Category: Withholding tax rules

Effects of (FATCA) on U.S. Citizens make Wyoming Asset Protection a Rival to Offshore Tax-Havens

CHEYENNE, WY, April 17, 2015 /24-7PressRelease/ — OUTPOST PROVISIONING LLC today announced the launch of its “Wyoming…the Offshore Alternative” campaign alongside release of its Wyoming Paymaster Purpose Trust product. “Wyoming…The Offshore Alternative” touts Wyoming as being the Offshore-equivalent for wealth protection without the inconvenience, scrutiny, compliance costs and risks involved… – Continue reading

Foreign Investors and India’s Tax Men Are Clashing Anew: Q&A

Nothing is certain in India except death and tax disputes. Ask foreign portfolio investors: they now face demands for past dues of as much as $6.4 billion. The wrangle stems from the Minimum Alternative Tax, or MAT, which officials say leads to a 20 percent levy on capital gains by… – Continue reading

Cyprus: Cyprus’s New Double Taxation Agreement With Bahrain

On 17 March 2015 Cyprus and Bahrain signed a new double taxation agreement. Like all of Cyprus’s recent DTAs it closely follows the 2010 OECD Model Tax Convention. Its main provisions are summarised below. Taxes covered The agreement applies to taxes on income imposed by either country. In Bahrain these… – Continue reading

Jaitley promises 'modern tax system'

“Tax policy and administration should incentivise compliance. They should be administered fairly, transparently, with minimum discretion, with no harassment of taxpayers but also ensuring that tax evasion is dealt with firmly.” Promising a ‘modern tax system’ with low and globally competitive rates, Finance Minister Arun Jaitley has assured foreign investors… – Continue reading

Studies show, Congress Favors the Rich

When Hillary Clinton recently borrowed Elizabeth Warren’s talking points and claimed “the deck is still stacked in favor of those at the top” (in our economic and political system) against regular working people, did she mention reforming the tax code — and then offer any solutions? The simple answer is… – Continue reading

Capital Gains Tax changes could spell trouble for expats owning UK property

Foreign owners of UK property assets are being advised to seek property valuations to avoid falling foul of changes to Capital Gains Tax, writes David Westgate – Managing Director, Andrews Letting & Management CHANGES to Capital Gains Tax for UK property investors based overseas were first announced by George Osborne… – Continue reading

India $6.4 Billion Back-Tax Claim Fails to Dent Foreign Inflows

As foreign portfolio investors balk at India’s claim of $6.4 billion in back taxes, the finance ministry’s latest demand isn’t damping interest in the nation’s stocks and bonds. Foreigners were net buyers of local equities every day barring one since the finance ministry said April 6 it is well within… – Continue reading

Germany-France cross border real estate transactions may need to be restructured, say experts

Cross border transactions involving German entities investing in French real estate may need to be restructured as a result of proposed changes to the France/Germany double tax treaty, according to two experts. French tax expert Franck Lagorce and German tax expert Werner Geisselmeier, both of Pinsent Masons, the law firm… – Continue reading

Supreme Court rejects appeal against transfer of Vodafone Essar Gujarat’s assets

In a major relief to Vodafone, the Supreme Court on Wednesday rejected the income tax department’s appeal challenging Vodafone Essar Gujarat’s transfer of certain passive assets to Vodafone Essar Infrastructure. However, it said that the department is free to raise tax demand under relevant tax laws but can’t block the… – Continue reading

Twenty-eight English clubs are now owned overseas, increasing the risk of tax avoidance

Research by the Guardian and the Tax Justice Network reveals 28 English clubs with substantial shareholdings overseas, opening up the football leagues to criticism for allowing ownership structures that could be used for tax avoidance Almost one in three of the 92 Premier and Football League clubs are now substantially… – Continue reading

Canada: Private Client Tax, Third Edition – Chapter: Canada

1. NON-TAX ISSUES 1.1 Domestic law 1.1.1 Briefly describe your legal system and its origins Canada is a federal state, with legislative powers divided between the federal and provincial governments. The federal government has legislative jurisdiction over issues concerning Canada as a whole, including foreign affairs, international trade, banking, telecommunications,… – Continue reading

New tax treaty between Hong Kong and mainland China which has consequences for shipping, airline and securities trading companies

This is relevant mainly for (1) Hong Kong companies or investment funds selling securities in Chinese listed companies and (2) ship or aircraft leasing companies resident in Hong Kong who (finance) lease vessels and aircraft to lessees in mainland China. On 1 April 2015, Hong Kong and mainland China signed… – Continue reading

Tax terrorism versus tax haven

The key is to arrive at a Goldilocks mean — rolling out tax-friendly policies while being firm with incorrigible offenders A phrase first used by Prime Minister Narendra Modi while addressing a group of businessmen in the run-up to the elections last year has now come back to haunt his… – Continue reading

France: French Tax Update – Early 2015 Noteworthy Case Law And Tax Transparency Package

The present French Tax Update will focus on (i) several noteworthy French and European Union court decisions issued in the last months of 2014 and in the first months of 2015, and (ii) the recent presentation by the European Commission of a package of tax transparency measures. VALIDITY OF TAX… – Continue reading

Ireland’s tax exiles now number over 3,000

Revenue figures show that just 13 people paid domicile levy of €200,000 in 2013 Ireland is home to more than 3,000 individuals or couples recognised as ‘non-domiciled’ for tax purposes, new figures from the Revenue Commissioners show. So-called “non-doms” can avoid paying tax on their worldwide income in Ireland, thus… – Continue reading

Cheers greet proposed changes for managed investment trusts

Proposed changes to Australia’s managed investment trust regime have been met with cheers from the investment community as they welcome the boost in certainty and tax treatments. The government revealed the long-awaited changes to Australia’s MIT tax system on Tuesday, and expects to create a new standalone regime that will… – Continue reading

Seaton sponsors income tax bill

• “Budget deficit calls for combination of cuts, and contributions,” says Seaton This week Republican Representative Paul Seaton, R-Homer, introduced a bill that would impose an income tax on residents and non-residents deriving an income source from within the state of Alaska. Proposed as a diversification strategy, Seaton said that… – Continue reading

Extending dividend benefits to foreign investors may address competition concerns

The Federal Government has floated the idea of lowering the corporate tax rate – arguing the current rate of 30% is not internationally competitive. The rationale is that globalisation makes capital perfectly mobile and the marginal non-resident investor in Australian companies will go where corporate tax rates are lowest. At… – Continue reading

Art: A market laid bare

An arrest over allegations of price fixing has increased calls for tighter regulation of the booming sector On a late February morning, Yves Bouvier arrived at the Monaco home of one of his best clients. He expected Dmitry Rybolovlev, the Russian billionaire owner of AS Monaco football club, to pay… – Continue reading

Rand Paul’s Record Shows He’s a Champion for Tax Cheats and the Wealthy

No member of Congress has been more active in the cause of protecting tax cheaters and tax avoidance by our nation’s wealthiest individuals and corporations than Sen.(now presidential candidate) Rand Paul. While Paul is a standard bearer of anti-tax conservatives through his advocacy of radical policies such as the flat… – Continue reading

Ways to ensure a great divide

To reduce the growing urban sprawl most levels of government are allowing higher density housing in the suburbs. This means people with larger residential blocks are presented with an opportunity to subdivide and increase the value of their home. However if the correct steps are not taken when subdividing a… – Continue reading

OECD discussion draft considers Controlled Foreign Corporation Rules

On April 3, 2015, as part of its Action Plan on Base Erosion and Profit Shifting (BEPS), the OECD released a discussion draft entitled “BEPS Action 3: Strengthening CFC Rules” (the Draft) for comments. The Draft stresses the importance of CFC rules in countering base erosion and profit shifting, and… – Continue reading

India sends out nearly $6-billion worth of tax notices to foreign funds

Till March 31, close to 100 FIIs got notices from the Tax Department for a controversial Minimum Alternate Tax (MAT) of 20 per cent, while they are now being followed up with Assessment Orders. In the biggest-ever tax demand slapped on them, nearly 100 foreign funds have been asked to… – Continue reading

The outlook for BEPS in 2015

National tax laws are struggling to keep pace with the rise of the digital economy and the progress of multinational companies. These factors leave gaps that are susceptible to misuse and lead to cases of double non-taxation, which undermine the integrity and fairness of tax systems around the world. The… – Continue reading

100 foreign funds get tax demands; total bill may hit $10 bn

New Delhi/Mumbai: In the biggest-ever tax demand slapped on them, nearly 100 foreign funds have been asked to cough up an estimated USD 5-6 billion for ‘untaxed gains’ made by them in the Indian markets over the past years. The number of affected investors can rise substantially as assessments are… – Continue reading

HMRC Welcomes Three New Anti-Avoidance Victories

The UK’s Upper Tribunal has ruled in HM Revenue and Customs’s (HMRC’s) favor in three tax avoidance cases. The Department said that the judgments protected over GBP260m (USD385m) in tax. All three rulings upheld earlier First-Tier Tribunal judgments in HMRC’s favor. In one case, the Upper Tribunal dismissed an appeal… – Continue reading

China ‘Through-Train’ Ends Double Taxation For Equity Investors

The Shanghai-Hong Kong Stock Exchange Connected is working out its kinks and investors are taking notice. Hong Kong and Beijing signed a tax treaty on Thursday that ends double taxation for equity traders, which was one of the sticking points for local brokers hoping to buy into China’s massive mainland… – Continue reading

OECD launches tax avoidance mandatory disclosure plan

AS PART of its Base Erosion and Profit Shifting (BEPS) project, the OECD has launched a public consultation on Action 12 – the mandatory disclosure of tax avoidance strategies by multinational companies. The 83-page draft document provides examples of various disclosure regimes in place in member countries, setting out recommendations… – Continue reading

Around the World, America’s Taxman Cometh by way of the Foreign Account Tax Compliance Act (FATCA)

As Tax Day approaches, homeland Americans scurry to file their annual tax filing obligations. But for an estimated 7.6 million Americans working and living overseas, they have an obligation to not only pay taxes in their respective countries where they live; they need to pay the piper in homeland America… – Continue reading

Cash-flush corporations at center of income-tax debate

U.S. multinationals represent the healthiest segment of the economy, with higher profits and more than $1 trillion of cash on hand. This has kept corporate tax reform alive as a political issue. ON Semiconductor had a solid 2014, boosting net income by 36 percent to $196 million on revenue of… – Continue reading

Aussies working in Hong Kong should avoid these tax traps

Australians working in Hong Kong should be aware of the various complexities that affect their residency, super and tax status. Going overseas to work is a grand adventure for many professionals. But the way income earned outside your home country is taxed is a complex area, and it’s worth seeking… – Continue reading

UK tax rules on disguised investment management fees: final legislation published

The UK’s Finance Bill was published on 24 March 2015. It was subsequently enacted on 26 March 2015 without further amendment and became the Finance Act 2015. The “disguised investment management fee” provisions contained in this Act, summarised below, will be effective from 6 April 2015. These rules apply to… – Continue reading

Dividend imputation clears an early tax review hurdle

Government questions dividend imputation and company tax rate Australian investors appear to have dodged a bullet, with the government’s first paper on tax reform discussing the dividend imputation system but falling short of attacking it outright as an idea that has outlived its usefulness. David Murray’s inquiry into the Australian… – Continue reading