In prior advisories, we have discussed the new withholding tax law commonly known as “FATCA” (standing for “Foreign Account Tax Compliance Act”). (See “FATCA’s July 1 Effective Date Has Arrived; Last-Minute Guidance Has Been Issued” and “Last Substantial Package of FATCA Regulations Released; Deadlines Approaching”.) To help implement FATCA, the… – Continue reading
Among 175 countries included in the Corruption Perceptions Index, Myanmar is ranked the 156th – being on par with Cambodia. According to Transparency International, which released the index earlier this month, both countries scored 21. Among Asia Pacific nations, Myanmar is the third most corrupt nation. The 2014 ranking showed… – Continue reading
The surge in U.S. companies avoiding taxes by taking a foreign address has been condemned by President Barack Obama and stirred a policy debate in Congress. What’s often overlooked is that these “inversions” are typically a final step in a hopscotch of multinational tax dodging. Many companies invert after years… – Continue reading
A collection of valid points of view 1.The Island Editorial says 2. Further Analysis by Nalliah Thayabharan 3 More observations by Christie 4. Some more observations by Nimal 5. A Possible Solution by NeelaMahaYoda The Island Editorial says; “Opposition presidential candidate Maithripala Sirisena claims that the government leaders’ corrupt deals… – Continue reading
Law360, New York (December 15, 2014, 5:52 PM ET) — Coming guidance from the Organization for Economic Cooperation and Development’s base erosion and profit shifting project on the implementation of the country-by-country reporting of financial information for transfer-pricing purposes will seek to make those reports as broadly accessible to governments… – Continue reading
Dec. 15— The Internal Revenue Service filed a petition in U.S. district court to enforce a summons against Microsoft Corp. to produce “books, records, papers and other data” related to the pricing of intangibles under two cost-sharing arrangements (United States v. Microsoft Corp., W.D. Wash., No. 2:14-mc-00117, petition filed 12/11/14)…. – Continue reading
The government’s plans to implement a Diverted Profits Tax (DPT) have been questioned by the Association of Chartered Certified Accountants (ACCA). Chas Roy-Chowdhury, head of taxation at the body, said nobody wants profits that should be subject to UK tax “escape the net”. As a result, he believes it is… – Continue reading
Background On 15 December, 2014, the OECD hosted a webcast to update the global tax community on progress under the Base Erosion and Profit Shifting (“BEPS”) Plan. This year, the OECD produced 10 different reports (“BEPS Reports”) covering several actions specific to transfer pricing. This latest OECD webcast summarised efforts… – Continue reading
December 15: The IRS has posted the final version of Form 8938, Statement of Specified Foreign Financial Assets (Rev. December 2014) for 2014, on the IRS website. Form 8938 is to be used to report specified foreign financial assets if the total value of all the specified foreign financial assets… – Continue reading
Given the publicity surrounding the practices of multinationals in structuring their affairs to minimise their tax liabilities, it is not completely surprising that the UK Government has chosen to act by introducing a new tax, called the Diverted Profits Tax (“DPT”), which applies at the rate of 25% (rather than… – Continue reading
They never really lived in U.S., but still have to pay taxes HONG KONG (CNNMoney) —He left America at the age of seven, has never earned a penny there, but might owe the U.S. government $6,000 in taxes. Meet Elad Shahar, who was born in 1969 to Israeli parents in… – Continue reading
Some of the best tax minds in the country agree on one thing: Corporate tax reform will be a very, very heavy lift. Sure, the White House and top lawmakers who will be in charge of writing tax law next year have signaled their openness to the idea. And, yes,… – Continue reading
Rome (dpa) – The head of Italy‘s tax office, Rossella Orlandi, on Monday criticized automaker Fiat‘s decision to move its tax residence to Britain after completing a merger with US peer Chrysler. “I would … like to stress that we need some sense of national pride. In Germany tax rates… – Continue reading
Former PricewaterhouseCoopers auditor charged with theft and violating trade secrets in wake of LuxLeaks scandal speaks out A 28-year-old former PricewaterhouseCoopers auditor charged with theft and violating trade secrets in Luxembourg in the wake of the LuxLeaks tax avoidance scandal has revealed his identity and claimed he acted out of… – Continue reading
Illicit Flows from Developing & Emerging Countries Growing at 9.4% per Year US$6.6 Trillion Stolen from Developing World from 2003-2012; Trade Misinvoicing Responsible for 77.8% of Illicit Outflows China, Russia, Mexico, India, Malaysia—in Declining Order—Are Biggest Exporters of Illicit Capital over Decade; Sub-Saharan Africa Still Suffers Biggest Illicit Outflows as… – Continue reading
A bill filed in the U.S. House of Representatives proposes to reform the tax code and attract new money for transportation and other infrastructure. The bill filed by U.S. Rep. John Delaney, D-Md., would create incentives for U.S. corporations to bring back profits stored in offshore accounts and invest it… – Continue reading
At its Fall Meeting in Nashville, Tennessee on December 11-12, the MTC’s Executive Committee voted to formally contact states to solidify whether there is sufficient financial commitment to fund any potential MTC transfer pricing program. The MTC also formally announced that Iowa, Pennsylvania and Rhode Island will join the MTC… – Continue reading
1. The traditional attitude to tax avoidance is encapsulated in the judgment of Lord Tomlin in the English case of IRC v Duke of Westminster (1936): “Every man is entitled if he can to arrange his affairs so that the tax attaching under the appropriate Acts is less than it… – Continue reading
Gains derived from the sale of Mexican public debt instruments listed abroad between two foreign tax residents will soon be exempt from Mexican tax. Currently, for Mexican income tax purposes, any gains derived from the transfer of publicly-traded bonds, securities and other credit instruments are treated as interest. If the… – Continue reading
The wise thing is to forget the past, bring reforms to prevent generation of black money Considering other man’s point of view is Decency — George Orwell This quality seems to be in short supply in India although it is the most needed even to understand any black money retrieval…. – Continue reading
IN TAX, the latest global buzzword is “BEPS” or base erosion and profit shifting. BEPS refers to the practice of multinational corporations (MNCs) of shifting profits from high tax jurisdictions to low tax jurisdictions as a tax mitigation strategy. In February 2013, the Organization for Economic Co-operation and Development (OECD)… – Continue reading
A secret deal with the Swiss government negotiated by media group Publishing and Broadcasting Ltd when James Packer was chief executive set a tax rate of less than 2.15 per cent on PBL’s intra-company loans. “We do have good news for you!” Ernst & Young Swiss partner Markus Huber wrote… – Continue reading
Around the world, countries are desperately seeking ways to stop multinational companies from earning profits within their borders without paying taxes on them, while stashing trillions in tax havens like the Cayman Islands. The British government, after a search, says it knows how to tax the profits Google earns in… – Continue reading
After multiple revisions of a controversial law, the government is adamant that its citizenship-by-investment programme only provides Maltese nationality to people who establish a genuine link to the country. But there may be hundreds of thousands of tourists in any given year who establish stronger links to Malta than many… – Continue reading
SINGAPORE, Dec 15 (IFR) -China Construction Bank Corporation said its board had approved a proposal to sell up to Rmb80bn (US$12.9bn) in preference shares. It will sell up to Rmb60bn onshore and up to Rmb20bn offshore. Chinese banks have been selling preference shares to raise Additional Tier 1 capital, with… – Continue reading
Financial institutions around the world including those in Asia are struggling to stay compliant with local privacy regulations that restrict the sharing of client data, whilst at the same time trying to meet the demands of costly FATCA reporting requirements. FATCA, the Foreign Account Tax Compliance Act, which came into… – Continue reading
The Federal Board of Revenue (FBR) is suffering massive revenue loss of Rs 361 billion per annum on account of estimated tax expenditure in direct taxes, ie, equivalent to 1.6 percent of the Gross Domestic Product (GDP) as a result of exemptions and concessions to various sectors. Former Finance Minister… – Continue reading
Tax evasion needs to be made a serious ‘criminal offence’ to force foreign countries to reveal names and account details of Indians stashing illicit wealth abroad, the Special Investigation Team on black money has said. ET SPECIAL: Save precious time tracking your investments NEW DELHI: Tax evasion needs to be… – Continue reading
NEW DELHI: A major reshuffle has been effected in the CBDT, with the board’s Chairperson Anita Kapur deciding to assume exclusive charge of Income-Tax department investigations in order to personally spearhead ongoing probes into cases of tax evasion and blackmoney. The charge of I-T investigations, usually, is handled by a… – Continue reading
Dubai: Hong Kong and the UAE will soon start negotiations to sign an investor protection agreement on a bi-lateral basis, John C Tsang, Financial Secretary of Hong Kong told Gulf News during his visit to the UAE. “The agreement will create a lot more comfort for people who are investing… – Continue reading
On Dec. 12, 2014, Standard & Poor’s Ratings Services revised its outlook on the Kingdom of Bahrain to negative from stable and affirmed its ‘BBB/A-2’ long- and short-term foreign and local currency sovereign credit ratings. “At the same time, we revised our outlook on the Central Bank of Bahrain to… – Continue reading
Just how the US Foreign Account Tax Compliance Act (FATCA) is impacting on the lives of Americans in sometimes unintended is illustrated in the tax troubles of the Mayor of London. Boris Johnson, a former British MP, has dual British and US nationality. He was born in New York but… – Continue reading
Three men accused of running a VAT scam; face 10 years in jail Prague, Dec 12 (ČTK) — The Czech Police have accused three men over tax evasion worth 261 million Kč caused by fictitious exports of tools and design services to the US, anti-corruption police spokesman Jaroslav Ibehej told… – Continue reading
The Income Tax Department has informed the Special Investigation Team (SIT) on Black Money that prosecution proceedings for non-furnishing of account details by Indians stashing black money abroad are in progress in 27 cases (under Section 276 D of the I-T Act) and has even filed a case in court… – Continue reading
Russian Prime Minister Dmitry Medvedev stated that Moscow does not intend to “physically drag money” to Russia in the framework of amnesty for capital returning to country suggested by Russian President Vladimir Putin. MOSCOW, December 13 (Sputnik) — Moscow does not intend to “physically drag money” to Russia in the… – Continue reading
As multinationals are forced to reveal more about themselves, where should the limits of transparency lie? HOWARD SCHULTZ, the head of Starbucks, said last year that “the currency of leadership is transparency.” If so, bosses should be feeling ever more qualified to command their troops. Business is being forced to… – Continue reading
The suspected leaker of documents that revealed confidential tax avoidance deals between Luxembourg and hundreds of multinational companies has been charged with theft, money-laundering and exposing trade secrets, prosecutors said. The suspect’s identity has not been revealed, but at Luxemburger Wort we have identified that he is a French former… – Continue reading
Fiji is looking at reviewing its existing taxation agreements with other countries in the coming months. Fiji Revenue and Customs Authority chief executive, Jitoko Tikolevu, said these reviews are long overdue. As a consequence, negotiations for the review of Fiji’s Double Tax Agreement (DTA) with Malaysia was completed this week…. – Continue reading
RBI says it has no information on any offshore accounts, allegedly held by three industrialists as per list ‘released’ by Washington NGO; This list doesn’t mention any Swiss bank account PANJIM: There is no evidence in public domain of any of the three industrialists named by Goa Foundation Director Claude… – Continue reading
When the Chesapeake Bay Foundation, the Johns Hopkins University and other Maryland nonprofits want to maximize the money they can spend in pursuit of their missions, they do what many wealthy individuals and businesses do. They open investment accounts overseas. Many of Maryland’s wealthiest nonprofits — including the University of… – Continue reading
MotoGP champion Marc Marquez hit hard by criticism of a planned move to Andorra, will continue to pay tax in Spain. MotoGP champion Marc Marquez gave an emotional response to the criticism he has received within Spain over a reported move to Andorra. Speaking during Friday’s preview for the Superprestigio… – Continue reading
Last week’s Autumn Statement was another step in the right direction for the British economy. The economic news it contained continues to warrant cautious optimism. Growth for this year has been revised up to 3 per cent, making us the fastest growing major advanced economy. Unemployment is predicted to fall… – Continue reading
MONTREAL – The problem is not that Bombardier Inc. played a complex shell game since at least 2010 by refinancing and redirecting US$500 million of its financing activities to Luxembourg, a notorious tax haven. It’s that it does so legally — and is hurting its home country despite being one… – Continue reading
Rep. John Delaney (D-Md.) introduced a new plan Friday to pay for highway improvements through fresh revenues from offshore income. Under the measure, offshore corporate income would be taxed at 8.75 percent, allowing multinationals to bring cash back to the U.S. far cheaper than at the top corporate rate of… – Continue reading
All those Dutch sandwiches, double Irishes and Luxembourg, uh, lunchboxes that US multinational companies use to defer taxes and shift profits abroad are expected to be re-empowered today when the Senate votes to enact a one-year tax extension package. Included in the package is a renewal of two breaks, one… – Continue reading
On 9 December 2014, the Government of Singapore and the Government of the United States signed an intergovernmental agreement (“IGA“) to facilitate the implementation of the Foreign Account Tax Compliance Act (“FATCA“) in Singapore. The IGA is based on the United States Department of the Treasury’s Model 1 IGA and… – Continue reading
There’s big news from across the pond. The U.K. government’s Autumn Statement (formerly known as the pre-Budget report), released December 3, promises to change how multinational corporations will be taxed – and offers a cautionary tale for would-be U.S. tax reformers. Britain will introduce a “diverted profits” tax, targeting corporations… – Continue reading
This is a United World interview for USA Today for a report on Antigua and Barbuda. Brian Stuart-Young, CEO of Global Bank of Commerce and Non-resident Ambassador to China, spoke about opportunities for American investors in the energy sector, Antigua’s robust framework for financial services, and the potential for the… – Continue reading
HM Revenue & Customs’ (HMRC) plan to make undeclared taxable offshore income a criminal offence has suffered a blow as it has been omitted from draft legislation. The draft Financial Bill, published earlier this week, extended the scope of civil penalties for tax evasion but there was no reference to… – Continue reading
Responding to another leak, the Luxembourg Finance Ministry has said that the advance tax rulings issued to multinationals by the country’s tax authority are not, and never have been, secret. The Ministry issued a statement on December 10 acknowledging the publication by the International Consortium of Investigative Journalists (ICIJ) of… – Continue reading
