With a slim new book that has the feel of Piketty’s bestselling Capital in the 21st Century, Zucman, a 28-year-old University of California-Berkeley economist, is taking his own swing at global capitalism. His target: tax havens that he says hide $7.6-trillion — about 8% of the world’s net financial wealth…. – Continue reading
On 28 March 2014, Luxembourg and the US signed an intergovernmental agreement (“IGA”) to implement automatic exchange of information in the context of the Foreign Account Tax Compliance Act, which gave birth to the Law of 24 July 2015 (“FATCA Law”). The purpose of the FATCA Law is to identify… – Continue reading
Tax laws are lagging behind the digital economy. As changes in the digital realm continue to outpace the speed at which legislators can work, and borders increasingly blur because of the internet, SA needs to play catch-up when it comes to tax. Currently, the only digital tax of any consequence… – Continue reading
Moving overseas to cut tax burden remains a viable option for some firms, though the presidential candidates may have other plans. With the long haul of a presidential election campaign just beginning, companies that leave the U.S. to lower their tax bills are once again political targets. Donald Trump this… – Continue reading
On 8 September 2015, Montserrat and the United States signed a Foreign Account Tax Compliance Act (FATCA) Agreement. FATCA seeks to obtain information on accounts held by U.S. taxpayers in other countries. It requires U.S. financial institutions to withhold a portion of certain payments made to Foreign Financial Institutions (FFIs)… – Continue reading
Ruling description In thejudgment of August 19, 2015 (case file no. II FSK 1747/13) the Supreme Administrative Court ruled, consistently with its previous rulings, that in the case of a transfer of shares for redemption at a remuneration lower than their market value, the tax authorities do not have the… – Continue reading
In light of the global Base Erosion and Profit Shifting (BEPS) initiative and the European developments against tax evasion and aggressive tax planning, two European Directives were adopted in July 2014 and January 20151 by the European Council, amending the Parent-Subsidiary Directive (2011/96/EU). These two Directives, in a nutshell, aim… – Continue reading
WASHINGTON, D.C. — United States authorities have begun the exchange of information with Mexico on all Mexicans with bank accounts or investments in the U.S. who have obtained more than $10 USD in annual interest. With the implementation of the Foreign Account Tax Compliance Act (FATCA), Mexico plans to deliver… – Continue reading
On 29 September, the Commission for Economic Policy (ECON) of the EU Committee of the Regions (CoR) held an external meeting in Gelsenkirchen, Germany, at the invitation of Markus Töns (DE/PES), member of the North Rhine-Westphalia Regional Parliament. On the agenda was the adoption of the draft opinions on the… – Continue reading
MUMBAI: The promoter of a Delhi-based, mid-sized, listed company has a Rs 700-crore problem. The cash is in various overseas accounts but the businessman has no plans of declare it before the black money deadline of September 30. Instead, he plans to invest it in the Indian capital markets by… – Continue reading
The Dutch Lower House (2e Kamer) approved earlier this month the new bilateral rules for the avoidance of double taxation between the Netherlands and Curacao. This new tax arrangement replaces the current tax arrangement for the Kingdom of The Netherlands. Next step will be approval by the Upper House (1e… – Continue reading
Tax havens are by design secretive and opaque. The entire point of their existence is to conceal the wealth hidden within them. And a new book by Gabriel Zucman, The Hidden Wealth of Nations: The Scourge of Tax Havens, reveals, as never before, the extent of their role in the… – Continue reading
Gabriel Zucman, one of 3 French economists who in recent times have published extensive research on wealth and equality, in a book, ‘The Hidden Wealth of Nations: The Scourge of Tax Havens,’ published this month, estimates that 8% of the world’s financial wealth — some US$7.6tn — is hidden in… – Continue reading
The European Commission will propose a draft law next year to stop tax regimes that favour raising corporate debt over equity as it tries to reduce the amount of company loans on banks’ books and to cut companies’ leverage, officials said on Monday, reports Reuters. In most European countries, companies… – Continue reading
The OECD has said that its base erosion and profit shifting (BEPS) project will create policy challenges for Ireland, but the nation should emerge well placed to attract foreign direct investment, reports Tax News. The report states: “Given the strong presence of intellectual property-intensive information technology and pharmaceutical companies in… – Continue reading
The court agrees to an early hearing in the case, scheduling it for 30 September New Delhi: The Supreme Court on Tuesday agreed to an early hearing in the case of Castleton Investment Ltd scheduling it for 30 September. Castleton Investment, a Mauritius-based foreign company, is contesting a case against… – Continue reading
PARIS – France’s fight against tax evaders is paying dividends, and will help the government cut taxes for households. On September 28th the Minister of Finance of France Michael Sapin announced that the upcoming budget plan for the 2016 year has been boosted by approximately EUR 2.4 billion, following a… – Continue reading
China’s State Administration of Taxation (SAT) has been busy during recent months pushing ahead with its own plans to update/revise a series of domestic tax laws and regulations as well as Sino-foreign tax treaties. The most prominent of these changes is a proposed update of Circular Guoshuifa 2009 No.2 (Circular… – Continue reading
Fundamental to any developed tax policy is knowing who the taxpayer is (or should be) with respect to any particular transaction. Although that can be relatively straightforward in purely domestic situations, a cross-border dimension can present different answers to this question in the jurisdictions involved and lead to issues over… – Continue reading
Having saved for most of their life to amass an income to use in retirement, most people get to a certain age and start to think about drawing on those financial reserves as they wind down from the daily grind. When that money is held in an international pension plan… – Continue reading
If you are a foreign executive moving to the United States for work, not only do you have to consider practical concerns like moving your family and finding a new residence, but you also need guidance as to any US tax implications stemming from the move. One of the first… – Continue reading
NEW DELHI: The ambitious anti-offshore tax evasion and black money detection pact between India and the US – Foreign Account Tax Compliance Act (FATCA) – will become operational from tomorrow. The pact aims to cover automatic sharing of information on bank accounts as well as financial products like equities, mutual… – Continue reading
One in five corporations with annual profits greater than $100 million paid no tax last year, the Australian Tax Office has revealed. Michael Cranston, one of the ATO’s deputy commissioners, revealed the figure to a Senate hearing into corporate tax avoidance. Corporations avoid paying tax by what is euphemistically called… – Continue reading
The Netherlands have requested information on a large number of Swiss bank accounts held by residents of its country in connection with a tax probe, Swiss authorities confirmed at the weekend, reports the Swiss Local. Swiss tax authorities received a request from their Dutch counterparts in July for access to… – Continue reading
Efforts to amend details of new rules on corporate profits raise questions, reports the Wall Street Journal. Nearly 50 governments are set to agree this fall to a new set of rules to clamp down on tax avoidance among multinational corporations. Their chance of success, however, is unclear. If the… – Continue reading
If the anti-corruption march goes ahead on Wednesday, it will be remiss if it doesn’t address one of the key issues of 2015: illicit financial flows. Institutions around the world are committing to combatting these and Unite Against Corruption needs to push the government to take action locally while lobbying… – Continue reading
International families are establishing domestic trusts at a record pace.1 Previously, these families set up trusts in the United States only if they had family and/or assets in the United States. This strategy still remains popular for international families, but now they’re also using domestic trusts even if they don’t… – Continue reading
MBABANE – City Press has alleged that the Swazi government has been robbed of billions of Emalangeni in the mining deal of iron ore at Ngwenya mine as the funds were siphoned off to the Seychelles in an abusive transfer pricing scheme. Financial statements of Shanmuga Rethenam’s companies have revealed… – Continue reading
Since its inception in August 2014, the SMU-TA Centre for Excellence in Taxation has worked tirelessly with industry practitioners, international academics and various key stakeholders to produce its first set of research works. On September 17, the Centre successfully presented its inaugural conference titled “A New Equilibrium in Tax Competition… – Continue reading
The Base Erosion and Profit Shifting (BEPS) Action Plan adopted by the OECD and G20 countries in 2013 recognised that enhancing transparency for tax administrations by providing them with adequate information to assess high-level transfer pricing and other BEPS-related risks is a crucial aspect for tackling the BEPS problem. Against… – Continue reading
Financial institutions, partner jurisdictions and affected stakeholders have been working to implement the Foreign Account Tax Compliance Act (“FATCA”) since its enactment in March 2010. Time and again, as key implementation dates draw near, stakeholders redouble their efforts to satisfy these deadlines. Nonetheless, some stakeholders are not as prepared as… – Continue reading
Tax Reform Still in Ryan’s Sights Despite Boehner’s Departure Last week, following the sudden announcement by House Speaker John Boehner (R-OH) that he would be stepping down from Congress at the end of October, House Ways and Means Committee Chairman Paul Ryan (R-WI) and various other Committee members quickly confirmed… – Continue reading
On September 17, 2015, the Canadian Border Services Agency (“CBSA“) released a revised D-Memorandum D13-4-5, “Transaction Value Method for Related Persons” (the “Memorandum“), addressing the impact of income tax transfer pricing on the value for duty to be declared on goods imported into Canada. This new guidance will have a… – Continue reading
NAIROBI, Kenya – The World Bank’s private arm, the International Finance Corporation (IFC) has jointly launched a business transparency initiative with the Swiss government, to promote corporate leadership in East Africa with the aim of helping firms attract foreign investments. The aim of the new initiative is to help firms… – Continue reading
India must align domestic laws with international treaties A recent ruling of the Punjab & Haryana High Court (HC) in the Serco BPO case has once again underlined the need for consistency between tax policies and the jurisprudence that evolves around it, thus, leaving little to interpretational hazards. The HC,… – Continue reading
The Department of Justice announced today that Migros Bank AG (Migros) and Graubündner Kantonalbank (Graubündner) have reached resolutions under the department’s Swiss Bank Program. These banks will collectively pay penalties totaling more than $18 million. “It is abundantly clear from the agreements reached to date that for decades, many foreign… – Continue reading
The UK’s tax treatment of US limited liability companies (LLCs) will remain mostly unchanged despite a recent Supreme Court decision in favour of the taxpayer, HM Revenue and Customs (HMRC) has confirmed.25 Sep 2015 HMRC said that the decision of the UK’s highest court in favour of George Anson, a… – Continue reading
The Foreign Account Tax Compliance Act, passed in 2010, is a tool devised to help the U.S. locate funds of U.S. citizens being held in foreign banks. (See this earlier FATCA report on LBN). The law requires foreign banks to report data about accounts owned by U.S. citizens to the… – Continue reading
In 2013, the Organisation for Economic Cooperation and Development (OECD) released a series of proposed tax measures for eliminating corporate tax structures that shift profits to foreign jurisdictions. This corporate tax practice is commonly referred to as base erosion and profit shifting or BEPS. Towards this, the OECD and G20… – Continue reading
The Danish tax authority Skat fired several top officials and was given an emergency lifeline from parliament on Friday after been hammered by scandals in recent weeks that could result in the loss of 14 billion kroner. Denmark hit by potential billion-dollar tax fraud (26 Aug 15) Danes face the… – Continue reading
ATO to force Uber drivers to pay GST Uber is to mount a legal challenge against the Australian Tax Office after a decision to force drivers to register and pay GST. Prime Minister Malcolm Turnbull has praised ride-sharing company Uber as part of the “agile” economy he envisages for Australia…. – Continue reading
Reading companies’ annual reports to the Securities and Exchange Commission is a reliable cure for insomnia. Every so often, though, there is a significant revelation in the paperwork. Last year, one of the most important revelations came from Microsoft’s filings, which spotlighted how the tax code allows corporations to enjoy… – Continue reading
The increasingly international nature of business will lead to complications and disruptions that may plague the future of audit, according to PwC. A recently-released PwC report, Global Tax Transparency and Risk Management – part of the ‘Tax Function of the Future’ series – notes that the number and size of… – Continue reading
TORONTO (miningweekly.com) – The world’s largest precious metals streaming firm Silver Wheaton is set to challenge the Canadian Revenue Agency (CRA) over the agency’s decision to reassess the company’s 2005 to 2010 tax years and collect taxes on income earned by Silver Wheaton’s offshore subsidiaries. The TSX– and NYSE-listed company,… – Continue reading
Thousands of Australians head offshore each year to expand their horizons and a lucky few will fund their adventure by working overseas. Some may live overseas and work for an extended period. There can often be confusion about the tax implications for taxpayers who take advantage of such offshore opportunities…. – Continue reading
The Internal Revenue Service has entered into landmark Competent Authority Agreements with authorities in Australia and the United Kingdom to support the implementation of the Foreign Account Tax Compliance Act (FATCA). The US has signed FATCA intergovernmental agreements with both of these nations. Each of these agreements provides that Competent… – Continue reading
Automatic exchange of information for tax law enforcement purposes started first in Europe with the EU Savings Tax Directive, went international with the US Foreign Accounts Tax Compliance Act, and, from 2017, will go global with the recently-agreed Common Reporting Standard, the subject of this feature. Introduction To The Common… – Continue reading
When Delta, a South Africa-based property investment fund, decided to switch the offshore domicile of its international operations from Bermuda to Mauritius a year ago, it gained unexpected benefits, reports the Financial Times. “We’ve been very pleased,” says Bronwyn Corbett, head of Delta, as she reflects on the success of… – Continue reading
The print media was awash on Tuesday, September 1, 2015 with reports of Gov. Ayo Fayose’s threat that no private school in Ekiti State will be allowed to commence school activities this Session unless it pays a tax of N150,000 and that anybody who buys one cow to be slaughtered… – Continue reading
Content supplied by EY New Zealand is one of only a few countries with a dividend imputation regime. Introduced in 1988, New Zealand’s imputation regime removes double taxation on distributions by attributing to shareholders a credit for the tax borne on profits at the company level. Benefits include a single… – Continue reading
