Shiseido Co., Japan’s top cosmetics brand, was alleged by tax authorities to have failed to report 3.8 billion yen in income in Japan for five years through March 2012 by pooling profits at a U.S. subsidiary, sources familiar with the matter said Thursday. The company is planning to dispute the… – Continue reading
Not only do Indians manage global investors’ money that is invested in India, Indian nationals often hold positions of responsibility in funds that have nothing to do with India. Now, given the rapid advances that have been made in technology, why aren’t these Indian nationals residing in India? Clearly, some… – Continue reading
As property values around the country continue to recover, many families now list their primary residence and vacation homes among their most valuable assets. As such, these homes may be excellent candidates for beneficial estate planning techniques. One of the more straightforward of these techniques is the use of a… – Continue reading
The Dutch public prosecution department is investigating hundreds of transactions in which residents of other EU countries have used the Netherlands to avoid paying tax, the Financieele Dagblad says on Tuesday. The Financieele Dagblad bases its claims on confidential legal documents and an interview with a main suspect – a Dutch… – Continue reading
Local banks have little choice but to comply with a controversial law that requires financial institutions around the world to hand over information about American citizens that will be passed on to the US tax department, the New Zealand Bankers’ Association says. The US Foreign Account Tax Compliance Act (FATCA),… – Continue reading
The Russian authorities are ready to provide the U.S. internal revenue service with information on American depositors, but have drafted a bill for similar measures in the United States. All foreign banks that work with Russian clients will be obligated to disclose information about such clients to Moscow. Primarily, the… – Continue reading
For more than a century, Geneva has provided wealthy French families a convenient and safe place to stash their money. Switzerland’s political neutrality, stability, and tradition of bank secrecy have kept their fortunes beyond the reach of warring powers and the most determined tax collectors, even though Geneva is less… – Continue reading
The IRS has announced important changes to its offshore account programs. They come as FATCA is taking hold worldwide. Many foreign banks are rooting out Americans with increasing vigilance. One key target of the changes? Americans living abroad and certain others who can now come within the IRS Streamlined Program…. – Continue reading
New Zealand financial institutions’ FATCA obligations are clarified with today’s signing of a NZ/US intergovernmental agreement (IGA). The long-awaited agreement comes not a moment too soon, with the 1 July implementation date just over two weeks away. FATCA’s global reach FATCA (short for Foreign Account Tax Compliance Act) is a… – Continue reading
The issue has dominated debate among world leaders and the Organisation for Economic Co-operation and Development (OECD) in recent months. In fact, it’s the OECD that’s been driving an effort to coordinate information exchange between jurisdictions under a single global standard in an effort to develop tax transparency. Moving on… – Continue reading
ANZ Bank chairman David Gonski has called for changes to dividend imputation, saying the system discourages offshore investment by large corporates that provide “enormous benefits” to the nation. While a “huge fan” of dividend imputation’s role in raising local investment and stimulating companies to pay a full tax rate, Mr… – Continue reading
Irish and shareholder eyes may be smiling at the prospect of medtech giant Medtronic acquiring Covidien and moving its headquarters to Ireland, where Covidien is based, but the $42.9 billion deal is causing at least a few frowns, as well. Minneapolis-based Medtronic is the largest U.S. company to try to… – Continue reading
As the start of FATCA looms, Americans living permanently overseas are rushing to renounce their US citizenship. The IRS’s five-year campaign to uncover undeclared, taxable assets held by US expats is having an unexpected result, as many middle-income Americans living abroad are deciding to hand in their citizenships. Those who… – Continue reading
NEW YORK • What’s greasing the wheels for the rise in mergers by U.S. companies? The tax man. Two tax-code quirks — one that charges U.S. companies when they repatriate overseas earnings, the other that allows them to claim a foriegn domicile without moving their senior leadership abroad — are… – Continue reading
DELHI – After classifying Cyprus as a “notified jurisdiction” last November and suspending double taxation avoidance agreement (DTAA) benefits, India may soon revise its DTAA with Cyprus and restore a 10 percent withholding tax rate in light of recent progress in tax information sharing. Since the two countries signed a… – Continue reading
It’s a very small world when it comes to money and banking, as we all learned in 2007. Now the Internal Revenue Service is extending its reach to financial activities of U.S. citizens who have money in foreign financial institutions. On July 1, 2014 FATCA — the Foreign Account Tax… – Continue reading
Going offshore means registering any intellectual property (IP) in an offshore company and delegating R&D and marketing to onshore companies. Money doesn’t grow on trees, and taking your business international is no picnic. On June 12, the International Business Structuring Association (IBSA) held a seminar to discuss ways of growing… – Continue reading
The organisations making the payments are required to withhold tax from such payments and pay over the withheld amounts to their respective relevant Tax Authorities within 30days of receipt of payment or credit by the person or entity suffering the Tax. The relevant tax authorities to receive the WHT tax… – Continue reading
The National Board of Revenue (NBR) is going to introduce transfer pricing regulations from July 1, 2014 in a bid to check tax avoidance by multinational companies. The Transfer Pricing Law, approved through the Finance Bill-2012, remained in process of preparing ground work for its successful implementation. It will help… – Continue reading
In a June 3 speech, IRS Commissioner John Koskinen said the agency may not have been accommodating enough to U.S. citizens who have lived abroad for years. “We have been considering whether these individuals should have an opportunity to come into compliance that doesn’t involve the type of penalties that… – Continue reading
New Zealand has signed a Foreign Account Tax Compliance Act intergovernmental agreement with the United States, which will minimize compliance costs for financial institutions in New Zealand. The agreement includes a waiver for certain account types that are deemed to be low risk. The IGA will facilitate information exchange under… – Continue reading
Here in Ireland we can puff up our breasts and deny that there is anything tax haven-like about this country but the rest of the world believes otherwise. Poor Enda Kenny, who is chief theologian on the not-a-tax-haven side needs the Medtronic announcement like a hole in the head. There… – Continue reading
Just as water flows downhill, so do the profits of multinational corporations travel toward the countries with the lowest tax rates. That’s a fact of life in an era of global markets and businesses; there will always be countries that set unusually low corporate tax rates in the hope of… – Continue reading
(Reuters) – Wealthy Asians are increasingly wary of letting banks look after their money and would rather use smaller asset managers instead, according to one of the region’s leading lawyers to the ultra rich. David Chong, chairman of Asia’s largest independent trust company, Portcullis TrustNet, said huge fines imposed on… – Continue reading
Medtronic Inc. (MDT), the globe-spanning medical device maker founded in a Minneapolis garage in 1949, is poised to become the biggest company yet to escape the U.S. tax system by shifting its incorporation abroad. Medtronic said yesterday it plans to take a legal address in tax-friendly Ireland as part of… – Continue reading
KATHMANDU: US taxpayers, including US citizens, firms and green card holders, living in or operating from Nepal will come under close scrutiny of the US taxman from now onwards. Issuing a circular today, Nepal Rastra Bank directed all Nepali banks and financial institutions to provide bank account information of US taxpayers living… – Continue reading
Measures to block abuse of ‘transfer of rights’ rules expected to bring in more than £160m, taxman says. Measures to block abuse of ‘transfer of rights’ rules expected to bring in more than £160m, taxman says. The High Court has rejected an attempt to bring a judicial review to challenge… – Continue reading
A Moscow City Hall official confronted with allegations of illegal business activity has sued his accuser, whistle-blowing blogger and opposition activist Alexei Navalny. Deputy Mayor Maxim Liksutov, who oversees transportation in Moscow, announced via Facebook on Thursday that he had sued Navalny for an unspecified sum. Data made publicly available… – Continue reading
Tens of thousands of Irish people and foreign nationals who have worked and lived in the UK or US and still have investments, property or pension funds there, are particularly vulnerable to those countries’ tax regulations. Soon, one group in particular – the nearly 12,000 American citizens living in Ireland… – Continue reading
While the UK government continues its battle against tax evasion and tax avoidance, the authorities have received welcome support from the High Court with a ruling backing last year’s bid to stop investors avoiding stamp duty. In simple terms, savvy investors were transferring ownership of property to an offshore company… – Continue reading
AS NAMIBIAN political activists, we are writing to you because we are greatly concerned about your transfer-pricing methods. We know that transfer-pricing occurs when two companies from the same multinational corporation trade with each other. This is probably the most important issue as far as international taxation is concerned, since… – Continue reading
As the first set of Foreign Account Tax Compliance Act (FATCA) compliance issues for banks worldwide is set to come into effect on July 1 we have seen a flurry of banks around the world advising US citizens that they will be immediately closing their accounts. None has been so far… – Continue reading
Competition takes many forms in capitalism. Financial engineering by corporations to avoid paying taxes is one aspect of this competition — under the rigors of market competition, evading responsibility is an innovation to be emulated. The magnitude of tax evasion on the part of multi-national corporations through one channel —… – Continue reading
On June 5, 2014, the Court of Justice of the European Union handed down a joint ruling concerning two Dutch companies’ objections to the imposition of withholding tax on dividends paid to their respective holding companies based in the former Netherlands Antilles. In X BV, TBG Limited vs Staatssecretaris van Financien (C-24/12… – Continue reading
New Zealand financial institutions’ FATCA obligations are clarified with today’s signing of a NZ/US intergovernmental agreement (IGA). The long-awaited agreement comes not a moment too soon, with the 1 July implementation date just over two weeks away. FATCA’s global reach FATCA (short for Foreign Account Tax Compliance Act) is a… – Continue reading
In 2010, Congress passed House Resolution (H.R.) 2847, the Hiring Incentives to Restore Employment Act, or HIRE Act. This legislation included a number of tax breaks meant to encourage businesses to put people on the payroll. This law also called for greater scrutiny of foreign accounts that U.S. citizens hold… – Continue reading
The fight against aggressive tax planning by multinationals will be one of the “key issues” for the European Parliament over the next five years, EU economics and monetary affairs commissioner Olli Rehn has said. Speaking at an event hosted by European Movement Ireland and BDO in Brussels yesterday, Mr Rehn,… – Continue reading
The Financial Times says today that 14 US tech & pharma groups, including Microsoft, Google and Johnson & Johnson, have cut their average tax rate by a quarter over the past eight years as they parked more cash offshore than all other US companies combined. Almost a half trillion dollars… – Continue reading
One of America’s best-known stores may soon decide that it’s no longer American. If it does, you will pay the price and feel real sick about it. Walgreens pharmacy is in every way an American company. It was founded in Chicago in 1901 and maintains its headquarters in Illinois. It… – Continue reading
Like a bad penny, this tax repatriation idea just keeps coming back. You know, the one where you offer a bribe to multinational corporations in the form of a big tax cut to “repatriate” their foreign earnings. In this case, members on both sides of the aisle are conspiring to… – Continue reading
ZIMBABWE lost about $770 million in potential revenue between 2008 and 2012 through undervaluation and transfer pricing of its gems from the Marange diamond fields. VENERANDA LANGA SENIOR PARLIAMENTARY REPORTER A report by Partnership Africa Canada on illicit financial flows in the diamonds industry said the gems were being exported… – Continue reading
The Heritage Foundation has issued a report to demonstrate how the United States Foreign Account Tax Compliance Act (FATCA) is hurting Americans living abroad, and has recommended that it should be reformed. In particular, Heritage noted that FATCA is burdening Americans living overseas with “enormous financial and legal burdens” through… – Continue reading
Last week, the TexPIRG Education Fund and the watchdog group Citizens for Tax Justice released a new report examining in detail how Fortune 500 companies in the United States are using offshore havens to avoid paying the taxes they owe the federal government. According to the report, an astounding 72% of American Fortune… – Continue reading
EC launches Apple tax investigation The European Commission has launched a formal investigation into Apple’s tax arrangements in Ireland The EC has announced three “in-depth investigations” into the transfer pricing arrangements on the corporate taxation of Apple, Starbucks in the Netherlands and Fiat in Luxembourg, as to whether they comply… – Continue reading
Apple Operations International, the principal Irish holding company for foreign subsidiaries, was not always stateless for tax purposes based on the last filed accounts in Ireland. It stopped paying tax in Ireland from 2006, based on US Senate Permanent Subcommittee on Investigations evidence. The most explosive revelation in the May… – Continue reading
India is said to be seeking a revision to its 1994 double tax agreement with Cyprus before the territory can be declassified as a notified jurisdictional area. In November of last year, the Indian Government invoked powers under Section 94A of the Indian Income Tax Act (ITA) 1961 to levy… – Continue reading
For more than a century, the Swiss city of Geneva has provided wealthy French families with a convenient and safe place to stash their money. Switzerland’s political neutrality and stability and its tradition of bank secrecy kept their fortunes beyond the reach of warring powers and the most determined tax… – Continue reading
One of America’s best known stores may soon decide that it’s no longer American. If it does, you will pay the price and feel real sick about it. Walgreens pharmacy is in every way an American company. It was founded in Chicago in 1901 and maintains its headquarters in Illinois…. – Continue reading
The European Commission is set to open formal investigations into Apple’s tax arrangements with Ireland. Last year, the US Senate accused the country of functioning as a “tax haven for Apple.” By funnelling profits into Irish subsidiaries that had no declared tax residency, the company was able to pay just… – Continue reading
The Cayman Islands needs to be more assertive in addressing its reputation as a so-called tax haven, that according to chairman of the Cayman Islands Stock Exchange Anthony Travers. A recent report by US-based watchdog groups Citizens For Tax Justice and the US PIRG named the Cayman Islands as one… – Continue reading
