Category: Canada

The ultimate pension freedom: Retire in Portugal and reduce your tax

New freedoms mean you can move your pension abroad. We show you where you’ll pay the least tax It is the ultimate dream for many people – to work hard, build up a nest egg and retire abroad to a climate with year-round sunshine. Now there is an added financial… – 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

No hiding place for expat tax evaders

New rules mean that almost 100 governments around the world will exchange information about bank accounts Expat tax dodgers are running out of places to hide, as information about their bank accounts and assets will soon be exchanged between 93 governments globally. At present, if tax authorities suspect people of… – Continue reading

$32 Trillion Stashed in Offshore Bank Accounts – Asset Protection Planners Examine the Facts

More and more Americans are opening offshore bank accounts. This article provides statistical details about why this is so, that offshore banking can be safe and legal and which banking jurisdictions are safest. Apr. 3, 2015 / PRZen / VALENCIA, Calif. — Offshore banking is growing in leaps and bounds… – Continue reading

Global Tax Transparency Goes Live in 2016

Cross border tax fraud and tax evasion by High Net Wealth Individuals (HNWI) are serious problems for many jurisdictions. For many years exchange of information between countries has been solely upon request. In practise this procedure is not efficiently working as it requires foreseeable relevance, thus ‘fishing’ for information is… – Continue reading

Netherlands: Record Rate Of Foreign Investment For The Netherlands

The US and Canada are fuelling a record influx of foreign investment in the Netherlands; our local expert looks at why Despite a fair bit of doom and gloom over global economy figures, foreign companies continue to grow – and they continue to look at the Netherlands to help fuel… – Continue reading

RBC’s Bahama unit caught up in allegations involving billionaire art dealer

Royal Bank of Canada’s wealth-management subsidiary in the Bahamas is caught up in tax fraud and money-laundering allegations involving billionaire international art dealer Guy Wildenstein. French prosecutor Franck Charon confirmed on Monday that France’s tax-evasion watchdog – Parquet national financer – has recommended to an investigating judge that RBC Trust… – Continue reading

Eldorado Gold faces accusations of tax avoidance in Greece

Canada’s Eldorado Gold Corp., the biggest foreign investor in Greece, is engaged in a tax-avoidance scheme that uses mailbox companies in the Netherlands to lower its tax load, a new report from a Dutch foundation says. The Centre for Research on Multinational Corporations, known as SOMO, made the claim in… – 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

Luxembourg: Luxembourg’s Direct Tax Administration Publishes Circular On Residency Certificates For Funds

Luxembourg’s Direct Tax Administration has published a circular on February 12 clarifying issues relating to residency certificates for Luxembourg funds. These are applicable to both UCITS and non-UCITS funds regulated by Luxembourg’s investment fund legislation of December 17, 2010, which transposed the UCITS IV Directive, as well as Specialised Investment… – Continue reading

Higher corporate tax rates worked in B.C., critics say

If the right-of-centre British Columbia government can raise its corporate tax rate, how about Alberta? That’s a question critics are asking in the wake of the spring budget that hits ordinary Albertans with a plethora of new taxes. Premier Jim Prentice is defending his decision not to raise Alberta’s corporate… – Continue reading

Zimbabwe: Diamond Miners On Looting Spree

DIAMOND mining companies operating in Zimbabwe’s Marange diamond fields are reportedly on a last minute looting spree ahead of a loathed mandatory consolidation exercise. As government peruses through various consolidation proposals submitted by seven companies operating in Marange and prepares for an audit, miners are reportedly exploiting the existing loopholes… – Continue reading

UPDATE 1-Leaked Pacific trade pact draft shows investment carve-outs sought

(Reuters) – Australia’s medicine subsidies, Canadian films and culture, and capital controls in Chile would be carved out from investment protection rules being negotiated in a Pacific trade pact, according to a draft text released by Wikileaks on Wednesday. An investment chapter, dated Jan. 20, from the 12-nation Trans-Pacific Partnership… – Continue reading

FATCA reporting: who and what

Introduction Every non-US entity has FATCA status Passive NFFEs report substantial US owners Trustee of trust or its sponsoring entity will report US persons Other reporting FFIs in structure will carry out FATCA due diligence Reporting when US account holders are identified Enforcement Comment Introduction The policy statement in the… – Continue reading

Real estate tax: One million American citizens in Canada face double tax troubles

Owning real property on both sides of the border can create a confusing tax situation. Consider this example. Stefan and Jane are married and live in Vancouver. Jane is a Canadian citizen while Stefan holds both U.S. and Canadian citizenship. In 1994, shortly after getting married, they bought a house… – Continue reading

Valeant Pharma raises bid for Salix

NEW YORK — Faced with the prospect of letting another deal slip through its fingers, Valeant Pharmaceuticals International substantially increased its bid for Salix Pharmaceuticals on Monday, putting a quick end to a bidding war with Endo International. Valeant said it would now pay about $11bn, or $173 a share,… – Continue reading

Calgary men guilty of defrauding feds of $14 million in RRSP scam

Two Calgary men have been convicted of defrauding the federal government of $14.1 million in taxes that should have been paid on registered retirement plans, in which the money was used for offshore investments. Steven Kendall and Christopher Houston were found guilty on Wednesday on one of four charges by… – Continue reading

Erin Go Bragh! American Companies See Green in Ireland

Irish eyes are smiling in corporate America. The Emerald Isle has emerged as the world’s top recipient of U.S. foreign direct investment, according to a report from the American Chamber of Commerce Ireland. In the first nine months of 2014, Ireland beat the likes of Canada, Mexico, the U.K. and… – Continue reading

Key says Government looking at unilateral consumption tax on online purchases from offshore sites; also looking at making online retailers register for GST

John Key has thrown his weight behind moves to catch more online purchases and even digital downloads in the GST net, and Labour says it would support changes to close the online revenue loophole. New Zealand is part of an OECD working group looking at the issue of consumption taxes… – Continue reading

Tax Inversion Restrictions Trigger Foreign Takeovers Of US Companies: Report

The U.S. government’s efforts to collect taxes on American corporations’ overseas earnings that have been shielded by so-called tax inversions may have backfired, triggering a wave of foreign takeovers of American firms, according to a report published Sunday in the Financial Times. To reduce taxes on foreign earnings, corporations based… – Continue reading

Rio Tinto says work to combat base erosion, profit shifting and tax avoidance could go too far and discriminate against multinational companies

Rio Tinto has warned that multinational companies could be discriminated against if moves to combat tax “base erosion and profit shifting” went too far. With Australia and the other 33 member nations of the Organisation for Economic Co-operation and Development ramping up efforts to prevent multinational companies avoiding tax, Rio… – Continue reading

Union whistleblowers spark OPPA fraud investigation in Barrie

Martin McNamara had his suspicions. An OPP officer and executive officer of the provincial force’s union, McNamara was the first to complain to authorities about unusual financial transactions involving the union’s top brass. When McNamara, who had signing authority for the 6,000-member union, was asked to authorize a $5,000 cheque… – Continue reading

Transfer pricing customs duty refund applications – let’s do it right

The Canada Border Services Agency (CBSA) has informed the Canadian importing community that importers may be entitled to obtain customs duty refunds in connection with downward transfer pricing adjustments having the effect of correcting/reducing invoiced prices that served as the basis of customs valuation of imported goods. On January 19,… – Continue reading

Canada: Case Study: Temporary Assignment Of An Employee From Canada To The United States

This article is the first in a series of four parts that will examine the Canadian and U.S. income tax implications when an employee employed by a Canadian entity is assigned temporarily to work in the U.S. This first article focuses on the importance of the determination of “residency” for… – Continue reading

Barbados Gov’t moving to close loopholes on tax evasion

BRIDGETOWN, Barbados (CMC) – The Barbados Government says it will not tolerate businesses operating within the international business and financial services sector engaging in tax evasion practices here and is seeking support from the Paris-based Organization for Economic Cooperation and Development (OECD). Commerce Minister Donville Inniss, speaking in Parliament Tuesday,… – Continue reading

GUEST COLUMN: Protect your investments

Many business owners have substantial personal assets invested in their business. This can have significant implications, not only for you and your business, but also for your family’s financial security. To protect your investment, both business and personal, your business strategy should include carefully structured tax-planning components to ensure you… – Continue reading

It’s time to choose what kind of tax system we want

The Conversation Five years ago the Henry Review undertook a detailed examination of Australia’s tax and transfer system. Today, the Tax and Transfer Policy Institute at ANU’s Crawford School has revisited the Henry Review, as the Australian government prepares to release its tax white paper. Tax reform should not be… – Continue reading

Refund Management Services, Canada’s Leading U.S. Gaming Tax Recovery Service, Weighs in on Report: U.S. Tourism to See Boom in Overseas Visitors

Refund Management Services (http://www.RefundManagement.com), the number-one choice for Canada’s biggest winners for U.S. gaming and casino tax refunds, is weighing in on a recent report showing international travel and tourism-related activities within the U.S. increased in November. Refund Management Services is also commenting on how, despite the strong dollar, U.S…. – Continue reading

CRA Releases Important Transfer Pricing Guidance on Management Fees and Other Intra-Group Services

CRA recently released a new Transfer Pricing Memorandum (TPM-15) giving detailed guidance on CRA’s audit approach to management fees and other charges for intra-group services, including on allocation keys for indirect chargebacks and markups on costs. The document expands considerably upon brief guidance on this topic in CRA’s main Information… – Continue reading

Alberta online bank first in Canada to shun U.S. clients amid tax rules

An Alberta online bank is believed to be the first Canadian financial institution to deny service to Americans, citing the burden of complying with strict new U.S. tax rules. Canadian Direct Financial, a subsidiary of Edmonton-based Canadian Western Bank, is refusing to open new Internet accounts for U.S. citizens, even… – Continue reading

2 Investments to Avoid in Your IRA

IRA plans can be excellent ways to save for retirement, but there are some investments to avoid if you want to take full advantage of IRA tax savings. Two that come immediately to mind are tax-exempt municipal bonds and high-yielding stocks from foreign countries with dividend withholding taxes. Tax-exempt municipal… – Continue reading

For Bigger Bank Dividends, It Could Pay to Go International

Following the financial crisis, dividend yields from American banks have remained below the level many income investors are looking for. While all four major American banks yield less than 3%, U.S. investors can still get fat bank dividends by looking abroad. The United Kingdom London has long been a financial… – Continue reading

Vern Krishna: Corporate barons vote with their feet

The abolition of unfair taxes was one of the foundational principles of Magna Carta, a document that King John assented to on June 15, 1215 at Runnymede, England. Taxation must be fair, and requires the consent of the people. There is no more unfair aspect of fiscal law than retroactive… – Continue reading

Treaty shopping and BEPS considerations in the M&A context

Every acquisition requires careful tax planning early on in the process, especially when dealing with cross border acquisitions. One important consideration when a foreign company plans to acquire a Canadian company is the impact of any tax treaties that currently exist between the two jurisdictions. Tax treaties effectively reduce tax… – Continue reading

BDA boss Webber responds to Miliband threat

Bermuda’s well-documented financial services regulation, international partnership treaties, and lack of bank secrecy legislation ought to be recognised by the UK Labour Party, the Bermuda Business Development Agency (BDA) said today. The BDA echoed the Bermuda Government’s weekend response to UK Opposition Leader Ed Miliband following a warning letter issued… – Continue reading

IRS Focus: Offshore Tax Evasion Tops Dirty Dozen List

The IRS issued two New Releases this week that restate its focus on offshore tax evasion.  The first was January 29, 2015 which followed the First International Criminal Tax Symposium. “The Internal Revenue Service Criminal Investigation Division (IRS-CI) and Her Majesty’s Revenue & Customs (HMRC) co-hosted a three-day International Criminal… – Continue reading

The era of offshore bank secrecy is dead

Almost every day brings new evidence that the era of bank secrecy for tax evaders using Swiss and “offshore” bank accounts in “tax havens” is over. Both tax authorities and banks are clamping down on unreported offshore accounts. Early in 2014, Swiss bank Credit Suisse agreed to pay fines of… – Continue reading