Concerns were raised in parliament Tuesday about the US Foreign Account Tax Compliance Act – FATCA, and its likely impact on the federation. The act, described as a tax act of the American government that the federation is being asked to enforce was being debated in the National Assembly Tuesday,… – Continue reading
NEW YORK: Noting that progress on a bilateral investment treaty with India has been “slow”, a senior US trade official has said in the absence of progress on economic reforms by India to ensure ease of doing business, the likelihood of getting to such a treaty is “low”. “Frankly, it… – Continue reading
The Transactional Net Margin Method (‘TNMM’) is a prescribed method for determining the arm’s length price in some cases. It also enjoins the adjustment owing to capacity under-utilization differences. Sizes of entities and level of activities differ, so does the available comparables for the purpose of transfer pricing adjustments. The… – Continue reading
Economist Richard Murphy, a long-standing critic of the Channel Islands, has told ITV News he believes the Bailiwicks are secretive “tax havens” that undermine the UK’s tax system. We spoke to him immediately after today’s Prime Minister’s Questions, where Jeremy Corbyn spoke for the first time as leader of the… – Continue reading
A federal court judge dismissed an attempt to put an early stop to a controversial program in which the Canadian government agreed to share financial information of an estimated one million “U.S. persons” living in Canada with the Internal Revenue Service. Particularly troubling to some opponents is that the agreement… – Continue reading
On Thursday, The House Ways and Means Committee will once again contemplate making permanent controversial tax breaks that overwhelmingly benefit big business at a cost of $380 billion over the next 10 years. Known as tax extenders, these giveaways are a package of tax breaks that Congress must vote to… – Continue reading
The night that Uber started offering its ride-hailing service in Costa Rica, vandals – reportedly taxi drivers – smashed the windows of one of the company’s cars in protest. Traffic police impounded two Uber vehicles earlier that same night. Airbnb, however, another staple of the so-called “sharing economy,” has been… – Continue reading
Tax professionals in Australia, in considering how to assess risk and prepare for potential controversy in light of the changing tax landscape, are focusing on a number of key themes. These include the following: The importance of assessing and contrasting positions taken, against positions that the Australian Taxation Office (ATO)… – Continue reading
Malta provides an outstanding opportunity for private equity and venture capital managers. It has a flexible LP structure, an extensive network of double tax treaties, a favourable local tax regime and experienced service providers who can provide a cost-effective solution,” comments Felicity Cole (pictured), Head of the Funds Department at… – Continue reading
Mombasa county has launched another attempt to collect levies on cargo at the port after earlier attempts were rejected by the Kenya Ports Authority (KPA). Through the Finance Bill 2015/2016, the county wants to directly tax shipping lines and cargo owners unlike in the previous bid where it sought to… – Continue reading
AUGUST DECLINE:Deposits at banks’ offshore banking units plunged 7.3 percent to 49.79 billion yuan and fell 2 percent to 277.15 billion yuan at domestic banking units Yuan deposits at Taiwanese banks fell 2.88 percent to 326.94 billion yuan (US$51.29 billion) last month from July, as the Chinese currency’s widening volatility… – Continue reading
Transparency International called today on European Commission President Jean-Claude Juncker to publicly support legislation that would allow citizens to scrutinise the corporate taxes paid by multinational companies to governments. Juncker will appear tomorrow in front of a special tax committee at the European Parliament to defend the Commission’s track record… – Continue reading
The Inland Revenue Board of Malaysia in September 2015 issued guidance concerning the requirements for compliance with an intergovernmental agreement (IGA) to implement the FATCA regime. The FATCA guidance notes provide guidelines and practical information for Malaysian-based financial institutions, businesses, their advisers, and officials dealing with application of the FATCA… – Continue reading
Former HSBC Bank employee Hervé Falciani gave a USB stick with eight names of alleged tax evaders to the four Greek prosecutors who took his testimony at the Greek Embassy in Paris. According to information from an anonymous source at the Public Prosecutor’s office, the list of names includes two… – Continue reading
‘I’m not going to buy into that’ Joe Hockey refuses to feed speculation that he could be replaced as Treasurer by Scott Morrison under the new Prime Minister Malcolm Turnbull. Malcolm Turnbull’s first full day as PM: Live coverage Joe Hockey signals he’s ready to serve on Malcolm Turnbull’s frontbench… – Continue reading
Exclusive: company faces renewed questions over its fitness as security contractor at Australian detention centres on Manus Island and Nauru Wilson Security faces renewed questions about its fitness as security contractor in Australia’s offshore detention centres in light of its corporate links to a tax haven, a corruption scandal that… – Continue reading
Changing Attitudes to Tax Reputation Risk In recent years, it seems that any discussion of tax includes mention of the moral obligation taxpayers have to “pay their fair share.” Many believe this theme began to get traction in 2011 when Warren Buffett realized that he was paying proportionately less taxes… – Continue reading
Consolidation in Europe’s private-banking industry is inevitable as pressure from clients and regulators increases costs, McKinsey & Co said in a study published yesterday. Pressures on profit margins could force private banks to cut costs and review the number of booking centers they operate, the New York-based consultancy said. The… – Continue reading
The Government should reduce the rate of capital gains tax (CGT) and expand corporation tax relief for start-up companies in next month’s budget to boost growth in the financial technology sector, Financial Services Ireland (FSI), a unit within employers’ group Ibec, has urged, reports the Irish Times. In a 10-page… – Continue reading
The tax arrangement for the Kingdom (BRK) will be replaced by a new tax system in relation to the Netherlands and Curaçao. The new tax arrangement was adopted by the Dutch House of Representatives on September 10 of this year, reports the Curacao Chronicle. The tax arrangement between Curaçao and… – Continue reading
Stimulus unleashed by China’s central bank will cushion Chinese companies –the region’s biggest dollar debt issuers — from a potential Federal Reserve interest rate increase, making cheaper yuan funds available. Five interest rate cuts by the People’s Bank of China since November and rules to relax yuan bond issuance onshore… – Continue reading
IN SPITE of the challenges from large developing countries, assurance has been given that Barbados is sticking with the International Business and Financial Services sector. This is according to Prime Minister Freundel Stuart, who used the opportunity over the weekend to commend Minister of International Business, Donville Inniss, for his… – Continue reading
NEW DELHI: Finance minister Arun Jaitley has promised “fairest and predictable taxation regime” while inviting US businesses to invest in the country. Speaking at the 11th Indo-US Economic Summit organised by the Indo-American Chamber of Commerce ahead of the India-US Strategic and Commercial Dialogue (SACD) in Washington later this month,… – Continue reading
Hewlett-Packard will offshore 60% of its workers at its consulting unit, HP Enterprise Services, CEO Meg Whitman told investors Tuesday during the company’s annual analyst meeting. In 2013, 36% of ES workers were in low-cost offshore locations like Manila, Philippines; Costa Rica; and Bangalore, India. By 2018, 60% of them… – Continue reading
Under the I-T Act, 1961, taxpayers are broadly categorised as Ordinary Resident, Not Ordinarily Resident (NOR) and Non-Resident (NR). Reporting and paying taxes on overseas incomes and assets come with their own set of challenges. Under the I-T Act, 1961, taxpayers are broadly categorised as Ordinary Resident, Not Ordinarily Resident… – Continue reading
The largest producer of nitrogen-based fertilizer in the United States, CF Industries, is considering merging with a Dutch competitor and moving its headquarters overseas to avoid the “double taxation” of profits earned by overseas subsidiaries going to the domestic company. Curtis Dubay, a tax and economic research fellow with The… – Continue reading
The European Confederation of Independent Trade Unions (CESI) has said that the proposed country-by-country reporting (CbCR) requirements are insufficient, and added that an extended CbCR, disclosure of tax rulings, and whistle-blower protection are key to ensuring corporate tax transparency. In its response to the public consultation on corporate tax transparency… – Continue reading
The question for many expats is in Australia is if switching their UK pension to a Qualifying Recognised Overseas Pension Scheme (QROPS) is worthwhile? Tax is a personal issue and no one-size-fits-all solution is available, but here are some general pointers to how pensions are taxed in different financial centres… – Continue reading
Victoria Seychelles — Promoting cooperation between African countries and increasing trade and industry have been the main focus of diplomatic work of the outgoing Nigerian High Commissioner to Seychelles, Solomon Akintola Oyateru, during his term in office. High Commissioner Oyateru made this statement in an interview with the press at… – Continue reading
Anne Berner, who serves as Minister of Transport and Communications, serves on the board of a Luxembourg firm involved in tax planning. This is the first time a Finnish minister has been known to have been involved in such a company. Finland’s Transport minister is a board member at a… – Continue reading
Administrators of tax-qualified retirement plans (or their delegated payor) are responsible for both withholding on distributions and for reporting the tax withheld. If taxes are under-withheld, the administrator/delegated payor may be subject to penalties. Although the rules governing withholding on distributions to US citizens and resident aliens are clear and… – Continue reading
(ZIZ News) — Tuesday’s sitting of the National Assembly featured heated debates on the Foreign Account Tax Compliance (United States of America) (Implementation and Enforcement of InterGovernmental Agreement) Bill 2015. Prime Minister, Hon. Dr. Timothy Harris, who sought leave to have the bill read a first and second time, was… – Continue reading
(Bloomberg) — Grupo BTG Pactual, the only publicly traded investment bank in Brazil, said it’s willing to consider more acquisitions in Switzerland after completing the purchase of BSI, the Swiss private-banking unit of Assicurazioni Generali SpA. “We are looking. We are always looking,” Renato Cohn, a BTG partner and member… – Continue reading
Whole regions of England are now owned by holding companies in tax-havens “from Panama to Luxembourg, and from Liechtenstein to the South Pacific island of Niue.” Private Eye’s interactive map mines Land Registry information to find the properties owned by “companies, arms dealers, oligarchs, money launderers and others who use… – Continue reading
Google’s CEO may be “proud” of the way his company avoids taxes, but a Canadian tax watchdog group thinks the tech giant’s tax practices should disqualify it from partnering in a Canadian election debate. The Globe and Mail is hosting a leaders’ debate on the economy Thursday night in partnership… – Continue reading
“Luxembourg is famous for two things: its steel industry and its rose cultivation industry”. This quote from an Italian guidebook of the 1930s was uttered by Luxembourg’s Finance Minister Pierre Gramegna at the annual conference of the Luxembourg Directors’ Association on 17 June 2015[1]. The economic outlook of the tiny… – Continue reading
The Department of Justice announced today that Bank La Roche & Co AG has reached a resolution under the department’s Swiss Bank Program. “Today’s agreement is yet another example of a foreign financial institution coming forward, acknowledging its criminal conduct, taking the necessary steps to resolve its criminal exposure, cooperating… – Continue reading
The number of banks with deferred prosecution agreements with the U.S. government keeps growing. The subject is tax evasion involving American account holders. Today, under FATCA, banks everywhere want to know if you are compliant with the IRS. And the IRS keeps updating its list of foreign banks where offshore… – Continue reading
Kenneth Leung (PC,F-Accountancy) explains what he – and the government – are doing to get Hong Kong off the EU’s undeserved blacklisting as a “non-cooperative tax jurisdiction”. Why has Hong Kong been placed on this list? There are ten European countries that have named Hong Kong as a tax haven…. – Continue reading
Is Xi Jinping (習近平)’s anti-corruption campaign crushing it or embarrassingly ineffective? You make the call. It was widely reported the year before Xi assumed office that upwards of 18,000 corrupt officials had fled China since 1990 with about US$120 billion. In early 2012, the Ministry of Supervision released figures saying… – Continue reading
On July 9, 2015, India and the US signed an agreement to implement the Foreign Account Tax Compliance Act (FATCA) that will facilitate exchange of information between the two countries starting on October 1, 2015. FATCA was signed by Revenue Secretary Shaktikanta Das and US Ambassador Richard Verma in New… – Continue reading
Belgian financial institutions have more time to comply with their reporting requirements under the FATCA regime. FATCA reporting for 2014 must be completed prior to the 10th day following the publication of the Belgian FATCA law in the Belgian official gazette. Currently, the law has not been enacted, but it… – Continue reading
The Swedish Tax Agency have published its opinion 27th of August on taxation of dividends from tax havens to Swedish companies. Sweden introduced the current participation exemption rules on dividend and capital gains for companies in 2003. Dividends that is received by tax resident limited liability companies (Aktiebolag or AB)… – Continue reading
An increasing number of Americans renounced their citizenship and cut-off long term residencies during the initial three months of 2015 due to a crackdown in the foreign tax rules. The exit wave went down a little in the second half, but has continued. The Internal Revenue Service and Treasury Department… – Continue reading
Note: This article was published by Bloomberg BNA in Tax Planning International European Tax Service Vol. 17 No. 7 July 2015 Introduction The recent LuxLeaks scandal has once again focused political attention on tax planning practices of multinationals (“MNEs”). It comes in the wake of the European Commission investigation of… – Continue reading
New Article L. 62 A of the French tax procedure code (published in the official bulletin on 2 September 2015) sets forth rules that effectively regularize the tax treatment of certain profits transferred abroad by French taxpayers, and allows for the repatriation of these funds without additional tax—and in particular,… – Continue reading
There are often a few major issues on everyone’s lips in the international community of tax lawyers. This was the case also at The International Fiscal Association’s (IFA) 69th Congress in Basel, Switzerland. One of the main subjects in the congress was how tax payers’ rights can be most efficiently… – Continue reading
The estates of high net-worth individuals often cross borders. They might reside in one country, with assets in that country and elsewhere, and possibly family members residing are in other countries for work, education, or lifestyle reasons. The tax resulting from death can be quite harsh to their estate or… – Continue reading
Seven leading Democrat lawmakers wrote a letter on September 12 to US Treasury Secretary Jack Lew urging him to publish an annual list of companies that have undertaken corporate tax inversions, and to use the Administration’s executive authority further to discourage the use of inversion techniques. Tax inversion techniques are… – Continue reading
Greece would be much better off if the government could collect the taxes owed by the self-employed. That’s the lesson from a paper released this month that uses an innovative method of capturing tax evasion. Estimating shadow economies is tough. Friedrich Schneider of the Johannes Kepler University of Linz in… – Continue reading
