CF Industries (CF – Analyst Report) and Netherlands-based fertilizers and industrial chemicals producer – OCI N.V. – said that they have amended their merger agreement originally announced in Aug 2015. Under the modified agreement, the jurisdiction of incorporation and tax residency of the new combined company has been changed to… – Continue reading
It’s probably not the best time in the province to announce a payroll rebate to a major offshore bank promising to create 50 jobs in Halifax. Nova Scotia Business Inc. on Tuesday announced a rebate worth a potential $840,000 over six years to the Bank of N.T. Butterfield and Son… – Continue reading
LONDON (Reuters) – Seven of the biggest investment banks operating in London paid little or no tax in Britain last year, despite reporting billions of dollars in profits, a Reuters analysis of corporate filings shows. In recent months, the seven investment and corporate banks operating in London reported figures showing… – Continue reading
On December 17, the South African Revenue Service (SARS) issued an explanatory memorandum on the 2015 Tax Administration Laws Amendment Bill (TALAB). In particular, the memorandum looks at the TALAB provisions giving effect to the collection of information from South African financial institutions (FIs), and the associated obligation on the… – Continue reading
Dec. 21 — The IRS proposed rules requiring large companies to report information including the amount of revenue, profit or loss, capital and accumulated earnings for each country of operation, consistent with OECD recommendations designed to combat base erosion and profit shifting. The proposed rules (REG-109822-15, RIN 1545-BM70) would apply… – Continue reading
American expats could have their passports revoked next month if they fail to comply with their tax and financial obligations. American expats could have their passports revoked next month if they fail to comply with their tax and financial obligations under the Foreign Account Tax Compliance Act, or Fatca, a… – Continue reading
MUMBAI: It seems, following a directive from PM Narendra Modi and Arun Jaitley, the Central Board of Direct Taxes (CBDT) is leaving no stones unturned to change the image of India from being too aggressive on taxation to being strict but friendly on corporate taxation. The CBDT, which has been… – Continue reading
Dividend income from shares paid into a foreign bank account are among the transactions covered by the Liechtenstein Disclosure Facility which is about to close, accountants warn. Other normal circumstances where offshore tax liabilities may have arisen but can be dealt with via the “generous” LDF include CGT or rent… – Continue reading
The announcements coming out from both the CI government and the UK government on beneficial ownership can provide a lesson in semantics. The arguments are seemingly centered on the meanings of the words “public” versus “centralised.” The “simple definition” of semantics from the Merriam-Webster Dictionary is “the study of the… – Continue reading
The Chartered Institute of Taxation (CIOT) has welcomed a change to the Government’s approach1 to improve tax compliance by large companies but remains sceptical about the effectiveness of a ‘special measures’ regime to target tax abuse. John Cullinane, Tax Policy Director, said: “We are pleased that the framework for improving… – Continue reading
Most people with undisclosed Swiss bank accounts have, by definition, something to hide. Secrets, however, sometimes don’t remain secret, especially when they involve someone else’s money. While disclosing the names and financial details of Swiss bank account holders has recently come into vogue, a whistleblower may have just as murky… – Continue reading
Luxembourg’s long-hidden role as a secret tax haven in the very heart of the European Union has been shattered by one man who happened to be in the right place at the right time to do what he thought was the right thing. Antoine Deltour brought to light how the… – Continue reading
MUMBAI: When Grant Thornton recently appointed India leader Vishesh Chandiok on its global governance board, it reflected the country’s growing importance as a market for the London-headquartered professional services firm. At 41, Chandiok may be the youngest member of the board ever but points out that he doesn’t lack for… – Continue reading
A BALANCING ACT in London, folly and redemption in America’s District of Columbia and sheer hypocrisy in Brussels. And in every case, Barbados and many of its Caribbean neighbours were placed in the negative international spotlight at a time when some of the world’s major financial centres are casting about… – Continue reading
BEIRUT: Lebanon’s commitment to fighting money laundering does not hurt banking secrecy but, to the contrary, is in the interests of the banking sector, said Joseph Torbey, president of the Association of Banks in Lebanon. “Lebanon’s serious commitment to fighting money laundering will prevent the escape of investments from Lebanon… – Continue reading
IRS Criminal Investigation » Agency initiated 3,853 investigations nationally and is nabbing criminals from tax cheats to terrorists despite budget cuts, chief says. Utahn Gerrit Timmerman III claimed his corporation — “The Office of the First Presiding Patriarch (Overseer) and his/her successors, a corporation sole over/for an unincorporated scriptural society,… – Continue reading
IT is ironic that what was almost at the centre of the BEPS project has ended up in not having a concrete agreement and with a vague promise of some review by the year 2020. One may recall that it was the big digital companies and their tax affairs that… – Continue reading
A study from Confindustria, the Italian business association, has estimated that tax and social security contributions evaded in Italy amounted to EUR122.2bn, or 7.5 percent of gross domestic product (GDP), in 2014. Confindustria described tax evasion as “a serious obstacle to Italy’s economic and social development because it penalizes equity,… – Continue reading
It is possible that the United States expats could have their passports revoked next month if they fail to comply with their tax and financial obligations under the Foreign Account Tax Compliance Act (FATCA). This was revealed by Mr. Jim O’Niell, Vice President of US Financial Advisory & Audit Firm… – Continue reading
American citizens risk losing passports if they do not report foreign income, bank accounts Dubai Americans must comply with tax law changes coming into effect in the new year and report income earned abroad and foreign-held bank accounts over $10,000 (Dh36,700) or else they risk losing their passports, a US… – Continue reading
It was Kerry Packer who famously told the nation’s politicians “if anybody in this country doesn’t minimise their tax they want their head read” because “as a government I can tell you you’re not spending it that well that we should be paying extra”. The words have gone down in… – Continue reading
The Protocol amending the Multilateral Convention on Mutual Administrative Assistance in Tax Matters will lead to substantially more transnational identity theft, crime, industrial espionage, financial fraud, and the suppression of political opponents and religious or ethnic minorities by authoritarian and corrupt governments. It puts Americans’ private financial information at risk…. – Continue reading
The Markets Supervision Directorate of the Central Bank published its programme of themed-inspections for 2016. These inspections reflect a number of supervisory priorities for 2016 and anticipate areas of emerging risk. This programme builds on the successful supervisory work undertaken in 2015 in the areas of Cyber Security, Operational Risk… – Continue reading
While the latest Bond movie, Spectre, brings glowing praise for Daniel Craig, life is running rather less smoothly for the prototype 007. In truth, Sir Sean Connery’s personal story has never remotely resembled that of the unruffled agent he so consummately portrayed. Down the years, he has faced a plethora… – Continue reading
The provisions commonly known as the Foreign Account Tax Compliance Act (FATCA) became law in March 2010. •FATCA targets tax non-compliance by U.S. taxpayers with foreign accounts •FATCA focuses on reporting: •By U.S. taxpayers about certain foreign financial accounts and offshore assets •By foreign financial institutions about financial accounts held… – Continue reading
MUMBAI: As many as 380 market entities, most of them stock brokers, faced action for failing to prevent possible money laundering and terror financing activities during the last fiscal. Discrepancies related to Anti-Money Laundering and Combating Financing of Terrorism (AML and CFT) regulations were observed against brokers and depository participants… – Continue reading
An Easy Checkoff for Global Competitiveness: The Case for a U.S. Innovation Box – Robert D. Atkinson – November 30, 2015. “Taxing corporate revenues from innovation-based activities less will not only boost U.S. global competitiveness it will help bring back IP-based corporate profits now overseas. “Within the last decade a… – Continue reading
Netflix the online movie rental service did not pay any UK corporation tax last year, despite generating an income of £200million in Britain. The world’s biggest internet movie streaming service has five million subscribers in the UK alone and has proved a hit by offering U.S. shows like House of… – Continue reading
The Australian Taxation Office (ATO) on 17 December 2015 released guidelines that address country-by-country reporting. The ATO release—Law Companion Guideline (LCG) 2015/3—discusses Tax Laws Amendment (Combating Multinational Tax Avoidance) Act 2015 that was enacted earlier this month and discusses, in particular, Schedule 4. Background Schedule 4 created Subdivision 815-E of… – Continue reading
The Australian Taxation Office (ATO) released its first tax transparency report, outlining for the 2013-14 year, the tax information published by the ATO covering income tax of certain corporate taxpayers with total income of AUS $100 million or more. Of the 1,539 total number of companies disclosed in the ATO’s… – Continue reading
Apple CEO says the company pays ‘every tax dollar we owe’ amid debate in the US over corporations avoiding tax by using offshore units Apple’s chief executive Tim Cook has dismissed as “total political crap” the notion that the technology giant was avoiding taxes. Cook’s remarks, made on CBS’ 60… – Continue reading
Footwear is one of the industries with high export turnover. However, the profitable industry is being controlled by companies from South Korea and Taiwan. According to the Vietnam Leather & Footwear Association (Lefaso), with 800 enterprises and 1 million workers, FIEs account for one-fourth of total number of footwear makers,… – Continue reading
On 16 October 2015, the Cayman Islands Government issued new regulations with respect to a global initiative on the automatic exchange of information (“AEOI“) and the Common Reporting Standard (“CRS“), established to improve tax transparency in the increasingly globalised world. Links to the Tax Information Authority Law (2014 Revision) and… – Continue reading
About Botswana Botswana, a former British colony in Southern Africa, is one of the most prominent countries in Africa. The country has a strong economy,uses one of the most advanced banking systems in the continent, and maintains a stable tradition of representative democracy. After becoming independent in 1966, Botswana developed… – Continue reading
As the Government of Jamaica moves on its agenda to prevent revenue leakage through transfer pricing legislation, local companies are still waiting to see what impact the changes will have on their operations. The new law allows for the detailed examination of the accounts of companies with associates and branches… – Continue reading
The Bundesrat (upper house of the German parliament) approved the Law on the Automatic Exchange of Financial Account Information (Finanzkonten-Informationsaustauschgesetz) on 18 December 2015. Financial institutions face new reporting obligations and duties of care under this law. The new legislation requires financial institutions to provide the German Federal Central Tax… – Continue reading
When purchasing a real property overseas, there are situations when it may prove advantageous or even necessary to do so through an offshore corporation, rather than owning the property individually. It is crucial to understand that this can also have significant US tax consequences for US persons. Fortunately, “checking the… – Continue reading
Case law Chevron appeal to the Full Federal Court Chevron Australia Holdings Pty Ltd has appealed the decision of the Federal Court in Chevron Australia Holdings Pty Ltd v Commissioner of Taxation (No 4) [2015] FCA 1092 to the Full Federal Court. For details of the Federal Court decision, please… – Continue reading
The Delhi High Court held that the taxpayer’s advertising, marketing, and sales promotion expenses were not an “international transaction” under provisions of India’s tax law, and thus, could not be the basis of a transfer pricing adjustment. The court further held that a “bright line test” as applied by the… – Continue reading
The Council of the European Union released details of a possible draft EU directive, addressing certain “anti-base erosion and profit shifting” (anti-BEPS) initiatives. The issues addressed concern certain international aspects of the proposal for an EU “common consolidated corporate tax base” (CCCTB), and reflect issues that are directly related to… – Continue reading
A list of tax paid by Australia’s biggest companies, released by Tax Commissioner Chris Jordan on Thursday, may have raised more questions than it answered. Nevertheless, we needed it. This is just the beginning of a long journey towards tax transparency. The Australian Taxation Office (ATO) released the data for… – Continue reading
The European Parliament has spelt out the legal steps needed to improve corporate tax transparency, coordination and an EU-wide policy convergence in a resolution voted on this week. Parliament’s drive to persuade EU member states to act to counter aggressive corporate tax planning and evasion by multinationals in Europe was… – Continue reading
MUMBAI|NEW DELHI: Many US-based non-resident Indians are considering selling their property in India – even at a discount – amid confusion and fear that a new information-sharing protocol may bring their assets, bank accounts, mutual funds and capital market investments in India under the scanner of US tax authorities. India… – Continue reading
The Indian government has become progressively more strict about what is considered income under tax law and who must file an income tax return. In particular, companies required to withhold taxes, and individuals or companies in receipt of income, have found themselves subject to increasingly stringent withholding rules. The topic… – Continue reading
Group companies, irrespective of the jurisdiction, will have to conform to common standards The Organization for Economic Cooperation and Development (OECD) recently released 15 action-plans to address the issue of “Base Erosion & Profit Shifting” or BEPS, which has led to misalignment between where taxes are paid and where value… – Continue reading
Employees relocating from Canada to the US may face a number of complex tax-related issues. Matt C Altro, president and CEO of Canadian firm MCA Cross Border Advisors, shares his advice for companies and their relocatees on planning for, and coping with, these challenges. Talent mobility is a key issue… – Continue reading
Maltese MEPs and their Cypriot counterparts have voted against a report which urges the European Union to introduce tax convergence and harmonisation among all EU member states. The vote passed with 500 votes in favour, 122 against and 81 abstentions. Head of the Maltese Labour Delegation, Alfred Sant, said that… – Continue reading
2016 Compliance Update For the past few years, FATCA has dominated the international tax compliance landscape. As that regime continues to be phased-in, a new regime – the Common Reporting Standard (“CRS”) – will begin to be implemented around the world. CRS, sometimes referred to as “Global FATCA,” will expand… – Continue reading
Turkey’s ruling Justice and Development Party (AKP) government, in power for 13 years, has been notoriously lax and often late when it comes to implementing stringent rules controlling money in order to ensure better transparency in financial movements, halt tax evasion, prevent illicit funding and disrupt money laundering activities. That… – Continue reading
Liability below the mid-point of the range in IPO prospectus TORONTO, Dec. 18, 2015 /CNW/ – Spin Master Corp. (“Spin Master” or the “Company”) (TSX: TOY) announced today that it has reached a settlement agreement with the Canada Revenue Agency (“CRA”), which resolves a previously disclosed transfer pricing matter arising… – Continue reading
