SUMMARY On February 2, 2015, the Obama Administration (the “Administration”) released the General Explanations of the Administration’s Fiscal Year 2016 Revenue Proposals (commonly known as the “Green Book”), which contains significant detail about the fiscal year 2016 revenue proposals. This memorandum discusses certain aspects of the Green Book relating to… – Continue reading
According to an estimate by the European Commission, the EU is at least 1,000 billion euros out of pocket because of tax evasion and avoidance. A major problem related to tax evasion is that in many cases it does not involve any illegal activities but is regarded as tax planning… – Continue reading
The present French Tax Update will focus on (i) the most salient features of the new double tax treaty signed by the People’s Republic of China (China) and France on November 26, 2013 (New DTT), (ii) the new double tax treaty signed by Singapore and France on January 15, 2015,… – Continue reading
Potential candidates can gain foreign experience and donations in the British capital but expatriate supporters want action on Obama’s onerous tax demands Republican donors in the UK are lobbying the presidential hopefuls visiting London in search of foreign policy credentials and wealthy corporate allies to abandon President Barack Obama’s aggressive… – Continue reading
IN LAST WEEK’S column we talked about the OECD’s BEPS Action Plan on Hybrid Mismatch Arrangements. This week’s column focuses on the OECD’s Action Plan on Harmful Tax Practices (HTP). As the world economy continues the process of globalization and technological advances, tax authorities from various jurisdictions are inevitably faced… – Continue reading
With over 7 million Americans living abroad, many have complained about the rigorous IRS enforcement of global tax reporting, the risk of draconian FBAR penalties for reporting foreign accounts, and FATCA discrimination. FATCA, America’s global tax enforcement law, applies virtually everywhere. It is easy for the IRS to find you,… – Continue reading
(Bloomberg) — President Barack Obama will propose that U.S.-based companies pay a minimum 19 percent tax on their future foreign earnings, capturing profits that are now often beyond the government’s reach. Obama will also seek a 14 percent mandatory tax on about $2 trillion in stockpiled offshore profits, said two… – Continue reading
NEW DELHI: Getting tough with investment proposals from tax heavens, FIPB has deferred 23 applications in its last three meetings apprehending “treaty abuse”. According to sources, the Department of Revenue has expressed doubt that a few foreign companies were evading tax by routing their investments through tax heaven countries with… – Continue reading
The upmarket leather goods firm employing the Prime Minister’s wife is based in a tax haven. Smythson is owned through a holding company in Luxembourg and linked to a secretive trust in the Channel Island of Guernsey, another well-known tax haven. The store in Central London’s New Bond Street, which… – Continue reading
IRS threatens 30% withholding tax on non-compliant banks Dubai: Many people, including American citizens working in the Gulf state, received recently letters from their UAE-based banks asking them for more details and papers in compliance with American laws introduced by tax service. The move comes as many citizens of the… – Continue reading
A Sunday Mirror investigation has found Apple, Facebook, Amazon, Google, Ebay and Starbucks has paid less than one per cent tax Six of the world’s biggest companies paid just 0.3 per cent of their UK earnings in corporation tax last year, a Sunday Mirror probe has found. We have examined… – Continue reading
Feb 1 (Reuters) – The Chinese government’s vow to increase tax scrutiny of foreign companies has sent firms rushing to tax advisors ahead of the implementation on Sunday of new rules designed to rein in cross-border tax avoidance. Tax professionals and business lobbies alike have welcomed the move as an… – Continue reading
Capital Gains tax and inheritance tax should be merged to prevent wealthy homeowners being taxed twice, IoD suggests Capital gains tax and inheritance tax should be merged to prevent wealthy homeowners being taxed twice, according to the Institute of Directors. Taxes raising less than £5billion a year should be merged… – Continue reading
VietNamNet Bridge –Inspectors looking for transfer-pricing cases examined 2,866 enterprises in 2014, discovering that the actual losses incurred by businesses was VND5.8 trillion lower than reported. The inspectors also attempted to collect VND1.7 trillion worth of tax arrears. The deputy general director of the General Department of Taxation (GDT), Tran… – Continue reading
Department of Finance officials expressed concern that changes to tax breaks in budget 2015 would cost at least €50 million in foregone taxes annually and reward a relatively small number of companies. On budget day last October, Minister for Finance Michael Noonan announced improved tax incentives for research and development… – Continue reading
The Government of Spain has announced that new country-by-country (CbC) reporting obligations will be effective in Spain for tax periods beginning on or after January 1, 2016. The CbC reporting obligation, which was announced on January 20, 2015, will technically apply from 2017, when tax returns for the previous year… – Continue reading
The EU won’t limit how much it seeks to claw back from companies including Apple and Amazon that are ensnared in tax probes if controversial deals with national governments are overturned. The European Commission is currently probing the tax arrangements between Apple and Ireland, alleging that a deal was struck… – Continue reading
At the US agency responsible for enforcing the Fatca tax withholding reporting law, an apparent lack of frequency in updating GIIN registrations, along with the as-yet-untested launch of its compliance service, reflect poorly on its capabilities I covered Foreign Account Tax Compliance Act (Fatca) developments in this space just two… – Continue reading
Speed read On 16 December 2014, Curaçao and the U.S. signed an intergovernmental agreement (“Curaçao-IGA”) setting out the information reporting and withholding requirements applicable to banks and other financial institutions resident in Curaçao (“FI’s”) under the Foreign Account Tax Compliance Act (“FATCA”). By virtue of the Curaçao-IGA, FI’s will be… – Continue reading
When a crowd of angry Americans threw 45 tonnes of tea into Boston Harbor in 1773, their concern was the under-enforcement of the principle of ‘no-taxation without representation’ — that governments should not impose fiscal obligations on their citizens without them having a saying on it. More than two centuries… – Continue reading
When a crowd of angry Americans threw 45 tonnes of tea into Boston Harbor in 1773, their concern was the under-enforcement of the principle of ‘no-taxation without representation’ — that governments should not impose fiscal obligations on their citizens without them having a saying on it. More than two centuries… – Continue reading
(Bloomberg) — Senators Rand Paul and Barbara Boxer are proposing a tax incentive for U.S. companies to bring home their offshore cash stockpiles and pledging to use that revenue to fund highways. The bipartisan proposal would let companies repatriate money parked overseas at a 6.5 percent tax rate, a steep… – Continue reading
The Association of Americans Resident Overseas – AARO – recently conducted a 4 month survey to see how Americans with offshore financial accounts were adapting to the mandatory electronic FBAR filing regimen. For decades, U.S. taxpayers with offshore accounts had to paper file FBAR reports each June. Now, FBARs must… – Continue reading
U.S.-based multinational corporations are using complex merger deals to avoid paying taxes on $12 billion a year in taxable foreign earnings that they repatriate back to the U.S., according to a new study. U.S. multinationals are required to pay U.S. corporate income taxes upon repatriation of foreign earnings earned in… – Continue reading
Government minister Laurence Skelly has spoken of his hopes for ‘social investing’ in the island after he was invited to a high-profile gathering in Downing Street. Social investment is finance that generates social as well as economic returns. Mr Skelly, who is in the hot seat at the Department of… – Continue reading
Yesterday, the Internal Revenue Service unveiled its latest statistics on participation in its Offshore Voluntary Disclosure Program (OVDP), an amnesty program for taxpayers with undisclosed foreign bank accounts that has existed in various forms since 2009. To date, more than 50,000 taxpayers have made voluntary disclosures regarding offshore bank accounts,… – Continue reading
Cash reserves held outside the US for tax reasons by US multinationals are “likely to fuel a big increase in M&A activity over the next year”, said Eloise Walker a tax expert at Pinsent Masons, the law firm behind Out-law.com.30 Jan 2015 Corporate Tax Corporate tax International tax M&A Advanced… – Continue reading
NEW YORK (CNNMoney) —The IRS has been cracking down on tax cheats trying to hide money in offshore accounts. But it’s still one of the top tax scams out there. U.S. tax filers who knowingly cheat on their taxes by parking their money in offshore accounts — or who naively… – Continue reading
On January 27, 2015, the Council of the European Union formally adopted a decision to add a binding anti-abuse clause to the EU Parent-Subsidiary Directive. The anti-abuse clause, which was agreed by the Economic and Financial Affairs Council on December 9, 2014, aims to prevent misuse of the Directive and… – Continue reading
The US Internal Revenue Service (IRS) has posted tax investigators to foreign embassies to lead a Foreign Account Tax Compliance Act (FATCA) crackdown on suspected tax evasion. The Asia Pacific financial centres of Hong and Singapore are two of the main targets, according to industry experts. The move follows claims… – Continue reading
Santo Domingo.- Internal Taxes Agency director Guarocuya Felix on Thursday warned that Dominican Republic must soon dismantle the barriers which limit the automatic access to information of the financial sector’s taxpayers, because despite the Arbitration Court resolution to break banking secrecy when the tax administration so requires, the information doesn’t… – Continue reading
Li Ka-shing, Hong Kong’s richest man for the past seventeen consecutive years with a reputed personal wealth of $33 billion, surprised analysts at the start of 2015 by announcing the restructuring of his vast business empire. His plans to merge all non-property assets of his two companies Cheung Kong Holdings… – Continue reading
With the Senate weighing a bipartisan effort to let companies repatriate offshore cash for five years at a 6.5% rate, Google (NASDAQ:GOOG) CFO Patrick Pichette states on the Q4 CC the passage of such a bill would change how his company spends. He adds ~60% of Google’s cash is offshore,… – Continue reading
In November 2012, a startled TV audience watched coverage of the House of Commons Select Committee questioning Google’s chief executive about why his business, with ostensibly billions of pounds in sales generated in the UK, accounted for UK corporation tax in an amount equivalent to the price of a single… – Continue reading
In November 2012, a startled TV audience watched coverage of the House of Commons Select Committee questioning Google’s chief executive about why his business, with ostensibly billions of pounds in sales generated in the UK, accounted for UK corporation tax in an amount equivalent to the price of a single… – Continue reading
The Cayman Islands – described by the Financial Times as having “a reputation for clandestine financial activity” – is the latest location for a Savills branch. The office is located in the Caribbean Plaza on Grand Cayman’s Seven Mile Beach and is the first fully branded Savills office in the… – Continue reading
Introduction The taxpayer, Seven Network Limited, has won a recent decision (22 December 2014) in the Australian Federal Court, Seven Network Limited v Federal Commissioner of Taxation (2014) FCA1411, which is significant to all broadcasters, particularly involving the delivery of live sport and other entertainment. Briefly, the key issue raised… – Continue reading
MUMBAI: In what will be widely perceived as a sentiment booster for investors, the government has asked the I-T department to apply the principle behind a tax ruling involving Vodafone Group to all similar transfer pricing cases, an official letter seen by Reuters showed. Reacting to the news, Dinesh Kanabar of KPMG India told ET Now,… – Continue reading
The Chief Secretary to the Treasury has warned Scotland could be one of the most centralised countries in the world, with too much power concentrated in Edinburgh. Danny Alexander MP was giving evidence on fiscal devolution to Holyrood’s finance committee. He argued power should be devolved to local authorities. He… – Continue reading
In a move that will likely soothe investors’ frayed nerves, the government on Wednesday decided not to appeal a Bombay High Court ruling in favour of Vodafone in a Rs. 3,200-crore tax dispute over a share transaction involving a local subsidiary. IT minister Ravi Shankar Prasad said the government wants… – Continue reading
ARLINGTON, Va., Jan. 28, 2015 /PRNewswire-USNewswire/ — Bloomberg BNA today announced that its Global Transfer Pricing Conference: Paris, held in conjunction with Baker & McKenzie and in association with the Tax Management Education Institute, will occur on March 30-31 immediately after the Organisation for Economic Co-operation and Development (OECD) Global… – Continue reading
Inter-Governmental Agreement (IGA) with United States of America (US) under Foreign Accounts Tax Compliance Act (FATCA)- Registration Please refer to circular DBR.AML.No.9644/14.07.018/2014-15 dated December 30, 2014, on the captioned subject. 2. In partial modification to the above circular, it is clarified that those RRBs which do not have more than… – Continue reading
Microsoft denies a transfer of ownership of its New Zealand business from the United States to Luxembourg is related to the tiny European state’s favourable tax policies. Luxembourg, which has a population of less than 600,000, has been accused of facilitating large-scale tax avoidance by multinationals. Microsoft New Zealand was… – Continue reading
The existence of 1MDB’s RM7 billion in the Cayman Islands and its return to Malaysia must be verified. KUALA LUMPUR: Pandan MP Rafizi Ramli urged Bank Negara Governor Zeti Akhtar Aziz, in a statement on Wednesday, to invoke the Anti Money Laundering Act and ensure that a reported RM7 billion… – Continue reading
BANDAR SERI BEGAWAN – Taiwan is keen on broadening the scope of cooperation with Brunei beyond the areas of oil, gas and organic chemicals. According to Albert Huang, representative at the Taipei Economic and Cultural Office in Brunei, the two parties can explore other trade opportunities. Taiwan is interested to… – Continue reading
MUMBAI: The Reserve Bank has exempted Regional Rural Banks with assets less than USD 175 million to register with the US Internal Revenue System under FATCA. It also said that if RRBs, taken together with related entities, do not have assets over USD 500 million, they need not register with… – Continue reading
Russian banks have canceled contracts with their US clients because of the Foreign Account Tax Compliance Act (FATCA), the law that requires foreign banks to share information on US citizen’s banking activities. If a bank does not comply, it may be subject to a fine. NOVOSIBIRSK, January 28 (Sputnik) —… – Continue reading
Almost every day brings new evidence that the era of bank secrecy for tax evaders using Swiss and “offshore” bank accounts in “tax havens” is over. Both tax authorities and banks are clamping down on unreported offshore accounts. Early in 2014, Swiss bank Credit Suisse agreed to pay fines of… – Continue reading
The IRS is harping again on the dangers of hiding money or assets in unreported offshore accounts, this time as part of its Dirty Dozen tax scams over 12 days for the 2015 tax filing season. In fact, the IRS has trumpeted the issue for over 5 years. Plainly, violations… – Continue reading
Yahoo is taking advantage of a loophole in the tax code to spin off its $40 billion stake in Chinese e-commerce giant Alibaba to shareholders without paying about $16 billion in corporate income tax. That’s how much Yahoo would pay if it sold its Alibaba shares or transferred them to… – Continue reading
