Category: Jurisdiction

Offshore Tax Evasion: The IRS & Swiss Banks

LIGHTNING RELEASES (1/30/2015) – Attorney Gary S. Wolfe of The Wolfe Law Group is pleased to announce, after 12 years of research, the publication of his 10th book, Offshore Tax Evasion: The IRS and Swiss Banks, now available for immediate download through the Amazon Kindle store. Switzerland is the epicenter… – Continue reading

The IRS’s Weak Tea

At the US agency responsible for enforcing the Fatca tax withholding reporting law, an apparent lack of frequency in updating GIIN registrations, along with the as-yet-untested launch of its compliance service, reflect poorly on its capabilities I covered Foreign Account Tax Compliance Act (Fatca) developments in this space just two… – Continue reading

Nepal, Bangladesh to sign DTAA

KATHMANDU, Jan 30: Nepal and Bangladesh on Thursday agreed to sign Double Taxation Avoidance Agreement (DTAA). Issuing a statement on Thursday, Inland Revenue Department (IRD) said the fourth round of meeting for DTAA held in Kathmandu took the decision. Director General of Inland Revenue Department (IRD) Chudamani Sharma and Head… – Continue reading

FATCA agreement between Curaçao and the U.S. – the data protection and contractual client confidentiality issues

Speed read On 16 December 2014, Curaçao and the U.S. signed an intergovernmental agreement (“Curaçao-IGA”) setting out the information reporting and withholding requirements applicable to banks and other financial institutions resident in Curaçao (“FI’s”) under the Foreign Account Tax Compliance Act (“FATCA”). By virtue of the Curaçao-IGA, FI’s will be… – Continue reading

IRS Announces That More Than 50,000 Have Enrolled In OVDP; Amnesty Program To Remain Open Indefinitely

Yesterday, the Internal Revenue Service unveiled its latest statistics on participation in its Offshore Voluntary Disclosure Program (OVDP), an amnesty program for taxpayers with undisclosed foreign bank accounts that has existed in various forms since 2009.  To date, more than 50,000 taxpayers have made voluntary disclosures regarding offshore bank accounts,… – Continue reading

M&A activity by US multinationals in technology sector likely to increase, says expert

Cash reserves held outside the US for tax reasons by US multinationals are “likely to fuel a big increase in M&A activity over the next year”, said Eloise Walker a tax expert at Pinsent Masons, the law firm behind Out-law.com.30 Jan 2015 Corporate Tax Corporate tax International tax M&A Advanced… – Continue reading

IRS Voluntary Disclosure Regime Expands Maximum Penalty Bracket

The IRS recently announced an expansion of the list of banks and advisors that trigger the highest penalty bracket within its Offshore Voluntary Disclosure Program. The addition of Sovereign Management & Legal, Ltd. and Bank Leumi to the increased penalty list will have repercussions in Asia, Israel and the United… – Continue reading

IRS Targets Banks In FATCA Crackdown

The US Internal Revenue Service (IRS) has posted tax investigators to foreign embassies to lead a Foreign Account Tax Compliance Act (FATCA) crackdown on suspected tax evasion. The Asia Pacific financial centres of Hong and Singapore are two of the main targets, according to industry experts. The move follows claims… – Continue reading

Dominican Republic must soon ease banking secret, Taxman warns

Santo Domingo.- Internal Taxes Agency director Guarocuya Felix on Thursday warned that Dominican Republic must soon dismantle the barriers which limit the automatic access to information of the financial sector’s taxpayers, because despite the Arbitration Court resolution to break banking secrecy when the tax administration so requires, the information doesn’t… – Continue reading

Maldives sees top bank aiding offshore hub goal in Islamic finance

The Maldives’ biggest bank is opening a Shari’ah-compliant unit, a move the government sees aiding its goal of becoming South Asia’s offshore Islamic finance hub. Bank of Maldives Plc began offering retail deposits that comply with the religion’s ban on interest on 22 January to be followed by finance for… – Continue reading

Unfiled FBAR Conviction Against St Louis Man–Report of Foreign Bank and Financial Accounts

The United States Department of Justice secured a conviction against a St. Louis man accused of not reporting foreign bank accounts in Switzerland and Singapore. Raju Mukhi, age 67, was indicted last year on charges of willful failure to file an FBAR and filing false tax returns. Offshore accounts with… – Continue reading

Grappling with inversions: UK “Google tax” addresses corporate diverted profits

In November 2012, a startled TV audience watched coverage of the House of Commons Select Committee questioning Google’s chief executive about why his business, with ostensibly billions of pounds in sales generated in the UK, accounted for UK corporation tax in an amount equivalent to the price of a single… – Continue reading

Grappling with inversions: UK “Google tax” addresses corporate diverted profits

In November 2012, a startled TV audience watched coverage of the House of Commons Select Committee questioning Google’s chief executive about why his business, with ostensibly billions of pounds in sales generated in the UK, accounted for UK corporation tax in an amount equivalent to the price of a single… – Continue reading

HSBC Still Aiding Tax Fraud Even After Justice Department Settlement: Report

This story has been updated. At her confirmation hearing Wednesday, attorney general-designate Loretta Lynch said she has been “very aggressive” in pursuing white-collar crime. “At the outset, no individual is ‘too big to jail.’ And no one is above the law,” said Lynch. Yet according to a new report from… – Continue reading

London: ‘a global haven for criminal financial activity’

London is a global haven for criminal financial activity – with billions of pounds laundered through British banks each day, according to the head of the UK’s National Crime Agency. “Many hundreds of billions of pounds of criminal money is almost certainly laundered through UK banks and their subsidiaries each… – Continue reading

Liechtenstein declines to cooperate in ex-Catalan premier’s tax fraud case

Principality judge says no proof exists that money in Pujol’s alleged accounts is illegal “I didn’t want to know anything about inheritance,” claims ex-Catalan chief The government of Liechtenstein has refused to cooperate with the ongoing tax fraud inquiry into foreign bank accounts held by former Catalan premier Jordi Pujol… – Continue reading

Important royalty withholding tax decision

Introduction The taxpayer, Seven Network Limited, has won a recent decision (22 December 2014) in the Australian Federal Court, Seven Network Limited v Federal Commissioner of Taxation (2014) FCA1411, which is significant to all broadcasters, particularly involving the delivery of live sport and other entertainment. Briefly, the key issue raised… – Continue reading

IRS and British Tax Agency to Co-Host 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 Tax Symposium in Washington, D.C. January 27 – 29, 2015. The symposium focused on combatting offshore tax evasion and international financial crimes—including cyber-crime—and brought together delegates from criminal tax and… – Continue reading

Harvey Norman’s Gerry Harvey slams multinationals’ tax lobbyists

Billionaire retailer Gerry Harvey has accused Australia’s powerful business lobby groups of failing to represent ordinary tax-paying businesses and instead pushing the interests of profit-shifting multinationals. Speaking after the release of Apple’s Australian accounts, which revealed the tech giant had paid just $80 million in tax despite reaping $6 billion… – Continue reading

KPMG Suggests Hong Kong Budget Tax Changes

Hong Kong’s Government should use greater-than-expected revenue receipts to implement measures to enhance the city’s international competitiveness in the 2015/16 Budget, according to a KPMG survey of senior Hong Kong-based business executives. It is foreseen that the Government will be in a position of increased fiscal strength at the end… – Continue reading

Government asks I-T department to apply Vodafone principle on similar Transfer Pricing cases

MUMBAI: In what will be widely perceived as a sentiment booster for investors, the government has asked the I-T department to apply the principle behind a tax ruling involving Vodafone Group to all similar transfer pricing cases, an official letter seen by Reuters showed. Reacting to the news, Dinesh Kanabar of KPMG India told ET Now,… – Continue reading

Transfer Pricing Leaders To Address Latest Trends At Bloomberg BNA-Baker McKenzie Global Conference In Paris March 30-31

ARLINGTON, Va., Jan. 28, 2015 /PRNewswire-USNewswire/ — Bloomberg BNA today announced that its Global Transfer Pricing Conference: Paris, held in conjunction with Baker & McKenzie and in association with the Tax Management Education Institute, will occur on March 30-31 immediately after the Organisation for Economic Co-operation and Development (OECD) Global… – Continue reading

IGA with United States of America under FATCA – Registration

Inter-Governmental Agreement (IGA) with United States of America (US) under Foreign Accounts Tax Compliance Act (FATCA)- Registration Please refer to circular DBR.AML.No.9644/14.07.018/2014-15 dated December 30, 2014, on the captioned subject. 2. In partial modification to the above circular, it is clarified that those RRBs which do not have more than… – Continue reading

Microsoft NZ ownership transferred from US to Luxembourg

Microsoft denies a transfer of ownership of its New Zealand business from the United States to Luxembourg is related to the tiny European state’s favourable tax policies. Luxembourg, which has a population of less than 600,000, has been accused of facilitating large-scale tax avoidance by multinationals. Microsoft New Zealand was… – Continue reading

Bank Negara urged to act on 1MDB funds in Cayman Islands

The existence of 1MDB’s RM7 billion in the Cayman Islands and its return to Malaysia must be verified. KUALA LUMPUR: Pandan MP Rafizi Ramli urged Bank Negara Governor Zeti Akhtar Aziz, in a statement on Wednesday, to invoke the Anti Money Laundering Act and ensure that a reported RM7 billion… – 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

Global Tax Transparency Rising in 2015 As FATCA, OECD Initiatives Gain Momentum

Jan. 23 — The growth of global tax transparency is expected to leap ahead in 2015—meaning companies, individual taxpayers and financial institutions must exercise new levels of caution, practitioners told Bloomberg BNA. With more than 100 intergovernmental agreements under the Foreign Account Tax Compliance Act and dozens of countries signing… – Continue reading

Lionel Messi representative admits depositing cash in Caribbean tax haven

Money from charity games featuring Barça star was sent to Curaçao, Civil Guard says Messi charity games investigated for link to drug traffickers Charity soccer matches organized under the name of Argentinean star Lionel Messi in four countries in 2012 and 2013 raked in hundreds of thousands of euros that… – Continue reading