The CBDT has constituted a high- level committee to secure confidential tax data, obtained under mutual exchange with US authorities, as part of India’s compliance measures for signing the much awaited Foreign Account Tax Compliance Act (FATCA). The seven-member panel will be headed by the Member (Income Tax) of the… – Continue reading
Chapter 3 of the Internal Revenue Code requires payors (and recipients) of certain types of U.S. source income to withhold tax if the beneficial owner or recipient is a non-U.S. person for income tax purposes. Chapter 4 also imposes similar withholding under FATCA for payments to foreign financial institutions and… – Continue reading
A year after the signing of the intergovernmental agreement regarding FATCA (Foreign Account Tax Compliance Act) between Luxembourg and the United States, the bill of law was finally introduced on 27 March 2015 to the Luxembourg Parliament. The bill of law relates to the exchange of tax information between the… – Continue reading
With its enviable reputation in offshore trusts, pensions and insurance, Bermuda is an ideal jurisdiction for employers to establish international pension and employee benefit plans (IPPs). Global organisations may consider establishing Bermuda IPPs for employees who work outside their home country or the home country of both the employees and… – Continue reading
The debate around transparency, information exchange and beneficial ownership continues to evolve and has demanded a real focus for those working in International Finance Centres (IFCs), which frequently find themselves in the frame when it comes to ill-considered accusations relating to secrecy and illicit financial flows. In fact, Jersey and… – Continue reading
During 2014, Barbados again produced strong evidence of the underlying strength of its financial system. All of the financial stability indicators and stress tests performed for the financial system strongly indicate that the system remains stable with the capacity to withstand a wide variety of severe economic shocks. It is… – Continue reading
Cayman Islands investment entities that have been classified as “Reporting Cayman Islands Financial Institutions” for purposes of FATCA should make every effort to enroll with the Cayman government by the April 30, 2015 deadline in order to comply with their obligations under FATCA, regardless of whether they will be required… – Continue reading
The IRS on Tuesday proposed to amend its regulations so that taxpayers that are subject to withholding under Secs. 1441 through 1443 (chapter 3 of the Code, imposing withholding tax on nonresident aliens, foreign corporations, and foreign exempt organizations) or Secs. 1471 and 1472 (chapter 4 of the Code or… – Continue reading
Top Bay Area CPA Firm, Safe Harbor LLP, bolsters its focus on FBAR compliance issues in light of the upcoming June, 2015, deadline. FBAR (Foreign Bank Account Reporting) requirements are often necessary for residents with foreign financial accounts and assets. Safe Harbor LLP, a CPA firm in San Francisco specializing… – Continue reading
The regulations require reporting FIs to notify TIA if they have reporting obligations under US FATCA and/or UK CDOT. With respect to US FATCA, Reporting FIs have until tomorrow (April 30th) to file their notification with an initial reporting deadline May 31st. With respect to UK CDOT, Reporting FIs have… – Continue reading
Mitsubishi UFJ Fund Services warn managers are up against a time crunch ahead of the April 30 registration deadline The upcoming April 30 deadline for registration on the Cayman Foreign Account Tax Compliance Act (Fatca) portal marks another milestone but could prove a significant test for the industry, according to… – Continue reading
The British Virgin Islands Government has received a report that it commissioned on finding a new direction for the financial services industry, the recommendations from which will now be implemented, reports Tax News. The BVI engaged consulting firm McKinsey and Company to develop a pragmatic new strategy and implementation plan… – Continue reading
“Why are we doing this to folks? Why are we tormenting them in this way?” IRS Taxpayer Advocate Nina Olson asked in an address to Securities Industry and Financial Markets Association FATCA Policy Symposium in Washington last year. These “folks” are Americans living abroad: NGO workers, English teachers, physicians, taxi… – Continue reading
The April 21, 2015 Federal budget released by the Conservative Government includes updates on Canada’s involvement in the BEPS project and how Canada intends to fulfill its obligations to implement an automatic exchange of tax information with the G-20. Notably (with the exception of the common reporting standard discussed below),… – Continue reading
Five years on from FATCA’s inception, Dev Bhudia of GoldenSource argues that in order to realise new revenue streams from customer data, financial institutions can no longer afford to view regulations in isolation. They say birthdays are the perfect time to reflect and for many banks, the fifth anniversary of… – Continue reading
One million American citizens in Canada face double tax troubles. Max Reed explores these challenges in a spring series. The United States has two tools with which to collect information on accounts held by its citizens, FATCA and FBAR. Lots of attention has been paid to FATCA, less so to… – Continue reading
The Mauritius Revenue Authority (MRA) has informed Mauritius-based financial institutions (MFIs) that the filing deadline for submitting their US Foreign Account Tax Compliance Act (FATCA) data for the 2014 reporting year is July 31, 2015. FATCA requires all FIs outside of the United States to submit regular information on financial… – Continue reading
British Virgin Islands through its International Tax Authority (BVI ITA), went live last week with the Vizor for FATCA & AEOI solution, the “BVI Financial Account Reporting System”. Today, Vizor Ltd. announced that BVI went live with the Vizor for FATCA & AEOI solution. The British Virgin Islands Government (BVIG)… – Continue reading
On 3 April 2015, Uzbekistan and the United States signed a Foreign Account Tax Compliance Act (FATCA) Agreement. FATCA seeks to obtain information on accounts held by U.S. taxpayers in other countries. It requires U.S. financial institutions to withhold a portion of certain payments made to Foreign Financial Institutions (FFIs)… – Continue reading
Americans have overcome oligarchy before — and there’s no reason we can’t do it again. Rising inequality seems to pose an insurmountable political problem. If the underlying causes are technological change and globalization, the forces appear to be unstoppable. Alternatively, if the causes are primarily political and involve the power… – Continue reading
Tim Thornton, Chief Data Officer, Mitsubishi UFJ Fund Services comments on the upcoming deadline for registration on the Cayman FATCA portal… The upcoming 30 April deadline for registration on the Cayman FATCA portal is another milestone in the implementation of FATCA. The relatively short window from the portal being available,… – Continue reading
The world’s high and ultrahigh net worth families are run much like businesses these days, with family governance in place as well as fund structures in favourable tax jurisdictions that allow for consolidated reporting across diversified assets. That is the way the world is moving, with global tax authorities grouping… – Continue reading
NUMBER OF THE WEEK: 6.5 percent The tax rate at which companies could voluntarily repatriate their foreign earnings under the Invest in Transportation Act of 2015 ( S. 981). Senators Barbara Boxer (D-CA) and Rand Paul (R-KY) introduced the bipartisan proposal, offering ways to save the Highway Trust Fund. Funding… – Continue reading
On 20 March 2015, the British Virgin Islands Government issued revised guidance notes regarding the Intergovernmental Agreements between the British Virgin Islands (“BVI”) and the United States of America (the “US”) and the United Kingdom (the “UK”) to improve international tax compliance (the “Guidance Notes”). The Guidance Notes confirm that… – Continue reading
On March 30, 2015, the U.S. Department of Justice announced that it had entered into a nonprosecution agreement with BSI SA, the first Swiss bank to reach resolution with the U.S. government as to its potential criminal exposure for assisting its U.S. clients in engaging in tax evasion.[1] As part… – Continue reading
Moves to create a supposed level playing field for succession issues in Europe, along with more established themes around automatic exchange of information and US extra-territorial tax powers make their appearance in a major Geneva-based conference later in April. Figures from the world of wealth management will gather at the… – Continue reading
On Oct. 14, 1960, President John F. Kennedy made an impassioned plea to University of Michigan students, exhorting them to move abroad and assist nations struggling under the weight of underdeveloped economies. Kennedy was convinced American talent is a unique, effective export commodity. That speech laid the foundation for the… – Continue reading
The Foreign Account Tax Compliance Act (FACTA) has created a global impact on tax policy and how international investors run their financial lives. Should investors be worried that 50% of their portfolios will be seized as a fine? Or is it even worse. How many will go to jail because… – Continue reading
FATCA 1. New FATCA IGA guidance notes On 3 February 2015, the Jersey Chief Minister’s Department published the latest version of the Guidance Notes on the Taxation (International Tax Compliance) (Jersey) Regulations 2014 in relation to the implementation of obligations arising under the intergovernmental agreements (IGAs) with the US and… – Continue reading
1 General news 1.1 HMRC organisation chart HMRC has published its latest organisation chart showing the names of senior management. One point to note is the number of senior people now in roles such as change management as opposed to being in pure technical roles. This clearly demonstrates the direction… – Continue reading
The Inland Revenue Department has announced an extension to the deadline for financial institutions to comply with the reporting deadlines under the Foreign Account Tax Compliance Act framework. The deadline for FIs to submit FATCA data has been moved forward to June 15, 2015. FATCA requires all FIs outside of… – Continue reading
As has been widely predicted, today’s federal budget (Budget 2015) delivered a handful of tax “goodies” in the lead-up to the coming election. It also includes a number of important proposed changes to the corporate tax rules. They are noteworthy, although not as extensive as the corporate tax changes proposed… – Continue reading
After years of upheaval in the financial sector, taxpayer confusion, and widespread international angst, the IRS has finally unveiled its FATCA registration and reporting system. The system is known as IDES, or the International Data Exchange Service, and claims to provide “a secure web application … to transmit FATCA data… – Continue reading
The Virgin Islands government has created an Internet-based reporting system to help the territory’s banks, trust companies and other financial institutions comply with their obligations under a United States tax law. The system, called the BVI Financial Account Reporting System, will allow VI firms to pass along information about their… – Continue reading
Finance Minister Joe Oliver faced formidable challenges, both economic and political, in delivering his first Budget. In a time of depressed oil prices, and mere months ahead of the next federal election, it appears he felt it was imperative to follow through with prior commitments to balance the budget, provide… – Continue reading
1. NON-TAX ISSUES 1.1 Domestic law 1.1.1 Briefly describe your legal system and its origins The legal system of the Republic of Ireland is a common law system. In order to ensure consistency, a legal principle developed whereby courts were generally required to follow earlier relevant decisions. This doctrine of… – Continue reading
In the end, Dale travelled most of the way across his adopted country to cut his last ties to his old one. Originally from Kansas, the Strathroy, Ont. man had become a Canadian citizen in 2004, which he thought of as marking the loss of his U.S. citizenship. Global News… – Continue reading
Doing so would get rid of ‘overlapping and duplicative disclosure requirements,’ says advocacy group for Americans abroad The IRS’ taxpayer advocate is urging the tax service to simplify rules for Americans living overseas. Currently, foreign bank accounts must be reported both to the Treasury, in a Report of Foreign Bank… – Continue reading
U.S. guards at Canada’s rail hubs? April 20 If years from now, we discover that Prime Minister Stephen Harper turned out to be working for the U.S. government, who could be surprised? He almost had Peter MacKay indenture us to Lockheed Martin for 65 ruinously expensive F-35s. When he isn’t… – Continue reading
The National Taxpayer Advocate made three specific recommendations to the IRS last week to try to simplify the process for reporting foreign assets. For several years the National Taxpayer Advocate has complained that the disclosure requirements for FBAR (Report of Foreign Bank and Financial Accounts) and Form 8938 (Statement of… – Continue reading
The National Taxpayer Advocate has recommended that the reporting rules under the Foreign Account Tax Compliance Act and for foreign bank account reports in effect be merged to simplify the duplicative disclosure requirements that make it difficult for American expatriates to have bank accounts in the foreign countries where they… – Continue reading
In recent years we have seen a seismic shift in the tax transparency landscape. The US Foreign Account Tax Compliance Act (US FATCA) has proved to be a watershed moment and we are rapidly moving towards a global network of automatic information exchange spearheaded by the OECD’s Common Reporting Standard… – Continue reading
The government’s recent steps to check the flow of unaccounted wealth to foreign assets and bank accounts have had the unintended result of making tax compliance tough for expatriates on corporate assignments here, who have legitimate assets in their home countries, say experts. The tax troubles of these people over… – Continue reading
CHEYENNE, WY, April 17, 2015 /24-7PressRelease/ — OUTPOST PROVISIONING LLC today announced the launch of its “Wyoming…the Offshore Alternative” campaign alongside release of its Wyoming Paymaster Purpose Trust product. “Wyoming…The Offshore Alternative” touts Wyoming as being the Offshore-equivalent for wealth protection without the inconvenience, scrutiny, compliance costs and risks involved… – Continue reading
According to the latest research conducted by Amanda Klekowski von Koppenfels from University of Kent, 31 per cent of American citizens living outside the United States are going to renounce their citizenship. Three per cents are in the process right now. The reason of such citizenship renunciation is the intrusive… – Continue reading
It has never been easier for Americans to start businesses while living outside the U.S. If you are an American entrepreneur operating abroad, however, be aware of U.S. tax reporting obligations on non-U.S. businesses operated by Americans and make sure you are leveraging the value of U.S qualified retirement accounts… – Continue reading
The British Virgin Islands International Tax Authority (ITA) has launched its BVI Financial Account Reporting System (BVIFARS). The portal was opened yesterday and is ready to accept enrolment applications from BVI Reporting Financial Institutions (FI) which are required to submit information under the Intergovernmental Agreement (IGA) between the BVI and… – Continue reading
On March 30, 2015, the U.S. Department of Justice (DOJ) announced that it reached the first non-prosecution agreement under the Swiss bank program with BSI, S.A. (BSI). BSI, one of Switzerland’s ten largest banks, has agreed to pay $211 million in fines and cooperate in any related civil or criminal… – Continue reading
During the multi-year build-up to FATCA,1 the primary focus was on entity classification and registration, and less attention was paid to the compliance obligations of U.S. and non-U.S. entities affected by FATCA. Withholding and information reporting responsibilities under FATCA were generally known, but with the numerous deadline postponements and references… – Continue reading
NASSAU, Bahamas — The Ministry of Financial Services is doing everything necessary to ensure the full compliance of The Bahamas with established international norms and standards, as the Ministry prepares the country to be ready to comply with the United States Foreign Accounts Tax Compliance Act (FATCA). The Ministries of… – Continue reading
