OTTAWA – The federal revenue agency has written off at least $4 billion in debts in the last two years — including accounts worth more than $10 million, newly released records show. Debts were declared uncollectible because those owing had died, gone bankrupt, could not be located or lived outside… – Continue reading
As many of our readers know, the Canadian Income Tax Act (the “Act”) provides for an unlimited exemption from the imposition of Canadian income tax on the gains resulting from a disposition of a “principal residence”. Access to the principal residence exemption can be valuable, especially in cities (e.g. Vancouver,… – Continue reading
10/07/2015 – The OECD set out a clear path for Lithuania’s accession to the Organisation, reinforcing the OECD’s commitment to further extend its global membership. On 8 July 2015 the 34 OECD Members adopted the Roadmap for the Accession of Lithuania to the OECD Convention setting out the terms, conditions… – Continue reading
Remuneration paid for employment services performed in Canada (even for short-term assignments) by non-resident employees is subject to Canadian income tax withholding, remittance and reporting requirements under subsection 153(1) and regulation 102 (Reg. 102) of the Income Tax Act (Canada) (Act). On April 21, 2015, Finance Minister Joe Oliver tabled… – Continue reading
Silver streaming company Silver Wheaton Corp said it received a proposal from the Canada Revenue Agency (CRA) on Monday to reassess the company under various income tax rules. The CRA is seeking to tax streaming income earned by the company’s foreign units and said that Silver Wheaton’s taxable income should… – Continue reading
Against a backdrop of slowing economic growth at home, Canadian companies are actively looking to expand in markets such as the United States, China and Mexico, says Simon Cooper, chief executive of global commercial banking at HSBC Bank Plc. “In Canada, from the companies I’m talking to about how they’re… – Continue reading
Concerns have been raised that there is an anomaly in the Canadian overseas pension schemes system, as under Canadian law savers are allowed to encash them at any age, irrespective of the UK’s pension age test, reports the FT Adviser. HM Revenue and Customs’ pension age test requires schemes to… – Continue reading
HMRC has delisted thousands of overseas schemes that could previously accept pension transfers from Britain HM Revenue and Customs has launched a crackdown on overseas schemes open to UK expats who want to move their pension abroad, with hundreds being removed from its approved list. Australia is one of the… – Continue reading
VANCOUVER, July 6, 2015 /PRNewswire/ – Silver Wheaton Corp. (“Silver Wheaton” or the “Company”) (TSX:SLW) (NYSE: SLW) announces that it has received a proposal letter dated July 6, 2015 (the “Proposal”) from the Canada Revenue Agency (the “CRA”) in which the CRA is proposing to reassess Silver Wheaton under various… – Continue reading
On June 24, 2015, the World Customs Organization (WCO) published the WCO Guide to Customs Valuation and Transfer Pricing (the Guide). The primary purpose of the Guide is to assist customs officials in understanding the relationship between customs valuation and transfer pricing. However, the WCO also recommends members of the… – Continue reading
New Zealand-Canada double tax agreement to help investors WELLINGTON, July 2 (Xinhua) — A new double tax agreement between New Zealand and Canada is set to facilitate investment and trade between the two nations, Revenue Minister Todd McClay said Thursday. The new agreement will lower withholding taxes on dividends, interest… – Continue reading
Legal and General has offloaded its Dublin-based offshore business, L&G International, to Canada Life Group for an undisclosed sum. Launched in 2007, the unit was a subsidiary of L&G, based in Dublin. It provides investment and tax planning solutions, primarily focused on the UK high net-worth market. The business has… – Continue reading
The Commerce Commission says it may not be able to do much about a company that more than 100 businesses have complained about, because it appears to be based overseas. The Commission has been investigating the New Zealand Small Business Assistance Centre since October 2014. Complainants say the company told… – Continue reading
An eyebrow-raising disclosure in the U.S. indictment of FIFA officials is that a representative of a Caribbean bank made it easy for one allegedly illegal transaction to be done by flying to New York to personally collect a check and then returned to deposit it in an account in the… – Continue reading
Chinese emigration continues to grow as the nation becomes increasingly wealthy. However, a handful of those leaving the country are wanted financial criminals, and they are heading to all corners of the world. While the United States and Canada continue to be popular destinations for corrupt Chinese on the run,… – Continue reading
June 30 — Taxpayers continue to wrestle with big questions a year after the Foreign Account Tax Compliance Act opened for business. Acknowledging that the Internal Revenue Service is doing its best to implement a complex law, issues still remain as the reach of FATCA goes global, practitioners told Bloomberg… – Continue reading
A common mistake when analyzing the tax implications of a cross border transaction is to jump too quickly to the ramifications of a tax treaty without first having a clear handle on the tax implications under the Income Tax Act (Canada) (“ITA”). A related issue is that even though a… – Continue reading
The UAE ranked 15th in an index rating countries’ residency-in-return-for-investment programmes As global economic growth slackens, a number of countries are offering citizenship or residency permits in return for investment in their markets. According to the latest Global Residency Programme Index by Henley & Partners, Portugal topped the list with… – Continue reading
The “wall of Chinese capital” hitting property markets in Sydney and Melbourne will not ease up until the government introduces its anti-money laundering legislation, says an expert in ‘flight capital’. James Tee, an ethnic Chinese property developer whose business specialises in “capital expatriation” – that is, getting money out of… – Continue reading
Financial Action Task Force on Money Laundering (FATF), an international intergovernmental organization created to combat money laundering has recently issued guidance in the form of a report titled ‘Guidance for a Risk-Based Approach to Virtual Currencies’ for closer monitoring of cryptocurrency exchanges. The report discusses about various benefits associated with… – Continue reading
Government data suggests there may be tax shenanigans going on in the city of Richmond, a situation that clearly is intolerable. Questions have been raised by a recent Vancouver Sun report by Douglas Todd about residents in the upscale neighbourhood of Thompson, located in northwest Richmond. Former Richmond mayor Greg… – Continue reading
A penny-stock firm’s mysterious surge last year to a $6 billion market cap that stunned Wall Street was allegedly the work of a California stock promoter who conspired with a network of corrupt offshore brokers. Gregg R. Mulholland, also known as “Stamps” and “Charlie Wolf” according to the government, was… – Continue reading
Newcomers to the United States on temporary visas may be unpleasantly surprised at the income tax consequences. A little advance planning with tax and immigration professionals can go a long way towards mitigating income taxes due. Many countries imposes taxes on income earned in that country (i.e., a territorial tax… – Continue reading
A recent report by Americans For Tax Fairness looks at how Walmart, the world’s largest corporation, uses a vast network of subsidiaries and branches in overseas tax havens with two purposes: 1.) to minimize taxes owed on its foreign operations. 2.) most importantly, to avoid United States taxes on those… – Continue reading
NEW YORK (Reuters) – A dual U.S. and Canadian citizen has been criminally charged with running a stock manipulation fraud that generated $300 million of illegal profit, and included a pump-and-dump scheme that caused the market value of little-known Cynk Technology to rocket past $6 billion. Gregg Mulholland, 45, is… – Continue reading
Despite the inevitable move towards automatic exchange of tax information and Common Reporting Standards internationally, there continues to be a steady flow of litigation in the Courts of International Financial Centres such as Bermuda, the Cayman Islands, and Singapore relating to challenges to inter-governmental Tax Information Exchange Agreement (TIEA) requests…. – Continue reading
Alberta’s new Finance Minister grudgingly admits it, and the province’s opposition proclaims it: The old Alberta Advantage is dead. The label long used by Progressive Conservative premiers to sell the Prairie province as a low-tax haven for individuals and corporations could be consigned to history when the NDP government passes… – Continue reading
PARIS: France is considering making 2017 a year free of income tax. The government wants to shift to a system of automatic withholding, similar to that in the United States and much of the rest of the world. Employees in France currently pay taxes a year after their income is… – Continue reading
The U.S. Model Income Tax Treaty (the U.S. Model Treaty) generally represents the United States’ opening position in treaty negotiations. As a result, when changes to the treaty are proposed, international tax practitioners should be aware of the potential impact those changes can have on their existing inbound U.S. structures…. – Continue reading
Wal-Mart Stores Inc. owns more than $76 billion of assets through a web of units in offshore tax havens around the world, though you wouldn’t know it from reading the giant retailer’s annual report. A new study has found Wal-Mart has at least 78 offshore subsidiaries and branches, more than… – Continue reading
Report on ‘poor’ neighborhoods full of mansions sparks calls for tax enforcement, residency documentation OTTAWA — The Canadian government takes a “zero tolerance” stand on tax evaders and is currently conducting audits on property owners in B.C., according to the Canada Revenue Agency. But Vancouver immigration lawyer Samuel Hyman said… – Continue reading
A group promoting Canadian sovereignty has raised 80% of the funds required to take the Canadian Government to court for providing residents’ details to the US for its Foreign Account Tax Compliance Act (FATCA). The lawsuit was filed by the Alliance for the Defence of Canadian Sovereignty (ADCS) on 11… – Continue reading
Property and casualty insurance companies in Canada are pushing more of their risks to reinsurers that aren’t federally regulated and are often located offshore, and Canada’s most powerful financial services regulator has become concerned enough to conduct a probe of the scope of this business. The Office of the Superintendent… – Continue reading
The number of voluntary disclosures of offshore income and assets to Canada’s tax authority nearly doubled in the year ended March 31 from the previous 12 months, the first time such figures have been gathered since the Canada Revenue Agency put in a whistleblower reward system to root out tax… – Continue reading
Part I of this series of articles reviewed some of the basic tax requirements for using trusts to split income, Part II discussed a number of tax planning opportunities that can be accessible through the use of trusts, and Part III reviewed traditional testamentary trust income splitting planning and the… – Continue reading
Retired Canadian lawyer Ginny Hillis has a message for the U.S. Congress. “They have no rights over me. None.” Hillis detests the “arrogance” of Congress for “imposing their laws on a sovereign nation with the complicity of that sovereign nation’s government.” America’s Foreign Account Tax Compliance Act (FATCA) “should embarrass… – Continue reading
India joined the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information on 3rd June, 2015, in Paris, France, alongwith Australia, Canada, Costa Rica, Indonesia and New Zealand. On our behalf, the Declaration to comply with the provisions of the MCAA was signed by H.E. Mr. Mohan Kumar,… – Continue reading
Canada’s Revenue Minister, Kerry-Lynne D Findlay, has signed the Multilateral Competent Authority Agreement (MCAA) on the Automatic Exchange of Financial Account Information. The adoption of the MCAA is a commitment from Canada to implement new international standards on the automatic exchange of information in tax matters. The MCAA specifies the… – Continue reading
The Honourable Kerry-Lynne D. Findlay, P.C., Q.C., M.P, Minister of National Revenue, today signed the international Multilateral Competent Authority Agreement (MCAA), an important step towards implementing the Common Reporting Standard for the automatic exchange of financial account information with other tax jurisdictions. Economic Action Plan (EAP) 2015 reiterated the Government… – Continue reading
Poland has removed Gibraltar from its schedule of countries and territories that it considers to be non-cooperative tax havens, the latest in a string of countries to do the same. The move means Gibraltar companies have been freed from previously held restrictions when doing business with Polish companies. It follows… – Continue reading
The news that Royal Bank of Canada plans to sell its wealth management services in Barbados no doubt caused some people to question the island’s future as a major centre for this type of business. After all, if the biggest player is leaving the field, what might this say to… – Continue reading
As another season of summer travel starts, Canadian residents with US ties should make sure they are thinking carefully about their tax obligations. Tax compliance may not be first in the minds of most people planning trips to the US, but Congress and the Obama administration certainly are thinking about… – Continue reading
Change to the Procedural Requirements at the Bank of Israel The Bank of Israel has recently implemented measures that are designed to minimize legal and reputational risks for Israeli banks. The Bank of Israel circulated a draft directive for all Israeli banks by virtue of which all foreign (non-Israeli resident)… – Continue reading
Canada’s health-care stocks are sizzling, as Concordia Healthcare Corp. and Valeant Pharmaceuticals International Inc.’s buy-and-streamline strategy has pushed the industry’s earnings and margins ahead of U.S. peers. The drugmakers are the two top-performing stocks in the Canadian equity benchmark this year, boosting total returns for the members of the Standard… – Continue reading
By stopping bogus claims of residency, his idea would force foreigners to pay capital gains tax when they sell a home in Canada OTTAWA — Inspired by the legendary FBI ploy to nab a notorious gangster, a B.C. immigration lawyer suggests the Canadian tax system be used to discourage the… – Continue reading
(Special) — The recent slump in oil prices is causing many Canadian investors to move their money from energy-weighted markets at home to foreign markets for better yields. While this may be a profitable investment strategy, it also can create its own set of problems because many investors may not… – Continue reading
Differences in how new accounts are treated by the US, the UK and Canada under the Foreign Account Tax Compliance Act are raising tough questions for banks across many jurisdictions, practitioners told Bloomberg BNA. “This is not an insignificant issue,” said Alan Granwell, of counsel with Sharp Partners P.A. in… – Continue reading
Luxembourg has been a prime destination for Canadians looking for a tax haven. Secretive. Discreet. Accommodating. These features were so attractive that Canadian companies, including a federal pension fund, sent $36 billion there in 2013. But new Statistics Canada data shows that more than $5 billion got pulled out of… – Continue reading
Singer revealed he bases some business ventures in the Netherlands Tax rates in the European country far lower than in his native Ireland Bono said ‘smart people’ were ‘just be sensible’ about ‘the way we’re taxed’ Sunday Times Rich List ranked U2 as the country’s third richest musicians He has… – Continue reading
House Foreign Affairs Committee Chairman Ed Royce (R-CA) and Congressional Armenian Caucus Co-Chair Frank Pallone (D-NJ) were among the first Congressional leaders to welcome the May 7th signing of the U.S.-Armenia Trade and Investment Framework Agreement (TIFA), a longstanding policy priority for the Armenian National Committee of America (ANCA). Chairman… – Continue reading
