Category: Canada

FOREIGN WITHHOLDING TAXES: HOW TO ESTIMATE THE HIDDEN TAX DRAG ON U.S. AND INTERNATIONAL EQUITY INDEX FUNDS AND ETFS

Course summary: Justin Bender of PWL Capital and Dan Bortolotti of PWL Advisors explain the ins and outs of foreign withholding tax on U.S. and international equity index funds and ETFs. INTRODUCTION Canadian investors get an enormous benefit from diversifying their portfolios with US and international stocks. But this benefit… – Continue reading

CALL CLIENTS WHO OWN GREEK BONDS

If you have clients who own Greek bonds (government or corporate), they may have immediate tax-filing concerns. A PwC notice explains that investors not resident in Greece who realized gains between February 29, 2012 and December 31, 2013 owe the Greek government 20% in taxes. It’s due June 25, and… – Continue reading

FEDS SHOULD IMPLEMENT FATCA LAW, SAYS IIAC

Ian Russell, president and CEO of the Investment Industry Association of Canada (IIAC), today urged members of the House of Commons Standing Committee on Finance to recommend approval of Bill C-31 at the earliest opportunity, which is necessary to implement the provisions of the United States Foreign Account Tax Compliance… – Continue reading

Don’t delay law for sharing tax information with U.S., Canada’s investment industry urges

The head of Canada’s investment industry association is urging the federal government not to defer legislation that will facilitate handing tax information of U.S. citizens living in Canada to authorities in the United States. Ian Russell, chief executive of the Investment Industry Association of Canada, made his pitch to the… – Continue reading

Costa Rica, 46 countries commit to automatic exchange of tax, financial info

May 7th, 2014 (InsideCostaRica.com) Tax evaders and privacy advocates beware – Costa Rica and 46 other countries signed up yesterday to automatically share banking, financial, and tax information in what the OECD is touting as a major step towards cracking down on global tax evasion. The Declaration on Automatic Exchange… – Continue reading

Canada: Treaty Shopping Proposals – A Review Of 2013 And 2014 Developments

In Budget 2013, the Government announced its intention to consult on possible measures to combat treaty shopping. Eleven months later, in Budget 2014, the Government invited comments on a proposed domestic anti-treaty abuse rule. This article briefly reviews developments arising between the two budgets and provides high level comments in… – Continue reading

KKR’s Entry Into Canadian Oil Patch Crimped by Tax Clampdown

Canada is clamping down on off-shore tax shelters used by private-equity funds, in a move that may curb investment in the oil and gas industry by KKR & Co. and Blackstone Group LP. (BX) The government has given private-equity firms and other interested parties until April 11 to respond to proposals tucked… – Continue reading

FEDS BURY FATCA LAW IN BUDGET BILL

On Friday the Conservative government tabled legislation to implement key elements of this year’s Budget. But it contains more than tax credits. Buried within is a revised version of draft legislation implementing the Intergovernmental Agreement (IGA) with the U.S. on FATCA. A Department of Finance press release makes no mention of this… – Continue reading

Quebecor companies registered in Delaware prompt questions

Québec Solidaire on Saturday asked Pierre Karl Péladeau, the Parti Québécois candidate for Saint-Jérôme, to confirm or deny the registration of more than 60 Quebecor affiliates in Delaware, a state considered by many to be a popular tax haven. Amir Khadir, Québec Solidaire’s candidate in the Montreal riding of Mercier, described Delaware as a known tax haven for… – Continue reading

Black money menace

It would be surprising if Union finance minister P. Chidambaram’s threat to his Swiss counterpart — to declare Switzerland an uncooperative nation for not sharing information on the 562 Indians who allegedly stashed their black money in Swiss banks — is actually carried out. The threat has trade implications. These… – Continue reading

UPDATED: CRA MAY IGNORE FATCA TRUST RULES

Aleaked document appears to reveal the Department of Finance and CRA may deviate from a tax deal struck with the U.S. Leaked by the Isaac Brock Society yesterday, the document purportedly presents the agency’s interpretation of draft legislation which, if passed, would give force to the Intergovernmental Agreement (IGA) on FATCA signed… – Continue reading

Ghana and Denmark sign Double Taxation Agreement

Ghana and Denmark have signed a Double Taxation Agreement, moving the bilateral cooperation between the two countries to another level. A Double Taxation Agreement regulates the tax treatment of income or capital gains in situations where the same taxpayer is subject to tax in two states with respect to the… – Continue reading

Who took advantage of the offshore account “safe harbor” program?

A report by the Government Accounting Office details who took part in the first voluntary disclosure program for offshore accounts. If you made an honest mistake and failed to keep up on international account reporting requirements, it is important to spe March 25, 2014 /24-7PressRelease/ — Congress has been on… – Continue reading

British Virgin Islands: BVI & Canada: Down To business – TIEA Now Effective

The Canada-BVI Tax Information Exchange Agreement (“TIEA”) came into force on 11 March 2014. The TIEA was signed in May 2013, and the effective date provisions are set out in Article 13 of the Agreement. The BVI is now party to 25 TIEAs. What are the benefits? The BVI/Canada TIEA is significant due… – Continue reading

Worldwide: Canada-U.S. FATCA Intergovernmental Agreement

On February 5th, 2014, the Canada signed an intergovernmental agreement (“IGA”) with the U.S. regarding the U.S. Foreign Account Tax Compliance Act (“FATCA”). Under the terms of FATCA, Canadian financial institutions need to report directly to the U.S. Internal Revenue Service (“IRS”) any information regarding bank accounts held by U.S…. – Continue reading

Corporate tax avoidance ‘scheme’ hurting Canada, expert says

Country’s corporate tax rate sits at about 25 per cent As Canadians dutifully file personal income tax returns during the coming weeks, consider this: many profitable companies pay little or no tax. In an interview this week on The Sunday Edition, Dennis Howlett, executive director of Canadians for Tax Fairness,… – Continue reading

Canada: Businesses Face More Onerous Transfer Pricing Documentation And Country-By-Country Tax Reporting

The OECD proposes to reform transfer pricing documentation for multinational enterprises and to impose onerous country-by-country (CbC) reporting obligations, including disclosure of taxes paid in each country in which a business operates, in a bid to enhance revenue authorities’ abilities to identify high risk transfer pricing situations and to make… – Continue reading

Canada’s draft legislation undermines FATCA agreement with U.S.

A prominent tax lawyer says that proposed federal legislation relieving Canadian financial institutions from onerous obligations under the U.S. Foreign Account Tax Compliance Act “eviscerates” an intergovernmental agreement signed between Canada and the U.S. earlier this month. “The U.S. Treasury Department may view the legislation, if passed in its current form, as an… – Continue reading

Pensions Create Yet Another Tax Trap For U.S. Expatriates

Think your taxes are confusing? Ha! Try living and working abroad as a U.S. citizen. As the following guest column details, even something as  seemingly ordinary as participating in a pension plan can create huge tax complications. (For less esoteric advice on preparing your 1040 for 2013 and minimizing your… – Continue reading

FATCA Puts Canada and Costa Rica in the IRS Pockets

As Canadian snowbirds and visitors in Costa Rica were following the performance of their compatriot athletes at the 2014 Winter Olympics in Sochi, their Finance and National Revenue Ministers announced that anintergovernmental agreement with the United States had been reached on the Foreign Account Tax Compliance Act (FATCA) of 2010. What… – Continue reading

BVI and Canada: down to business — TIEA now effective

The Canada-British Virgin Islands (BVI) tax information exchange agreement (TIEA) came into force on 11 March 2014. The TIEA was signed in May 2013, and the effective date provisions are set out in article 13 of the agreement. The BVI is now party to 25 TIEAs. The BVI-Canada TIEA is… – Continue reading

Enforce Canadian law, not FATCA

The Canadian government is bending over backwards, and bending our laws, to allow the U.S. to enforce its new tax compliance act. Canadian visitors to Washington sometimes wonder why their embassy stands at the foot of Capitol Hill. The answer? To be close to where Canada’s laws are made. Case… – Continue reading

Canada: IGA Requires Canadian FFIs To Register On IRS FATCA Portal

As noted in our previous post, the recently signed Inter-Governmental Agreement between the Canada and the U.S. relating to FATCA (the IGA) will modify the FATCA reporting obligations for Canadian financial institutions. Under the IGA, the term “Financial Institution” (or “FI”) includes custodial institutions, depository institutions, investment entities and specified insurance companies. For… – Continue reading

National News: Tax havens must be taken seriously

New Democrat MP Pierre Dionne Labelle (Rivière-du-Nord) has tabled a motion in the House of Commons demanding accountability from Conservatives for their continued failure to bring an end to the billions of dollars lost through tax evasion. “Conservatives have repeatedly demonstrated their gross underestimation of the scope of this multi-billion… – Continue reading

Ortega’s Zara Fashions Tax Avoidance by Shifting Profits to Alps

Zara’s celebrity chic helps make its Spanish parent company, Inditex SA, the world’s biggest fashion retailer. Singer Taylor Swift, reality-television personality Kim Kardashian and Kate Middleton, Prince William’s wife, have all been spotted wearing the stylish, low-cost brand. Another reason for Inditex’s industry-best profit margins of almost 15 percent: the… – Continue reading

Barbados To Expand Double Taxation Network

Barbados’ financial-services sector is rated as the second-largest source of foreign exchange earnings, behind tourism, for which new markets are being sought outside of Canada. On Thursday, central bank governor, Dr DeLisle Worrell, said the country has been losing business in its International Business and Financial Services Sector (IBFS), which… – Continue reading

G20 to tackle transfer pricing with new tax exchange scheme

The days of multinational companies being able to use the Double Irish Dutch Sandwich to avoid taxation may soon be coming to an end, with the G20 group of nations looking to create a reporting standard to allow for automatic exchange of tax information. In the official communique coming at the end… – Continue reading

GAO Report: Where Offshore Tax Evaders Live And Bank

Congress is on a roll, trying to track down hidden offshore accounts, and the latest news is a report that shows which states have the most taxpayers disclosing such accounts (California is No. 1), and where they are located (Switzerland is tops). All told, taxpayers in at least 45 states… – Continue reading

Russians Return to Cyprus, a Favorite Tax Haven

NICOSIA, Cyprus — When the Cypriot government forced bank depositors — many of them Russian — to pay their share of an international bailout last spring, Vasilis Zertalis’s phone started ringing. The companies his consultancy helps incorporate on this breezy Mediterranean island — many of them Russian, too — wanted… – Continue reading

Ambassador Berhane meets the Parliamentary Secretary of Foreign Ministry of Canada

State Minister Ambassador Berhane met on Monday (January 27) with Mr. Deepak Obhrai, Parliamentary Secretary of the Foreign Ministry of Canada. Their discussions focused on strengthening the bilateral relations between Ethiopia and Canada. Mr. Obhrai said he appreciated the growing relationship between the two countries and was looking for additional… – Continue reading