Category: Jurisdiction

2 of the Top 5 FATCA Registration Listings Use Vizor Software

The latest FATCA Foreign Financial Institutions (FFI) list reveals that of the top five countries with the most registrations to date, the Tax Authorities of two – the Cayman Islands and the British Virgin Islands – are implementing the Vizor for FATCA & AEOI Vizor Software, the leading regulatory supervision… – Continue reading

New China law targets tax avoidance offshore

The mainland has stepped up its participation in the G20’s fight against international tax avoidance by passing a law cracking down on the indirect sale of assets outside the country to avoid paying taxes. The law would affect investment companies, analysts said, adding it would also have a significant impact… – Continue reading

OECD To Update G-20 On BEPS Progress

On February 6, 2015, the Organisation for Economic Co-operation and Development (OECD) announced that it has reached agreement with the Group of Twenty (G-20) Finance Ministers on three key elements of its base erosion and profit shifting project. The three elements, which the OECD said will enable implementation of the… – Continue reading

Asian cities attract more overseas money than Switzerland

Jeremy Grant in Singapore Clampdowns on bank secrecy in Europe and a proliferation of billionaires in Asia helped Hong Kong and Singapore attract more overseas money over the past two years than rivals such as Switzerland, according to a report by Deloitte. The consultancy’s annual ranking of wealth centres highlights… – Continue reading

U.S. companies may not be fleeing due to high tax rate, Reuters analysis shows

(Reuters) – When a series of big U.S. companies last year moved to reincorporate abroad in inversion deals, some Republican lawmakers and tax policy critics blamed the high U.S. corporate tax rate. Lowering it, they said, would keep companies from fleeing the country. But a Reuters analysis of the taxes… – Continue reading

Switzerland, Liechtenstein Conclude DTA Talks

Switzerland and Liechtenstein have concluded negotiations toward a new double tax agreement (DTA), which should enter into force from January 2017. Switzerland’s Federal Department of Finance (FDF) announced on February 5, 2015, that talks concluded on February 2. The FDF expects the deal to be signed this summer and, pending… – Continue reading

Newspaper headlines: Tax evasion, bonds ‘bribe’ and ‘Twitter asbos’

The Guardian’s very “word-heavy” front page is entirely taken up with details about what the paper calls “questionable practices” at a subsidiary of HSBC – one of the world’s largest banks. The paper says the financial institution’s private Swiss bank “helped wealthy customers dodge taxes and conceal millions of dollars… – Continue reading

HSBC Swiss unit says has made changes to prevent tax evasion’

GENEVA: HSBC’s Swiss banking arm, which according to leaked documents helped wealthy customers avoid millions in taxes in the past, insisted Monday it has since undergone a “radical transformation”. “HSBC’s Swiss Private Bank began a radical transformation in 2008 to prevent its services from being used to evade taxes or… – Continue reading

Irish names in HSBC bank’s secret files

International clients include those involved in arms trade and blood diamondsA huge cache of secret files from the Swiss branch of one of the world’s largest banks includes Irish people who made tax settlements with the Revenue Commissioners for more than €4.5 million. Other clients include arms dealers who sold… – Continue reading

Bulgaria approves USA’s FATCA agreement

Bulgaria’s cabinet has approved an agreement with the United States on the US’s Foreign Account Tax Compliance Act (FATCA), which targets tax non-compliance by US taxpayers with foreign accounts, Sofia Globe wrote. The cabinet approved the agreement, reached in December 2014, and said that it would ask the National Assembly… – Continue reading

“FATCA Finally Takes Effect, Subject to Transition Rules”

After several years of delays, the Foreign Account Tax Compliance Act (FATCA) finally took effect on July 1, 2014. Congress enacted FATCA as part of the Hiring Incentives to Restore Employment Act in 2010 to stop U.S. taxpayers from evading U.S. taxes through undisclosed offshore accounts and investments. FATCA requires… – Continue reading

Tax row engulfs Rexam predator Ball Corporation as a third of the US giant’s subsidiaries are based in tax havens

The US giant trying to take over Britain’s biggest drinks can maker in a £4.3billion deal is a serial user of tax havens. Ball Corporation is in talks to buy FTSE 250-listed Rexam that would create an industry goliath. The deal could be finalised as early as this week, and… – Continue reading

Sharing tax details: door for dialogue still open, says Swiss Finance Ministry

NEW DELHI, FEBRUARY 9: The “door for dialogue” with India remains open despite the current “difficult environment” on the tax-related information sharing front, the Swiss Finance Ministry has said. In a just released annual report on International Financial and Tax Matters 2015, Switzerland has admitted that its relations with India… – Continue reading

AICPA Urges Senate to Act on International Income Tax Treaties

The nation’s largest organization of accounting and tax professionals is urging the Senate to approve income tax treaties between the U.S. and various countries. In a February 3 letter to Senator Bob Corker (R-Tenn.), chairman of the Senate Committee on Foreign Relations and Senator Robert Menendez (D-N.J.), the committee’s ranking… – Continue reading

Guest Post: Transfer Prices Are an Evidentiary Gold Mine for Patent Defendants

Guest Post by Andrew Blair-Stanek, Assistant Professor of Law at University of Maryland Carey School of Law Patent owners routinely tell the IRS, under penalties of perjury, that their patents have little value.  Litigators representing defendants should take advantage of these remarkable admissions. IP has become the world’s leading tax… – Continue reading

MTC Puts Designs on Increasing State Transfer Pricing Revenues

This past December, the Multistate Tax Commission’s (MTC) transfer pricing advisory committee and its project facilitator Dan Bucks recommended what it calls the “preliminary design” approach for a proposed Arm’s Length Adjustment Services (ALAS) program.  While still subject to approval, states have already put designs on increasing state transfer pricing… – Continue reading

Dubai Islamic Bank Partners with SAS to Combat Money Laundering

SAS supports Dubai Islamic Bank with Anti-Money Laundering solutions Dubai – SAS, the leader in business analytics software and services, announced its collaboration with Dubai Islamic Bank ( DIB ) to help prevent money laundering among the bank’s customers. SAS will support the bank with Anti-Money Laundering (AML) solutions that… – Continue reading

India, US set to map out way to end transfer pricing cases in court

More than 100 tax disputes involving Indian associates of US companies such as IBM and Microsoft are set to be settled out of court by April this year with the income tax department and the US Internal Revenue Service identifying disputes in the contract research, IT and software sectors for… – Continue reading

Follow the money

As countries share more information, opportunities to squirrel away cash abroad will continue to narrow AMONG the sins that have most angered the austerity-weary everywhere is the use of undeclared offshore accounts to stash the wealth of the rich. Greeks were particularly enraged when data stolen from Swiss banks showed… – Continue reading

Ed Miliband issues warning to UK-controlled ‘tax havens’

A Labour government would push for UK overseas territories to be put on an international blacklist if they refuse to co-operate with a drive against tax avoidance, Ed Miliband has told them. In a letter to their leaders, he said they would have six months to compile a public register… – Continue reading

Swiss banker arrested in Germany over U.S. tax case: lawyer

Feb 7 (Reuters) – A former Swiss banker charged by U.S. prosecutors with helping wealthy Americans evade taxes has been arrested in Germany pending extradition to the United States, his lawyer said on Saturday. Roger Keller, a onetime client adviser in Zurich at Wegelin & Co, was one of three… – Continue reading

MTC Puts Designs on Increasing State Transfer Pricing Revenues

This past December, the Multistate Tax Commission’s (MTC) transfer pricing advisory committee and its project facilitator Dan Bucks recommended what it calls the “preliminary design” approach for a proposed Arm’s Length Adjustment Services (ALAS) program.  While still subject to approval, states have already put designs on increasing state transfer pricing… – Continue reading

Cayman Islands: FATCA In The Cayman Islands

The serious doubts expressed by many, most recently Professor Christians of McGill University, as to the Constitutional authority cited by the US Treasury1 in support of each Inter Governmental Agreement (an “IGA”) entered into by it on behalf of the United States government to implement FATCA have been rendered practically… – Continue reading

Hong Kong’s new and impossible rules for obtaining tax treaty residency certificates

On 29 January 2015, the Hong Kong Inland Revenue Department (“IRD”) announced new, hard-line procedures for obtaining a certificate of Hong Kong resident status (“tax residence certificate”) for the purpose of Hong Kong’s comprehensive double taxation agreement (“DTA”) network. The new rules became effective on 1 February 2015. This Client… – Continue reading

U.K. rails against Shire’s tax tricks that suitors extol

Report skewers PwC for creation of Shire tax shelter it calls ‘tax avoidance on an industrial scale’ Shire’s Ireland address has made the specialty drugmaker a prime takeover target. AbbVie was attracted but dumped the $55 billion buyout when the U.S. Treasury Department threw cold water on the deal with… – Continue reading

New wave of transfer pricing audits in Belgium

This week, almost 200 taxpayers in Belgium received a detailed information request regarding their transfer prices. For the third year in a row, this coordinated audit effort is organised by the specialised audit team at the Belgian tax administration. Downsized transfer pricing audit team The transfer pricing audit cell is… – Continue reading

OECD will update G20 finance ministers on BEPS project implementation next week

G20 finance ministers will hear about the OECD’s three-pronged approach to implementation of the BEPS Action Plan at their meeting in Istanbul on Monday and Tuesday of next week (February 9 and 10). The OECD, which is leading the work, outlined today what has been agreed so far with the… – Continue reading

Big companies need to tell the public how much tax they pay, says business lobby group CTA

The group that represents most of the ASX 200 on tax issues, the Corporate Tax Association, has emerged as a surprise advocate of increasing transparency about the amount of taxes big companies pay. The Corporate Tax Association’s submission to the inquiry into corporate tax avoidance said it had concerns about… – Continue reading

As Middle Class Flees, Puerto Rico Tries Luring Rich People

Bond trader Ben Eiler swapped life in suburban Georgia for an island in the Caribbean, and he didn’t even have to apply for a visa. The towering 38-year-old native of Arkansas is one of at least 250 people who’ve accepted Puerto Rico’s invitation to well-heeled U.S. citizens to move to… – Continue reading