic 90-day extension of time in which to file their FATCA reporting forms. Therefore, financial institutions have until 30 June 2015 to file their FATCA reports to the U.S. tax agency (IRS). KPMG observation Pending… – Continue reading

Important lift for Hong Kong’s air finance hub ambitions

An agreement to lower the mainland withholding tax for aircraft and ship leasing is a crucial first step towards realising the Hong Kong government’s ambition of making the city an international centre for financing a global aviation industry that will need US$4.6 trillion worth of planes in the next two… – Continue reading

China ‘Through-Train’ Ends Double Taxation For Equity Investors

The Shanghai-Hong Kong Stock Exchange Connected is working out its kinks and investors are taking notice. Hong Kong and Beijing signed a tax treaty on Thursday that ends double taxation for equity traders, which was one of the sticking points for local brokers hoping to buy into China’s massive mainland… – Continue reading

Tax Authority to impose VAT on foreign Internet cos

A new circular says multinational corporations like Google and Facebook will pay taxes on online business with Israelis. Foreign Internet companies and another other foreign corporation with significant business in Israel must register with the VAT authorities as authorized dealers, and their transactions are liable to VAT. Under certain conditions,… – Continue reading