The UK is proposing to introduce a unilateral, non-OECD co-ordinated anti-BEPS provision, referred to in the media as the “Google Tax”, with effect from 1 April 2015. The draft provision is very complex, and it will be time consuming to assess its potential impact on many common cross-border business structures…. – Continue reading
Taiwan’s Strait Exchange Foundation (SEF) chairman is scheduled to hold negotiations with his Chinese counterpart on the Agreement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income on Jan. 13, reports our Chinese-language sister newspaper Commercial Times. The agreement will possibly… – Continue reading
China has decided to join the likes of the US and tax its citizens living and working abroad, forming part of a crackdown on tax evasion by individuals and companies. China has had its own version of the Foreign Account Tax Compliance Act (Fatca) since 1993 when Chinese officials visited… – Continue reading
The Model 1B Intergovernmental Agreement signed between the Cayman Islands and the United States, sees those entities considered Financial Institutions (FI) that fall under FATCA, and have not registered with the IRS (to obtain a Global Intermediary Identification Number (GIIN), prior to 22 December 2014) now facing possible penalties (withholding)… – Continue reading
2014 marked a significant increase in the enforcement efforts by the IRS and Department of Justice against non-compliant U.S. taxpayers who failed to report their off-shore bank accounts and earnings. Grand Jury proceedings have been in full force and various criminal proceedings have been instituted. IRS investigations continue to increase… – Continue reading
January 8 2015 As of 2003, Israeli tax residents are subject to tax in Israel on their worldwide income, including passive income (i.e., interest, dividends and capital gains) generated in their offshore bank accounts. Although more than a decade has passed, many Israeli residents have still not reported on income… – Continue reading
Q: Reader Neill Clift of Washington, saying he and his wife are British immigrants with U.K. pensions from when they worked in that country, wrote that FinCen 114 and IRS Form 8938 filing obligations feel like “traps set for us and expect additional traps to be set. Is there any… – Continue reading
As Chinese individuals and companies head overseas in greater numbers, the country’s tax authorities are starting to follow. The Beijing billionaires who set up cryptically named companies in the British Virgin Islands to hold their fortunes are in the cross hairs. So are the Guangdong salesmen living and working in… – Continue reading
‘Deflation, Devaluation, and Default’ loom in China this year. The denouement for Shanghai’s bourse will not be pretty, says the US bank. China is at mounting risk of a financial crisis this year as growth sputters and deflationary pressures trigger a wave of defaults, Bank of America has warned. The… – Continue reading
A US criminal investigation into how Swiss banks helped wealthy Americans hide their money has had an unexpected side effect: shaking out scores of tax cheats among the Swiss themselves. Secrecy laws in Switzerland, the world’s largest offshore financial centre with trillions in assets, have been under siege in recent… – Continue reading
Buenos Aires (AFP) – Authorities raided the Buenos Aires offices of British bank HSBC on Wednesday investigating alleged tax evasion involving more than 4,000 influential locals’ Swiss accounts, a court source said. About 100 agents took part in the raid, the source said, adding the bank gave “court authorities the… – Continue reading
From Premier International Tax Library With the publication in September of Notice 2014-52, the IRS has made it extremely difficult for any foreign corporation that is not primarily engaged in an active business to acquire a U.S. business in exchange for its stock without risking being transformed into a U.S…. – Continue reading
A delegation from the US Internal Revenue Service (IRS) visited Israel last week to meet representatives of the Israel Tax Authority. Sources inform “Globes” that the purpose of the meeting was to implement the agreement for the exchange of information between Israel and the US concerning the accounts of US… – Continue reading
Argentinean Authorities Allege Bank Aided in Providing Secret Swiss Accounts A group of federal tax bureau agents and 100 police officers raided the downtown Buenos Aires offices of British bank HSBC on Wednesday, January 7. The Argentinean government is investigating the bank over alleged tax evasion and money laundering. In… – Continue reading
CRA has launched the Electronic Funds Transfer (EFT) initiative, introduced in the 2013 Budget as one of several new measures to crack down on international tax evasion and aggressive tax avoidance. Read: Top 10 tax changes of 2014 Effective January 1, 2015, certain financial intermediaries, including banks, have to report… – Continue reading
Other bodies announce similar probes; bank agreed to pay $400 million to US he Attorney General’s Office will open an investigation into the Bank Leumi Group, it revealed Thursday, weeks after the bank agreed to pay $400 million to United States and New York authorities for helping American taxpayers hide… – Continue reading
(Reuters) – Credit Suisse said its offices in Milan were searched by Italian tax police last month, following media reports of an investigation into whether a Bermuda subsidiary of the bank helped wealthy Italians hide undeclared funds. The searches follow a series of investigations against Swiss banks, including Credit Suisse,… – Continue reading
The Attorney General will examine the civil and criminal implications of the bank’s conduct in helping US citizens evade US taxes. Attorney General Yehuda Weinstein is to examine the Bank Leumi (TASE: LUMI) tax evasion affair, in which the Israeli bank helped American customers evade US taxes. Weinstein is consulting… – Continue reading
SINGAPORE (Reuters) – Singapore is updating guidelines on an accounting practice mired in controversy for helping multinational companies minimize their tax bills, as the city-state moves more in line with a crackdown by Western governments on aggressive tax avoidance. International taxation has come under scrutiny since a quirk of “transfer… – Continue reading
Outlook PwC’s request the Luxembourg authorities prosecute the whistleblower who lifted the lid on the vast extent of tax avoidance there is ill-judged and unpalatable. Antoine Deltour did the world a service in leaking the details of thousands of PWC-arranged tax deals in the tiny country. The result is likely… – Continue reading
With substantial amendments to SA transfer pricing legislation in April 2012 – as well as a lack of any subsequently updated or final Practice Note from SARS – much uncertainty still surrounds the realm of transfer pricing in SA, says Lauren Hart, of Webber Wentzel, in an analysis on the… – Continue reading
India enacted transfer pricing rules in 2001, which require companies to conclude international transactions with associated enterprises at an arm’s length. The legislation is primarily targeted at large business groups who engage in base erosion and profit shifting to avoid paying corporate income tax in India. This article is the… – Continue reading
Many factors influence a foreign buyer’s decision to purchase residential real estate in the United States. Generally, most of these decisions tend to be driven by concerns over political and economic uncertainty in the buyer’s home country. Most foreigners do not leave their home country, family, and friends for trivial… – Continue reading
Countries are competing to lower their tax rates to please the corporate giants, but the result is a massive collective loss of revenue. Only international coordination can wipe out the practice and defeat the negative influence of the Big Four accounting firms. Tax havens have long existed in the popular… – Continue reading
On December 28, 2014 Ukrainian Parliament has adopted the Draft law No. 1264-1 “On amending the Tax Code of Ukraine regarding improvement of tax control over transfer pricing” as of 22.12.2014 (the Draft Law). In order to become effective, the Draft law has to be signed by the President of… – Continue reading
Massive growth in the global foreign currency exchange (forex) markets has attracted the interest of traders and investors alike. With a plethora of currencies available and trade volumes running into the trillions of dollars, forex markets provide a convenient way to take advantage of inherent leverage and volatility, and to… – Continue reading
Overseas property buyers have to pay significantly more tax than domestic buyers in Singapore and Hong Kong, making them the most costly places for foreigners to invest in residential real estate in Asia Pacific, says Knight Frank Singapore and Hong Kong are the most costly places for a foreigner to… – Continue reading
The 4,029-page tax code is so complex both parties want to revise it. On business tax reform, they share surprising common ground, raising the potential for partial tax reform to be enacted this year. As the 114th Congress convenes this week, it has a golden opportunity to rid itself of… – Continue reading
The Inland Revenue Authority of Singapore (IRAS) has published an updated consolidated e-Tax Guide on the country’s transfer pricing regime. The e-Tax Guide, which was released on January 6, 2015, is divided into three main parts. Part I of the Guide provides background on the treatment of related-party transactions and… – Continue reading
With particular reference to issues associated with the requirements of the Foreign Account Tax Compliance Act (FATCA), the United States Internal Revenue Service (IRS) has updated Publication 515: The Withholding of Tax on Nonresident Aliens and Foreign Entities. It is specified that the Publication is for withholding agents who pay… – Continue reading
(CS/vb) A former PwC employee could face up to 10 years in prison for leaking thousands of documents in what has become known as the LuxLeaks scandal, his lawyer has said. Informant Antoine Deltour spoke on French television station Canal+ on Tuesday, saying that among experts, tax avoidance schemes via… – Continue reading
THE South African Revenue Service (SARS) has already begun to tackle the erosion of the tax base through profit shifting, which was addressed in an interim report of the Davis tax committee that was released last month for public comment. SA loses billions of rand in revenue annually through the… – Continue reading
A tax information exchange agreement signed between the Isle of Man and Lesotho has come into force. The government says it’s part of its programme of developing closer economic and taxation co-operation with other countries around the world. It was signed in September 2013 in London by Treasury Minister Eddie… – Continue reading
More than 100 countries including India, China and Russia have already entered into agreements with the US on the Foreign Account Tax Compliance Act (FATCA) and with new FATCA requirements coming into effect on 1st of January 2015 applying to U.S. and non-U.S insurers and insurance brokers, large portions of… – Continue reading
PM’s trip to principality comes after Catalan ex-leader’s revelations about hidden accounts Prime Minister Mariano Rajoy is expected to sign an agreement that will include a system for automatically sharing tax information between Andorra and Spain during an official two-day visit to the principality that begins on Wednesday. The agreement… – Continue reading
SINGAPORE – On December 9, 2014, Singapore became the first country in Southeast Asia to sign an Intergovernmental Agreement (IGA) on tax information sharing with the United States. The signing follows an in substance agreement reached between Singapore and the US in May 2014. Most countries around the world have… – Continue reading
Barbados appears to be moving into full financial information-sharing mode as the world’s most powerful countries put their foot down on tax evasion. It is already known that last November Government signed an Inter Governmental Agreement with the United States (US) to exchange information on their citizens who have thousands… – Continue reading
Data as of a week before deadline The total number of Indian financial institutions who have signed up with the American tax authorities under the Foreign Account Tax Compliance Act (FATCA) was less than 500 as per data from less than a fortnight ago. There were a total of 442… – Continue reading
The Federal Board of Revenue (FBR) is planning to introduce amendments to the income tax law in next federal budget (2015-16) to effectively deal with the transfer pricing issues of non-resident companies. Sources told Business Recorder on Monday that the first meeting of the FBR’s transfer pricing unit would be… – Continue reading
The Federal Board of Revenue (FBR) is planning to introduce amendments to the income tax law in next federal budget (2015-16) to effectively deal with the transfer pricing issues of non-resident companies. Sources told Business Recorder on Monday that the first meeting of the FBR’s transfer pricing unit would be… – Continue reading
Due to its geographical proximity to the mainland, modern and (until now) friendly banking system and transparent legal regime, Hong Kong has long served as a popular gateway into China for foreign businesses. Americans in particular have favored the former British colony, which retains its widespread use of the English… – Continue reading
Controversial proposals for a law to make failing to declare offshore income a criminal offence seem to have been put on the backburner by The Treasury. Chancellor George Osborne announced the measure as part of a campaign to stamp out tax evasion as part of his Budget 2014. However, no… – Continue reading
TWO noteworthy taxation amendments came into effect on the 1st of January 2015. The first tax amendment relates to the deductibility of interest paid to a person who is not liable to tax in South Africa, for example non-residents. The section in question, section 23M of the Income Tax Act,… – Continue reading
Many registered firms are subsidiaries of the same organisation, so actual number could be much lower than latest available figure of 442 Sachin P Mampatta | Mumbai January 6, 2015 Last Updated at 22:47 IST The picture regarding the number and proportion of Indian financial institutions which had registered with… – Continue reading
What’s coming our with with regards to the Foreign Account Tax Compliance Act (FATCA) in 2015? 2015 sees a number of impeding developments regarding FATCA compliance as the US presses on with its quest to target tax non-compliance by U.S. taxpayers with foreign accounts. Nick Matthews, Global Head of Forensic… – Continue reading
What’s coming our with with regards to the Foreign Account Tax Compliance Act (FATCA) in 2015? 2015 sees a number of impeding developments regarding FATCA compliance as the US presses on with its quest to target tax non-compliance by U.S. taxpayers with foreign accounts. Nick Matthews, Global Head of Forensic… – Continue reading
As a means of encouraging the development of intellectual property (IP) in Italy, rather than elsewhere, a “patent box” preferential tax regime has been introduced with effect from January 1, 2015, at the same time as a restructuring of the country’s research and development (R&D) tax credit system. Following the… – Continue reading
The Cayman Islands government announced it will not implement a central register of beneficial ownership information, but will continue its current method of providing this type of information to law enforcement, tax and regulatory authorities. At the same time, government proposes to enact new legislation that will improve access to… – Continue reading
The IRS released three updated documents through its electronic FATCA news service. Form 1042-S is used to report certain amounts from US sources paid to foreign persons (including persons presumed to be foreign). Form 8938 is used by certain individuals to report specified foreign financial assets if the total value… – Continue reading
Medtronic Inc. took one step closer to becoming an Irish company when shareholders voted in favor of acquiring Dublin-based medical supply maker Covidien Ltd. Covidien shareholders similarly voted on the deal early today and also approved it. The acquisition now goes before the Irish High Court, which may take several… – Continue reading
