On 21 April 2015, the Danish Parliament adopted a bill, which sets out to deal with certain potential abuses recently encountered by the tax authorities as well as the Danish enactment of the general international anti-abuse initiatives currently considered at EU and OECD level. The new Danish GAAR will take… – Continue reading
MUMBAI: Five Foreign Portfolio Investors (FPIs) on Thursday mainly from the US and the UK have dragged the Indian government and the Income Tax department to the court for levying Minimum Alternate Tax (MAT) on their capital gains for the year 2011-12. The five FPIs — National Westminster Bank Plc,… – Continue reading
With its enviable reputation in offshore trusts, pensions and insurance, Bermuda is an ideal jurisdiction for employers to establish international pension and employee benefit plans (IPPs). Global organisations may consider establishing Bermuda IPPs for employees who work outside their home country or the home country of both the employees and… – Continue reading
The OECD/G20 Base Erosion and Profit Shifting (BEPS) Project is changing the international tax landscape by building a new international consensus on how to tackle BEPS. In September 2014, the first seven of the deliverables under the 15-point BEPS Action Plan were presented to G20 Finance Ministers when they met… – Continue reading
A committee set up by the finance ministry to address industry’s tax concerns has invited trade and industry for talks on the issue. Experts, however, say Finance Minister Arun Jaitley should have in his reply to a debate on the Finance Bill 2015 provided clarity on minimum alternate tax (MAT)… – Continue reading
The game of cat and mouse between tax authorities and citizens has been played for a very long time. People have been dodging taxes for centuries. But the more nuanced and sophisticated game of avoiding tax is a more recent phenomenon. Indeed, when it comes to tax avoidance the game… – Continue reading
Deferring income helped the billionaire hedge fund manager build his fortune George Soros likes to say the rich should pay more taxes. A substantial part of his wealth, though, comes from delaying them. While building a record as one of the world’s greatest investors, the 84-year-old billionaire used a loophole… – Continue reading
Autumn Statement 2014, Budget 2015 and Finance Act 2015 The UK Chancellor delivered his Autumn Statement on 3 December 2014 and his Budget speech on 18 March 2015. For an overview of some of the key announcements, please see our Autumn Statement 2014 briefing and Budget 2015 briefing. The UK’s… – Continue reading
The IRS on Tuesday proposed to amend its regulations so that taxpayers that are subject to withholding under Secs. 1441 through 1443 (chapter 3 of the Code, imposing withholding tax on nonresident aliens, foreign corporations, and foreign exempt organizations) or Secs. 1471 and 1472 (chapter 4 of the Code or… – Continue reading
Athens: Greek authorities arrested one of the most important businessmen in the country, Leonidas Bobolas on Wednesday, for tax evasion. He was released later after paying €1.8 million in back taxes. This is just one of the Greek government’s attempts to collect money from tax evaders. In Greece, income tax… – Continue reading
Ontario’s 2015 Budget, delivered on April 23, overhauled a number of the province’s tax credits and set out plans for a further crackdown on tax avoidance. The Budget made numerous changes to creative tax breaks, effective from April 23, 2015. The Ontario Production Services Tax Credit was reduced from 25… – Continue reading
Although you may be working in China, does the ATO still consider you an Australian resident? It’s just one of the things you need to get absolutely right. The tax requirements for Aussies working overseas vary from region to region. Aussies working in Hong Kong will find last month’s tax… – Continue reading
India’s rupee rose for a second day as the dollar weakened and global funds resumed purchases of local bonds after the government sought to clear uncertainties over a retrospective tax on capital gains. Overseas funds bought a net $130 million of local-currency notes on April 24, the latest figures show,… – Continue reading
Last September, the US Treasury Department announced new tax rules designed to crack down on the rising trend of “tax-inversion” deals in the pharmaceutical industry, as an increasing number of US firms had begun to pursue overseas acquisitions in attempts to relocate their legal addresses to non-US based headquarters to… – Continue reading
NEW DELHI: India may set up a panel to resolve legacy tax cases that have revived allegations of ‘tax terrorism’, making it difficult for the government to meet its pledge to boost investor sentiment. “I am considering a high-level committee to explore what can be done to resolve the past,… – Continue reading
Section 55 of the Income Tax Act (Canada) (the “Tax Act”) contains an anti-avoidance rule that prevents a corporation from converting what would otherwise be a taxable capital gain into a tax-free intercorporate dividend. Section 55 deems a dividend not to be a dividend, but rather a capital gain, where… – Continue reading
In brief: At the recent G20 meeting in Washington, Treasurer Joe Hockey announced the establishment of a working group between Australia and the UK to develop initiatives to address so-called diverted profits involving multinational enterprises. What are the implications for multinationals doing business in Australia? Partner Martin Fry (view CV)… – Continue reading
An OECD initiative on tax evasion is causing ripples around the world While a host of topics — from the necessity and the proposed scope of corporate tax reform, to corporate rate reduction and corporate inversions — are of major concern to those engaged in international tax, the overriding issue… – Continue reading
Yesterday afternoon, the Canadian government tabled the 2015 Canadian Federal Budget. Two measures are particularly relevant to certain employers. Withholding Relief for Non-Resident Employers and Employees To take effect next year (if the measure is enacted), Budget 2015 proposes an exemption from certain withholding requirements on payments from “qualifying non-resident… – Continue reading
NEW YORK — Introduced in the 1920s to ease the tax burden of farmers who wanted to swap property, it soon became a tool for real estate investors flipping, say, office buildings for shopping malls. Now, this little-known provision in the tax code, known as a like-kind exchange, has become… – Continue reading
With the Transcontinental Trusts Bermuda Forum taking place next week, it is timely to reflect on some of the attractive features and structuring alternatives that Bermuda’s trusts and related law provides and to consider some recent exciting developments. Bermuda provides a flexible, cost effective regime for the formation and administration… – Continue reading
Americans have overcome oligarchy before — and there’s no reason we can’t do it again. Rising inequality seems to pose an insurmountable political problem. If the underlying causes are technological change and globalization, the forces appear to be unstoppable. Alternatively, if the causes are primarily political and involve the power… – Continue reading
THE REVENUE Commissioner’s large cases division is investigating almost 100 schemes it suspects were designed by companies and wealthy individuals to avoid paying capital gains tax. The taxman is enquiring into 89 cases which used sophisticated financial instruments known as contracts for difference to generate artificial losses. The schemes avoided… – Continue reading
Lahore – Pakistan Tanners Association has said that exporters are paying full tax to the government and there is no chance of evasion of income tax on exports. “Exporters, whether making profit or loss, will have to pay 1% income tax on the value of each export consignment while 1%… – Continue reading
Benchmarks are poised just above their 200-day moving average — a long-term support April 25, 2015: Both the Sensex and the Nifty are very tantalizingly poised just above a long-term support level. This adds zing to next week’s trading that is expected to be full of action thanks to the… – Continue reading
Mumbai, April 25 (IANS): The capital gains tax claims on foreign funds with retrospective effect and worries over similar notices ahead hit the marked mood during the week ended Friday, sending a key index down to its lowest level in three-and-a-half months. The mixed corporate results for the last quarter… – Continue reading
FPIs are battling it out with the income-tax department, which has issued notices demanding that they pay MAT to the tune of Rs40,000 crore New Delhi/Mumbai: Despite the government affirming that foreign portfolio investors (FPIs) can use tax treaties to fight tax demands on past capital gains, a majority of… – Continue reading
However, OECD being persuasive may not help funds based out of nations whose treaties do not give specific exemption The Indian government’s clarification that it would honour tax treaties while making a demand of Minimum Alternate Tax (MAT) at the effective rate of 20 per cent came as a relief… – Continue reading
Britons overseas are now subject to CGT when selling UK properties, but this straightforward advice could help minimise the impact Expats who have kept a house or flat in Britain need to act now to avoid being stung by a hefty capital gains tax (CGT) bill in the future. Since… – Continue reading
Tax evasion overseas has been further targeted by authorities as HM Revenue and Customs (HMRC) implements tougher penalties for those who hide assets and income abroad. The maximum penalty for offshore evasion of income and capital gains tax has doubled to 200 per cent of the tax due, but can… – Continue reading
Investment vehicles set up by Paulson & Co. and Highbridge Capital Management in tax-friendly Bermuda may be under threat from the U.S. Internal Revenue Service. The IRS, in proposed rules published Thursday, said that the favorable treatment enjoyed by insurers under the tax code shouldn’t extend to companies that borrow… – Continue reading
A property investment company does not believe its advert selling Auckland property as a cash cow for offshore landlords is exploiting New Zealanders. The radio advert has been on air in Singapore since Monday for Property Solutions Singapore, which is a subsidiary of Dunedin-based company Australian Property Solutions. It said… – Continue reading
The government on Wednesday assured over 1,000 foreign institutional investors (FIIs) across the United States, Hong Kong and Singapore they can avail of treaty benefits to ward off tax demands on capital gains booked over the years till March 31, reports the Financial Express. The development is significant given the… – Continue reading
1 General news 1.1 HMRC organisation chart HMRC has published its latest organisation chart showing the names of senior management. One point to note is the number of senior people now in roles such as change management as opposed to being in pure technical roles. This clearly demonstrates the direction… – Continue reading
The Minister of Finance (Canada), the Honourable Joe Oliver, presented the Government of Canada’s 2015 Federal Budget (“Budget 2015”) on April 21, 2015 (“Budget Day”). Budget 2015 contains several significant proposals to amend the Income Tax Act (Canada) (the “ITA”) while also providing updates on previously announced tax measures and… – Continue reading
Minister of Finance Joe Oliver today tabled the 2015 Federal Budget (the “Budget”), his first budget as Minister of Finance, entitled “Strong Leadership: A Balanced-Budget, Low-Tax Plan for Jobs, Growth and Security”. We are pleased to provide our summary of tax measures contained in the Budget. The Budget proposed no… – Continue reading
As has been widely predicted, today’s federal budget (Budget 2015) delivered a handful of tax “goodies” in the lead-up to the coming election. It also includes a number of important proposed changes to the corporate tax rules. They are noteworthy, although not as extensive as the corporate tax changes proposed… – Continue reading
San Francisco, California – The United States filed a complaint to bar a San Francisco enrolled agent and tax return preparer from implementing, facilitating and promoting allegedly abusive tax shelters and tax avoidance schemes, the Justice Department announced today. According to the complaint, which was filed in the U.S. District… – Continue reading
Finance Minister Joe Oliver faced formidable challenges, both economic and political, in delivering his first Budget. In a time of depressed oil prices, and mere months ahead of the next federal election, it appears he felt it was imperative to follow through with prior commitments to balance the budget, provide… – Continue reading
1. NON-TAX ISSUES 1.1 Domestic law 1.1.1 Briefly describe your legal system and its origins The legal system of the Republic of Ireland is a common law system. In order to ensure consistency, a legal principle developed whereby courts were generally required to follow earlier relevant decisions. This doctrine of… – Continue reading
India said foreign portfolio investors can use tax treaties to reject demands on past capital gains, seeking to defuse a row that cast a cloud over the $48 billion poured into stocks and bonds from overseas. Foreign institutional investors domiciled in countries that have signed double taxation avoidance treaties with… – Continue reading
TL: What are the main considerations and advantages for doing business in Malta? AB: Malta’s positive approach to business promotion, development and standard of living within the EU makes the island a destination of choice for relocation of business purposes. Malta offers noteworthy benefits to individuals and investors who are… – Continue reading
Dinesh Kanabar, CEO, Dhruva Advisors explains that there are three kinds of FIIs: protected by double taxation avoidance treaty, no treaty but physical presence in India, and no treaty and no presence in India. So far notices have been sent only to the second category of investors. Minimum alternate tax… – Continue reading
The Finance Minister has failed to assuage markets’ fears on the issue of retrospective tax Markets are getting jittery each time the finance minister or his ministry utters the T word. Finance Minister Arun Jaitley reminds the market of UPA’s finance minister Pranab Mukherjee, who introduced the now-dreaded retrospective tax…. – Continue reading
NEW DELHI: Tax authorities have issued a fresh notice to UK-based telecom giant Vodafone seeking reassessment of tax returns for two years. The notice has been served under Section 148 of the Income Tax Act which seeks to deal with income that has escaped assessment. Sources said the notice seeks… – Continue reading
Why Does Residency Status Matter? An Ohio resident must pay Ohio income tax on his or her worldwide income (including investment income (i.e., dividends, capital gains etc.) and pass-through income from LLCs and S corporations with operations outside of Ohio), subject to credits for taxes paid in other jurisdictions. A… – Continue reading
CHINA Tax Free Reorganisations • With circulars 109 and 116 jointly issued in December 2014 by the Ministry of Finance and the State Administration of Taxation, the Chinese authorities have relaxed the conditions for internal reorganisations. • Circular 109 deals with internal reorganisations. Provided the pertinent requirements are met, the… – Continue reading
India and China developing frameworks for Reits but while their sheer sizes impress, both face tax and high interest rate hurdles, reports the Business Times. India and China are both developing frameworks for real estate investment trusts (Reits), but the threat to Singapore’s position as a major regional Reit centre… – Continue reading
NEW DELHI: Tax authorities have issued a fresh notice to UK-based telecom giant Vodafone seeking reassessment of tax returns for two years. The notice has been served under Section 148 of the Income Tax Act which seeks to deal with income that has escaped assessment. Sources said the notice seeks… – Continue reading
To balance the books, Australians will have to pay more tax, the only questions being what will be taxed and how high the rate. Boasting glittering skyscrapers and label-clad youth, Singapore is the new jewel in the capitalist world’s crown. The city state is home to the third-highest density of… – Continue reading
