Mark Davies is not happy that accidents are going to cost you as much as intentions Recently, the government issued a consultation document on new legislation to extend HM Revenue & Customs’ powers of retribution for undeclared income and gains hidden offshore. It believes that offshore tax evasion is difficult… – Continue reading
21/10/14-Tax administrations will play a central role as governments move to implement the measures they have agreed to counter offshore evasion and combat tax avoidance by multinational enterprises. Global initiatives like the OECD/G20 Base Erosion and Profit Shifting (BEPS) Project and the move toward automatic exchange of financial account account… – Continue reading
Estonia will issue identity cards allowing access to its digital services to people residing outside the Baltic nation as it seeks to boost foreign investment. Lawmakers in the capital Tallinn voted unanimously with no abstentions to let foreigners seek e-residence status to be able to set up a company in… – Continue reading
Samuel Wyly, the U.S. businessman who may have to forfeit as much as $400 million after being found liable for using offshore trusts to hide stock holdings and make illegal trades, filed for bankruptcy. Wyly, 80, listed assets and debt of $100 million to $500 million each in a Chapter… – Continue reading
As of July 1, 2014, the Internal Revenue Service (IRS) has implemented several changes to the streamlined filing procedures for offshore compliance, as well as the Offshore Voluntary Disclosure Program (OVDP). These programs provide taxpayers with offshore assets an avenue to bring their tax obligations into compliance. The expanded programs… – Continue reading
Reports from Vanuatu say an entertainment company with interests in China is to offer a new style of gambling to Vanuatu. The Daily Post Newspaper reports Amax International Holdings plans to offer live-dealer online gambling to high-rollers in the country. Amax is an investment holding company engaged in gambling and… – Continue reading
Internet giant plays down speculation it is considering closing Bermudan arm Google has played down speculation in France that it is considering shutting its Bermudan arm and boosting its operations in Dublin, following the closure of the Double Irish tax loophole in last week’s budget. Le Monde yesterday reported that… – Continue reading
There may some benefits to the closed-down loopholes Unbearable pressure was exerted on this State by our neighbours in Europe to take action unilaterally to close down corporate tax avoidance loopholes such as the Double Irish, upon which time was called in last week’s budget. The pressure and the Irish… – Continue reading
There is a common misunderstanding in the charity world that tax avoidance, and its ugly sister – tax abuse, cannot be regarded as applying to charities except where charities are ‘hijacked’ to line the pockets of wealthy ostensible donors. But that is simply not the case. A charity which seeks… – Continue reading
As Indian tax authorities have been slapping foreign firms with billions of dollars in unexpected tax bills, hundreds of global companies are now negotiating with the taxman here to clarify ahead of time what they will owe in the future, hoping to avoid surprises. In the past five years there… – Continue reading
The U.S. government’s move to hamper tax-inversion deals is good for the drug industry because it forces companies to focus on intrinsic business reasons for transactions, Actelion Ltd. Chief Executive Officer Jean-Paul Clozel said. Since the U.S. Treasury said last month that it would tighten tax rules, three of eight… – Continue reading
In determining the optimum gateway for investing into India, reliance on industry data may be the most prudent opening gambit. Data released by India’s Department of Industrial Policy & Promotion peg Mauritius and Singapore as the top two destinations through which foreign direct investment and private equity capital is routed… – Continue reading
Senate Finance Committee Chairman Ron Wyden has indicated that, as companies appear to be reconsidering inversions following the administrative measures put forward by the Treasury Department last month, he is focused on reforming the US tax code, rather than pressing for immediate anti-inversion legislation. “While it looks like the rush… – Continue reading
Background The Foreign Account Tax Compliance Act, commonly known as FATCA, was signed into law on March 18, 2010. FATCA generally requires U.S. withholding agents to withhold tax at a 30 percent rate on certain U.S. payments to a foreign financial institution (“FFI”) unless the FFI has entered into an… – Continue reading
NEW DELHI: Finance Minister Arun Jaitley said the government has never said that it will not reveal the names of Indians who have undeclared income parked in foreign bank accounts. “The Congress will be embarrassed by the names when we reveal them in court,” said Mr Jaitley in an exclusive… – Continue reading
AbbVie Inc. (ABBV) and Shire Plc agreed to terminate what would have been the biggest U.S. tax inversion after AbbVie pulled its support for the deal in the wake of proposed changes to U.S. rules governing such transactions. AbbVie, based in North Chicago, Illinois, planned to buy Shire for an… – Continue reading
Echegaray says account holders can take part in country’s fiscal amnesty If Argentines who hold 4,040 undeclared bank accounts in Switzerland don’t normalize their fiscal status and pay their debts, the AFIP tax bureau will file a complaint before the Office of Economic Crime and Money-Laundering (PROCELAC) requesting it investigates… – Continue reading
Lump sum taxation, the tailor-made measure tax regime designed to attract wealthy foreigners to Switzerland, is facing a crucial test as voters head to the polls on November 30 to decide whether or not to abolish the system for good. Proponents of the initiative say lump sum taxation is unfair… – Continue reading
Bombay High Court holds that shares issued at a premium by a resident entity to a non-resident entity is a capital account transaction and does not give rise to any income; Income arising from an International Transaction between AEs must satisfy the test of ‘income; as provided under the ITA… – Continue reading
Foreign structures are tempting targets for governments, says Vanessa Houlder. When governments around the world embarked on a drive to plug tax loopholes in 2012, the urgency of the move was underpinned by rising tensions over austerity and inequality. Widespread public outrage over alleged tax-dodging by wealthy individuals and multinationals… – Continue reading
A Residence Programme (“TRP Rules”) has been introduced with effect from 1 July 2013 for individuals who are nationals of the EU, EEA or Switzerland (but not Maltese nationals) in terms of Legal Notice 270 of 2014 and Articles 56(23) and 96 of the (Malta) Income Tax Act, Chapter 123… – Continue reading
DALLAS (CN) – Former Texas billionaire Sam Wyly filed for bankruptcy protection after a federal jury ordered him to pay as much as $400 million for using offshore trusts to hide stock trades. A noted philanthropist and contributor to Republican causes, Wyly, 77, of Dallas, made his fortune… – Continue reading
If you are a US taxpayer with overseas bank accounts or investments, you need to take immediate steps to show you are reporting your overseas earnings to avoid tax penalties under Foreign Account Tax Compliance Act (FATCA). Now FATCA is in full swing with foreign financial institutions filing reports on… – Continue reading
Climate Change Law Practice Group Blog, Environmental, Energy and Resources Law The BC Government tabled Bill 6, the Liquefied Natural Gas Income Tax Act, on October 2, 2014. Bill 6 sets out the features of the new LNG tax regime. The LNG taxation proposals have been the subject of great… – Continue reading
Unprecedented international collaboration is needed to overcome a single-, isolated-country view to tackling base erosion and profit shifting (BEPS) issues, Andrew Mills, Second Commissioner of Australian Taxation Office (ATO) for Law Design and Practice, has said. In a speech delivered at the Second Annual Tax Forum organized by the Tax… – Continue reading
The Organization for Economic Cooperation and Development’s (OECD) plan for base erosion and profit shifting (BEPS) is already affecting corporations, according to speakers participating in a Captive Insurance Companies Association (CICA) transfer pricing webinar. Polling results during the webinar revealed attendees’ opinions were in line with tax industry surveys indicating… – Continue reading
The tide of tax inversions has started to recede, taking with it a substitute for real growth at some of our biggest companies. AbbVie Inc. just decided to bail out of an acquisition that would have moved its headquarters overseas where corporate tax rates are lower than U.S. rates. AbbVie… – Continue reading
Privacy Commissioner welcomes the news. The office of NSW Attorney-General Brad Hazzard has confirmed the government’s intentions to update the state’s privacy legislation to make it clear where agencies and healthcare providers stand when it comes to storing data offshore, particularly as part of cloud computing arrangements. The NSW Privacy… – Continue reading
Hang Seng Indexes Company and Markit have launched the Hang Seng Markit iBoxx Offshore RMB Bond Index family (HSM iBoxx). The bond index series will track the performance of offshore renminbi (RMB) sovereign and corporate debt using an enhanced methodology for the treatment of unrated bonds alongside comprehensive breakdowns by… – Continue reading
Dividend represents a share of the company’s post-tax profit that is divided among its shareholders. In other words, once corporate tax has been paid on profit, the remaining earnings are distributed amongst shareholders as dividend. So far, so good. Then, this dividend is characterised as income in the hands of… – Continue reading
European Union finance ministers have reached a breakthrough agreement that will make it more difficult for tax cheats to hide their money. The new legislation, which had been blocked for years by countries with a reputation as tax havens, was approved last week after Luxembourg and Austria agreed to lift… – Continue reading
Grant Thornton calls on government to show greater support for mid-sized companies as they drive UK growth GRANT THORNTON has lent its weight to calls for the government to back high-growth, mid-sized firms in the Autumn Statement on 3 December. In a 20-page document submitted to the chancellor, the top-ten… – Continue reading
On July 15th 2014, the OECD published its 2014 update of the Model Tax Convention (“2014 OECD Update”). This update is the outcome of the work accomplished between 2010 and the end of 2013. It does not however take into account the OECD conclusions of the “Action Plan on Base… – Continue reading
The revenue implications for South Africa of ‘base erosion and profit shifting’ by corporate taxpayers are firmly in the crosshairs of the Davis Tax Committee (DTC) and Judge Dennis Davis hinted on Monday that recommendations were being considered to “detect and deter” tax-avoiding financial flows. Speaking at a G20 study… – Continue reading
Swiss authorities have confirmed that, if asked, they will assist India in efforts to confirm the genuineness of bank documents and will swiftly provide information on requests relating to non-banking dossiers. The commitment was made in a joint statement following a meeting between the Swiss State Secretary, Jacques de Watteville,… – Continue reading
There has been a lot of press coverage recently around the pricing and tax arrangements of multinationals, in particular Apple, Starbucks and Amazon. In this respect, the EU is undertaking in-depth investigates into these companies to establish whether the companies’ tax arrangements have breached EU State Aid rules. These cases… – Continue reading
Non-EU investment firms’ access to EU investors under MiFID 2 The recast Markets in Financial Instruments Directive (MiFID 2), along with its accompanying Regulation (MiFIR), were published in the Official Journal of the EU in June. The new legislation is currently expected to come into effect in January 2017. The… – Continue reading
Representation of foreign individuals who wish to purchase US residential property should include careful attention to the manner in which the income and gain from the property will be taxed in addition to the other aspects of ownership. In addition, it is important to be aware of the manner in… – Continue reading
(Reuters) – International banking activity expanded for a second straight quarter between April and June with banks lending more to emerging markets, particularly China, and to investment funds in offshore centers such as the Cayman Islands, data showed on Monday. Foreign lending to offshore centers rose to $2.269 trillion in… – Continue reading
Devolving further tax powers to Scotland would be “more complex than many might anticipate”, Scotland’s accountancy body has said. The Institute of Chartered Accountants of Scotland (ICAS) highlighted factors such as tax competition within the UK and the need to reduce tax avoidance. A commission is considering proposals for more… – Continue reading
In recent years, the United States has increased initiatives to counter tax evasion committed by U.S. persons who are not reporting and paying U.S. income tax on earnings derived from foreign financial assets. The Foreign Account Tax Compliance Act (“FATCA”) represents the latest major initiative in this regard, having been… – Continue reading
Obama finds foreign a tax rate that is both fair and efficient What is the maximum income-tax rate that anyone should be expected to pay? Some questions are never settled, in part because people often ignore the theoretical and empirical evidence, and history that can help answer the question. The… – Continue reading
The Irish government decided last week to get rid of a tax loophole that has helped big multinational companies like Apple and Google avoid paying billions in taxes to any government at all. But hold the champagne: Ireland could well replace one problematic tax policy with another, leaving aggressive tax… – Continue reading
Nearly 105,000 financial institutions are listed on the US Internal Revenue Service (IRS) database of Foreign Account Tax Compliance Act (FATCA) organisations complying with the tax reporting rules for US citizens. The latest list was published on October 1, 2014 by the IRS and shows 104,344 financial organisations have signed… – Continue reading
These crimes hinder the development of societies, prevent strengthening the legitimacy of democracy SANTIAGO — Corruption and tax evasion are flagrant violations of human rights in Latin America, where they contribute to inequality and injustice in the countries of the region, according to studies and experts consulted by IPS. “Tax… – Continue reading
A number of American corporations are making news, and not in a good way. They have announced mergers with foreign companies so they can avoid paying U.S. taxes. They are seeking what is called a “tax inversion” and it allows an American corporation to merge with a foreign corporation, move… – Continue reading
New Delhi: Communist Party of India (Marxist) leader Brinda Karat on Saturday criticized the Prime Minister Narendra Modi-led NDA Government at the Centre for not disclosing the names of persons having money stashed away in safe havens abroad, and alleged that it exposed the utter hypocrisy and double standards of… – Continue reading
The tax gap has increased to £34bn in the past year according to the latest figure from HM Revenue and Customs (HMRC), but Baker Tilly’s George Bull has said that HMRC are nonetheless “winning the battle” against tax avoidance. The tax gap in the UK jumped from 6.6% in 2011-12… – Continue reading
Senate Finance Chairman Ron Wyden (D-Ore.) said Friday that he hopes to build on the pharmaceutical company AbbVie’s move away from a tax inversion. AbbVie’s board advised shareholders to vote against the proposed merger with the Irish competitor Shire, which Wyden said showed the company saw “the strategic business value… – Continue reading
Some 19 British firms are at the center of an investigation into in a mammoth global money-laundering operation. The scheme was allegedly contrived to make $20bn (£12.5bn) worth of ill-gotten gains appear legitimate. The illicit funds are thought to have originated from criminal gangs and corrupt officials across the globe,… – Continue reading
