* Dublin set to change tax residency rules in Oct. 14 budget * Companies already in Ireland to be given time to adjust * Measures due to be signed off by cabinet next Tuesday By Padraic Halpin DUBLIN, Oct 10 (Reuters) – Ireland is set to announce legal changes next… – Continue reading
Introduction Action 1: the digital economy Action 2: hybrid mismatch arrangements Action 5: harmful tax competition Action 6: preventing tax treaty abuse Action 8: guidance on transfer pricing and intangible assets Action 13: transfer pricing documentation and country-by-country reporting Action 15: developing a multilateral legal instrument Next steps Introduction On… – Continue reading
This week brings a wealth of news in the FATCA arena, which we summarize in today’s post. First, former acting IRS Commissioner Steven Miller speaks out against FATCA and suggests that the benefits of the new information reporting regime imposed by FATCA may not outweigh its costs. An article published… – Continue reading
For a large majority of the ever-increasing number of British expatriates with pensions which remain in the UK, a Qualifying Recognised Overseas Pension Scheme (QROPS) provides a viable and sometimes integral role in retirement planning. This counts for those now residing in Europe, Asia and the Middle East, however arguments… – Continue reading
On October 8, 2014, Swiss officials announced that they intend to negotiate a reciprocal Model 1 FATCA IGA to replace the Model 2 IGA that they signed in 2013. The motivation for the change is unknown, but the automatic exchange of information under Model 1 is more in line with… – Continue reading
Taipei, Oct. 10 (CNA) Taiwan’s top financial regulator said Friday it will relax rules governing the business scope of Taiwanese securities firms’ offshore securities units (OSU), a move that could help the units seize more opportunities. The Financial Supervisory Commission (FSC) said that it will seek approval from the Central… – Continue reading
Two Canadian women mounting a legal challenge to FATCA have expanded their action to include the Minister of National Revenue as a defendant. Gwen Deegan, a graphic designer from Toronto, and Ginny Hillis, a retired lawyer from Windsor, claim the Canadian federal government doesn’t have the constitutional authority to comply… – Continue reading
The Hackett Group predicted in a 2012 report that this year would be the start of an eight-year death of offshoring to India Yahoo! just made about $9 billion in cash from Alibaba Group’s initial public offering, and investors are licking their lips at the thought of how Marissa Mayer… – Continue reading
Mission Hills businesswoman Cheryl Womack is scheduled to appear in federal court in Kansas City on November 12 for a change of plea hearing in her criminal case. Womack had earlier entered a not guilty plea to charges of avoiding income taxes and lying to investigators. (Update, 9:03 p.m) It’s… – Continue reading
SAN ANTONIO — A tax protester who fancied himself as a pirate was ordered Friday to dry dock for 41 months for dodging more than $400,000 in taxes before fleeing to Mexico in 2005. Chief U.S. District Judge Fred Biery imposed the prison sentence on Sterling R. Benningfield, 66, and… – Continue reading
Illegal Gambling Crackdown in Italy…A “Report on Tax Evasion“ Illegal Gambling Crackdown in Italy…A “Report on Tax Evasion“ Italy’s Report on Tax Evasion Runs Gamut on GamblingItaly is cracking down on illegal gambling operations. Pier Carlo Padoan, Italian Finance Minister, has disclosed the chain of new procedures that is being… – Continue reading
The European Commission’s recent action to crack down on special deals some European Union governments offer to corporations could be a blow to multinational corporations’ tax-dodging strategies. As we noted in a report earlier this year, three European countries (Ireland, Luxembourg and the Netherlands) are among the top twelve tax… – Continue reading
Asian financial institutions could come under closer scrutiny by US authorities that are seeking to expand a probe into offshore tax avoidance activities across more jurisdictions, according to consultancy firm AlixPartners. The US government has stepped up efforts to counter tax evasion activities by its citizens in recent years. Last… – Continue reading
Medical device giant Medtronic is close to finishing a deal to move its tax headquarters to Ireland and boost its stock price. But while shareholders face taxes on those gains, the company is shelling out more than $60 million to make sure its CEO and 25 other top officials won’t… – Continue reading
On October 7, 2014, the Organisation for Economic Cooperation and Development (OECD) published comments received from various stakeholders regarding the OECD’s work on establishing methodologies to collect and analyze data on base erosion and profit shifting (BEPS) and the actions to address it (Action 11). In the main, many commentators… – Continue reading
Endo International Plc (ENDP) agreed to buy Auxilium Pharmaceuticals Inc. (AUXL) for about $2.6 billion to gain testosterone products. Endo will pay $33.25 a share, and Auxilium holders will be able to choose cash, stock or a combination of the two, the companies said today in a statement. The price… – Continue reading
NEW DELHI: India and Japan will soon sign an advance-pricing agreement (APA), a move that will provide certainty to investors at a time the country is looking to attract big Japanese investment. “I am happy to mention here that APA between India and Japan in a particular company’s case has… – Continue reading
Both the Securities Industry and Financial Markets Association (SIFMA) and Mindtree, a global technology services company, have pointed out the immense global compliance costs and issues posed by the Foreign Account Tax Compliance Act (FATCA) to the financial services industry. Enacted by the US Congress in 2010, and effective from… – Continue reading
High quality global journalism requires investment. Please share this article with others using the link below, do not cut & paste the article. See our Ts&Cs and Copyright Policy for more detail. Email ftsales.support@ft.com to buy additional rights. http://www.ft.com/cms/s/0/ba95cff0-4fcd-11e4-a0a4-00144feab7de.html#ixzz3G77zeNBz Brussels is challenging the “double Irish” tax avoidance measure prized by big US tech… – Continue reading
VietNamNet Bridge – Foreign automobile and electronics manufacturers often choose foreign enterprises for their parts and accessory suppliers instead of Vietnamese companies because it allows them to engage in transfer pricing, some analysts have claimed. Samsung, Toyota, Canon and other giants in the manufacturing industry have complained many times that… – Continue reading
Yahoo! just made about $9 billion in cash from Alibaba Group’s initial public offering, and investors are licking their lips at the thought of how Marissa Mayer might spend it. Snapchat? AOL? Well, here’s one area you shouldn’t expect her to invest in: offshoring more jobs to India. The company… – Continue reading
Australian tax authorities allege multinational oil giant Chevron used a series of loans and related party payments worth billions of dollars to slash its tax bill by up to $258 million. New documents filed in a long-running dispute in the Federal Court show how Chevron allegedly engaged in a complex… – Continue reading
European body adds another high-profile name to its crackdown on multinationals’ tax avoidance in bloc. The European Union is broadening its crackdown on multinationals’ tax avoidance schemes, opening an investigation yesterday into Amazon’s practices on suspicion the online retailer is not paying its dues on profits made across the 28-nation… – Continue reading
Findings that New Zealand’s tax system is the second most competitive of all 34 OECD countries reflect changes that should be promoted more internationally, says Greg Thompson, Partner and National Director, Tax at Grant Thornton New Zealand. The Tax Foundation’s International Tax Competitiveness Index ranks tax systems on the basis… – Continue reading
There are reportedly about to be major moves in the fight against tax evasion within the European Union. The region’s finance ministers are said to be close to an agreement on automatic sharing of bank data so that the authorities could spot tax dodging or illicit money flows more easily…. – Continue reading
Oct. 7 — The IRS is working to finalize rules aimed at curbing the ability of foreign investors to skirt the withholding tax on dividends under tax code Section 871(m) by the end of 2014, an Internal Revenue Service official said. The IRS has “a team of people” dedicated to… – Continue reading
The question has often arisen whether “international law” is an oxymoron – whether “obligations” in income tax treaties and other international agreements are really binding upon the parties, when they are not buttressed by some sort of enforcement mechanism. That question has never been more relevant in the tax world… – Continue reading
As a part of the OECD/G20 project to combat base erosion and profit shifting (“BEPS”), the OECD released the first set of reports and recommendations on September 16, 2014. These reports address seven of the actions described in the 15-point action plan to address BEPS published in July 2013 (the… – Continue reading
Overview I have mentioned in prior articles that I was a Spanish and Portuguese major as an undergraduate. During the time that I was attending law school at the University of Miami, the early 1990’s, the Brazilians had yet to arrive in South Florida in a significant manner. The Brazilian… – Continue reading
The UK Finance Act 2014, enacted in July 2014, contains new legislation to deal with cases of purported tax avoidance, which marks a radical departure from previous policy in this area. Until Finance Act 2014, it was generally the case that where a taxpayer contested a direct tax assessment made… – Continue reading
Indonesia’s tax chief is pushing for access to personal bank accounts and wants to track car and home purchases in his fight to catch evaders and boost revenue. The department is asking parliament to amend the banking law to give it the right to get lenders to reveal customer account… – Continue reading
Medtronic announced last week that it will go ahead with its Covidien buyout despite a recent notification by the U.S. Department of the Treasury and the Internal Revenue Service discouraging tax-avoiding corporate inversion deals. Per the new guidelines, companies will not be able to avoid paying U.S. taxes when accessing… – Continue reading
OPINION: How often do you hear governments say ‘we’re not sure if it will work, but we’ll give it a shot’? Not a lot, Chalkie would say. Lack of evidence that a policy will produce the desired effect is generally its death knell, particularly if said government was not keen… – Continue reading
According to a report published in the Sydney Morning Herald on October 6, Tim Cahill may be dealing with an irksome tax problem, stemming from investments made when he was living and working in England. The newspaper claims to have seen documents linking Cahill to a company called Phoenix Film… – Continue reading
The Organization for Economic Cooperation and Development (OECD) has released the first components of its comprehensive plan for creating an agreed set of international rules for fighting base erosion and profit shifting (BEPS) and ending opportunities for double non-taxation. The four model legal instruments and three reports are the first… – Continue reading
BANGALORE, India — One of the world’s biggest cellular phone manufacturing plants, located in the southern India city of Chennai, will stop production of mobile phones and down shutters after Nov. 1. Microsoft, its lone customer, has terminated a subcontract agreement. “Microsoft has informed Nokia that it will be terminating… – Continue reading
The UK government will continue to defend its ‘patent box’ tax break for income from qualifying intellectual property (IP) during discussions to develop a global corporate tax regime, a Treasury official has said.08 Oct 2014 Intellectual Property Tax Patents Corporate tax Life sciences Advanced Manufacturing & Technology Services UK Europe… – Continue reading
The non-legislative measures put forward by the Treasury Department on September 22, to deter multinationals from using corporate inversions to move their tax residence abroad and move away from the high United States tax rate, have so far produced a mixed bag of results. The measures are aimed at preventing… – Continue reading
MOSCOW, October 8. /TASS/. The Russian Finance Ministry has drafted a decree that will exclude Malta from the black list of offshore jurisdictions. The decision followed the enactment of the convention between the governments of Russia and Malta of May 22, 2014 on the avoidance of dual taxation and prevention… – Continue reading
Simon Carter Prime Minister David Cameron pledged at Tory party conference to make tax cuts to assist 30 million “hardworking families”. However, according to tax experts, the main beneficiaries won’t be the claimed 30 million but only the rich. According to the Institute of Fiscal Studies only 15% of the gains from increasing… – Continue reading
The UK government will continue to defend its ‘patent box’ tax break for income from qualifying intellectual property (IP) during discussions to develop a global corporate tax regime, a Treasury official has said.08 Oct 2014 Intellectual Property Tax Patents Corporate tax Life sciences Advanced Manufacturing & Technology Services UK Europe… – Continue reading
The Internal Revenue Service plans to take additional actions to improve taxpayer compliance with a law related to the disposition of foreign investments in U.S. real property, according to a new government report. The report, from the Treasury Inspector General for Tax Administration, noted that Congress passed the Foreign Investment… – Continue reading
HM Revenue and Customs (HMRC) is consulting on draft regulations that will exclude two types of persons from the definition of “promoter” for the purposes of the Promoters of Tax Avoidance legislation. The regulations are intended to meet concerns raised during the development of the primary legislation. They are relieving… – Continue reading
The Markets in Financial Instruments Directive (“MiFID”) is a European Union law that aims to harmonise the regulation of investment services across the member states of the European Economic Area and came into effect from 1 November 2007. Following the 2008 financial crisis, amendments to MiFID became the focus of… – Continue reading
The taxman is willing to “negotiate and strike a balance” with multinationals being audited for transfer pricing misconduct, a drive it says has a potential to realise over Sh30 billion. The Kenya Revenue Authority told a workshop organised by the Association of Chartered Certified Accountants in Nairobi that this will… – Continue reading
SOUTH African property punters are still making more money offshore than in their own backyards — in both rand and dollar terms. Latest figures from Cape-based Catalyst Fund Managers and UBS show that global property stocks, or real estate investment trusts (Reits) as they are commonly known, delivered a total… – Continue reading
Eight of the top 200 companies publicly listed on the Australian stock exchange (ASX200) paid no taxes on profits averaging $50 million to more than half a billion dollars over the decade to 2013! More than 20 (10 percent) corporations paid an average tax rate of five percent or less…. – Continue reading
Miguel Arias Cañete, the Spanish Commissioner-designate for Energy and Climate Change, has left five important questions unanswered during his confirmation hearing in the European Parliament, writes Alicia Gutiérrez. Alicia Gutiérrez is a journalist at the Spanish online media infoLibre. (Translation by Avaaz. Original version here) 1. Has Cañete had any… – Continue reading
In Starr International Company, Inc., v. United States, the taxpayer (“Starr International Company, Inc.” or “SICO”) filed a complaint in the United States District Court for the District of Columbia seeking a tax refund from the IRS of approximately $38 million. The refund is allegedly due to an overpayment of… – Continue reading
The relationship between the IRS and Canadians is not great. Groups like the Alliance for the Defense of Canadian Sovereignty want relief from the horrendous double filing and higher taxes Ameri-Canadians often face. Add to that the Canadian suit to block Canada’s FATCA deal with the U.S. It adds up… – Continue reading
