Category: Activity

Shareholders Approve Medtronic-Covidien Deal

Medtronic Inc. took one step closer to becoming an Irish company when shareholders voted in favor of acquiring Dublin-based medical supply maker Covidien Ltd. Covidien shareholders similarly voted on the deal early today and also approved it. The acquisition now goes before the Irish High Court, which may take several… – Continue reading

Will a Sponge Tax Soak Up BEPS Concerns?

As the Organisation for Economic Co-operation and Development (OECD) passes the halfway point in its joint project with the G20 to address base erosion and profit shifting (BEPS) concerns, it is worth pausing to examine what the consequences of some of the proposed changes may be. Much of the focus… – Continue reading

Australia: FATCA in Australia: Q&A

Holley Nethercote commercial & financial services lawyers David Court, a partner at Holley Nethercote Commercial and Financial Services Lawyers was recently interviewed by an international publication regarding the implementation of FATCA in Australia. Below are some of David’s thoughts – How have you approached FATCA? What’s your biggest challenge? What… – Continue reading

U.S. Officials in Hong Kong Gathering FATCA Non-Compliance Data

HSBC, Sovereign, FedEx, DHL & UPS all expecting summons from IRS American IRS officials are said to be carrying out investigative work concerning FATCA transgressions from the American Consulate in Hong Kong, according to a report issued in the South China Morning Post. The article quoted Travis Benjamin, a Partner… – Continue reading

The Death Of Hidden Offshore Accounts

The future for offshore tax planning, also known as “aggressive tax planning” is likely to be limited to if not curtailed by the global exchange of information agreement signed in October, 2014 by 51 countries and growing. The link below is to a video summary of the predicted consequences of… – Continue reading

China’s crackdown on tax evasion to impact cross-border transactions

Multinationals told to be more cautious about intra-group transactions as Beijing imposes stiff measures against avoidance and evasion Multinationals have been advised to take notice of Beijing’s New Year resolution to crack down on tax avoidance and evasion, especially after the announcement of the general anti-avoidance rule (GAAR) and new… – Continue reading

HSBC, Hong Kong Under Scanner As US Steps Up Investigation Of American Tax Frauds

HSBC Holdings and the city of Hong Kong, which were last month linked to an international tax evasion network, are currently under scrutiny as part of efforts by U.S. authorities to hunt down American tax evaders, the South China Morning Post (SCMP) reported Monday, citing lawyers. Official with the U.S…. – Continue reading

HSBC and Hong Kong Targeted By IRS Looking For American Tax Evaders

U.S. Internal Revenue Service officials are stepping up an international tax evasion investigation into HSBC Holdings and the city of Hong Kong in an effort to crack down on American tax evaders, the South China Morning Post reported. IRS officials are now stationed in overseas Asian jurisdictions, including at the… – Continue reading

BEPS action plan 1: The digital economy

IN A PREVIOUS column (http://www.bworldonline.com/content.php?section=Economy&title=the-oecd-action-plan-on-base-erosion-and-profit-shifting&id=99561), we wrote about the general framework of the Base Erosion and Profit Shifting (BEPS) initiative, why addressing BEPS is a key priority for many governments across the globe, and the 15-point BEPS Action Plan drafted by the Organization for Economic Co-operation and Development (OECD). The… – Continue reading

Collins declines to comment on Ansbacher letter to PAC

FORMER Minister for Justice Gerry Collins has declined to comment on correspondence from his solicitors accusing the Public Accounts Committee of “exceeding its jurisdiction” in any further pursuit of allegations he had an Ansbacher offshore account. Mr Collins, as well as another retired Limerick minister, Des O’Malley, earlier this month… – Continue reading

GDR route under scanner for routing black money

New Delhi: As a probe continues into misuse of stock markets for routing black money and tax evasion, the regulatory and other agencies suspect that GDR route is being used for bringing back suspected illicit funds stashed abroad. The modus-operandi, in cases currently under scanner, involves an intricate web of… – Continue reading

Tax evasion by super rich hurts every Australian

We will probably never know their names, but one thing we do know – one in 20 of the richest people in Australia tried to evade paying their fair share of tax in recent years. By what authority do we know this? By none other than the Australian Taxation Office…. – Continue reading

More Than 1,000 Indian Companies, Individuals Under Radar For Tax Evasion

MUMBAI – At least 1,000 individuals and companies have come under Securities and Exchange  Board of India’s (Sebi) scanner for allegedly using stock markets to evade taxes and launder money through companies mostly existing on paper. Sebi is focussing on securities market related violations by these individuals and companies, who… – Continue reading

There is at least $21tn stashed away in tax havens

The Price of Offshore Revisited was written by James Henry, a former chief economist at the consultancy McKinsey, for the Tax Justice Network. Tax expert and UK government adviser John Whiting said he was sceptical that the amount hidden was so large. Mr Whiting, tax policy director at the Chartered… – Continue reading

A taxing tale of two peak bodies

Four days out from Christmas, Blind Citizens Australia (BCA), Deaf Australia, Homelessness Australia and Down Syndrome Australia learned they were to be subject to federal government funding cuts. New Social Services Minister Scott Morrison assured concerned parties that frontline services to the disabled would not be cut, just grants to… – Continue reading

Digital tax increase to take effect in Europe

Europe’s tax showdown could be headed straight to people’s wallets. With the new year, a change in fiscal rules in the European Union is increasing the tax on many purchases of digital content like e-books and smartphone applications. Under the new rules, first approved in 2008, the tax rate on… – Continue reading

Minnesota investment board withholds support of Medtronic-Covidien deal

Critics said the deal would allow Medtronic avoid taxes while providing preferential treatment to executives. The promise of 1,000 new Minnesota jobs was not enough to convince the state’s pension board to support a $48 billion corporate transaction that will move Medtronic’s legal headquarters overseas. A four-member subcommittee of the… – Continue reading

Tax disputes: FinMin’s new mechanism for resolution should cheer foreign firms

NEW DELHI, JANUARY 2:  The dispute resolution mechanism for matters relating to international tax and transfer pricing has been streamlined. The Finance Ministry has put in place a new framework that seeks to bring much-needed rigour and neutrality to dispute resolution on international tax issues. The move should encourage multinationals… – Continue reading

Don’t run before you can walk – Russian deoffshorisation uncertainties

The new deoffshorisation legislation that passed with lightning speed through Russia’s Parliament and then hastingly signed by President Putin in the time span of a week and a half, comes into force on January 1, 2015. The new deoffshorisation legislation that passed with lightning speed through Russia’s Parliament and then… – Continue reading

The Outlook for Taxes in 2015

The new year could bring important changes to the tax landscape. Here are several issues that will affect how much taxpayers owe for 2015 and beyond: Federal tax policy There is serious talk of overhauling the federal tax code. “There appears to be a consensus” on making changes, says Stephen… – Continue reading

LuxLeaks: An opportunity?

BRUSSELS – As political honeymoons go, it was short and ended abruptly. Just one week into his job as European Commission president, Jean-Claude Juncker was broadsided by a series of newspaper articles outlining the depth and breadth of corporate tax avoidance schemes in Luxembourg. Schemes thought up and enacted while… – Continue reading

Financial institutions rush to meet FATCA deadline

A number of financial institutions rushed to meet a registration deadline after a late-night regulatory circular on Tuesday urged them to sign up with American tax authorities. The circular had advised registration by Thursday. The institutions have to do so under America’s Foreign Account Tax Compliance Act (Fatca). It requires… – Continue reading

Taxing times

Businesses in the island’s vital financial services are gearing up for ‘substantial changes’ dealing with tax. That was one of the important messages to come out of a seminar organised by KPMG in the island. More than 200 experts attended the event which covered a series of changes in property… – Continue reading

Financial institutions rush to meet FATCA deadline

A number of financial institutions rushed to meet a registration deadline after a late-night regulatory circular on Tuesday urged them to sign-up with American tax authorities. The circular came out on 30th December, and asked institutions to register by 1st January. The institutions have to sign up under the Foreign… – Continue reading

SA must not miss out on e-commerce tax revenue, says Davis committee

SOUTH Africa’s tax authorities need to beef up the country’s tax laws and regulations to ensure it derives its rightful dues from the digital economy and e-commerce, the Davis committee says. The committee’s interim report on base erosion and profit shifting, released for public comment last week, said gaps in… – Continue reading

Tax systems and the 183 days’ rule

The conditions for becoming tax-resident and tax non-resident vary from country to country and depend on such things as length of stay, type of accommodation, location of family, and nationality. In most tax systems, presence of an individual in a country for 183 days or more in any 12-month period… – Continue reading

Zero corporation tax: the arguments for and against

Once a niche proposal, the recent public focus on corporate tax avoidance has sparked real interest in the idea of eliminating corporation tax altogether. Surprisingly, the statistics suggest that employees and other stakeholders may also benefit from this In winter 2012, hundreds of activists packed inside their local Starbucks after… – Continue reading

New FATCA requirements apply to U.S. and non-U.S. insurers and insurance brokers on January 1, 2015

Summary New FATCA requirements that apply to U.S. and non-U.S. insurance brokers and insurance companies will take effect on January 1, 2015. Those requirements impose new information gathering and reporting rules when U.S. insurance and reinsurance premiums are sent outside the U.S. Background The Foreign Account Tax Compliance Act (FATCA)1… – Continue reading

Swiss banks target Israeli tax evaders

Swiss banks are training their crosshairs on Israeli customers. Legal sources said that in the past two weeks, the large banks in Switzerland have begun sending many queries to their Israeli customers demanding confirmation either that the assets deposited with the banks were reported to the Israeli tax authorities, or… – Continue reading

Internal Revenue Service Getting Tough on Production of Evidence From Current and Former Microsoft Executives In Connection With Its Transfer Pricing Audit

In recent court filings made in various federal district courts in Washington and California, the Internal Revenue Service is seeking to enforce testimonial summonses issued to current or former Microsoft employees, including former CEO Steven A. Ballmer. The summons had been issued earlier this fall. Microsoft’s outside tax counsel responded… – Continue reading

Asia to test bond record again in 2015

[HONG KONG] Asia could set another record for international bond issues in 2015 if Chinese companies continue to borrow offshore at the same voracious pace they did this year, while bankers expect a heavy redemption schedule and larger pipelines from India and Indonesia to lift activity. Barclays is forecasting volumes… – Continue reading

HMRC prolongs Contractor Loan Settlement Opportunity until June 2015

HM Revenue and Customs (HMRC) has confirmed it has extended the lifetime of the Contractor Loan Settlement Opportunity (CLSO), a chance for contractors to own up to using an offshore tax avoidance scheme, until 30th June 2015. The settlement opportunity was originally meant to be open until January 2015. HMRC… – Continue reading

IRS Adds FATCA FAQ On In-Substance IGAs

Within its list of frequently asked questions (FAQs) on issues associated with the requirements of the Foreign Account Tax Compliance Act (FATCA), the United States Internal Revenue Service (IRS) has provided added information for foreign financial institutions (FFIs) in jurisdictions with in-substance intergovernmental agreements (IGAs). FATCA, which was enacted by… – Continue reading

Analysis of Asia’s Tax Rates, Part 2: Withholding Tax

A withholding tax is a tax that is kept back from an employee’s salary and subsequently paid directly to the government. Withholding taxes are commonly employed by countries throughout the world to help combat tax evasion. Countries in Asia typically divide withholding tax into dividends, interest and royalties payments, with… – Continue reading

Vodafone transfer pricing case: Tax dept may not lose hope

The transfer pricing department is yet to make adjustments on share issuances by Vodafone India services to Vodafone Teleservices Mauritius for assessment year 2011 and 2012. The transfer pricing department has sought clarity from the government on legal recourse in the Vodafone transfer pricing case. Sources have indicated that the… – Continue reading

South Africa urged to finalise renegotation of Mauritius tax treaty

CAPE TOWN — South Africa needs to finalise the renegotiation of its tax treaty with Mauritius as soon as possible to prevent the loss of large sums of money through “treaty shopping” the Davis tax committee has urged. The committee released its interim report on ways to prevent base erosion… – Continue reading

Vatican Bank Complies With FATCA. St. Lawrence Pray For Us!

Forbes is reporting on the Vatican Bank’s decision under pressure to comply with the FATCA requirements for reporting on American citizen accounts. In his annual Christmas messages to more than one billion Catholics, the Pope may have left out something: offshore account compliance. Maybe, but the U.S. Treasury is more… – Continue reading

News Round Up

Currently, there is a tendency among those who take an interest in international tax developments to look to the future and try to guess how the international tax landscape will look in, say, three of four years, once countries begin to implement the OECD’s base erosion and profit shifting (BEPS)… – Continue reading

London mayor’s unpaid tax bill provides food for thought

You may have heard in the news about Boris Johnson. He’s a flamboyant politician in the U.K. with an unruly mop of blonde hair. Recently, he made news by publicly saying he absolutely won’t pay his U.S. taxes. And yes, he is the mayor of London (the “real” London, where… – Continue reading