American Citizens Abroad (ACA) has provided testimony to the Senate Homeland Security and Governmental Affairs Permanent Investigations Subcommittee following its recent hearing on offshore tax evasion, and has recommended that the United States should implement a residence-based tax (RBT) system to avoid penalizing American expatriates. The ACA, as the principal… – Continue reading
The Foreign Accounts Tax Compliance Act (FATCA) will, from 1 July 2014, impose an array of new reporting obligations, especially on foreign financial institutions that serve Americans, including the need to report directly to the IRS. Leading many non-resident Americans and EU based financial firms calling for change or looking… – Continue reading
Cambodia has agreed to help the United States in its global effort to crack down on tax evasion by working with local banks to hand over financial data on US residents and business interests abroad, according to tax experts and officials. Speaking yesterday at the 17th Government-Private Sector Forum held… – Continue reading
The Canadian government is bending over backwards, and bending our laws, to allow the U.S. to enforce its new tax compliance act. Canadian visitors to Washington sometimes wonder why their embassy stands at the foot of Capitol Hill. The answer? To be close to where Canada’s laws are made. Case… – Continue reading
When a bipartisan Senate panel last week lambasted Swiss bank Credit Suisse for helping rich Americans evade billions in taxes, some watching the high-profile hearing couldn’t help but notice an elephant in the room. That is, Sen. Rand Paul. The connection? Paul for years has single-handedly blocked an obscure U.S.-Swiss… – Continue reading
The Republican Party has recently formally approved a petition to repeal the Foreign Account Tax Compliance Act – the repeal comes just 5 months before the act is set to come into effect. The main sponsor of the Republic party resolution to repeal FACTA, is Solomon Yue, who is a… – Continue reading
Kevin E. Packman is a Partner in our Miami office While Israel welcomes immigrants, and even provides them with tax incentives, it is serious about ending any perceived notion that it is somehow complicit with taxes evaded by its foreign residents in their home country. As such, it plans to… – Continue reading
On February 20, 2014, the Internal Revenue Service (IRS) issued additional final and temporary regulations (T.D. 9657)under the Foreign Account Tax Compliance Act of 2009 (FATCA) as well as new regulations (T.D. 9658) that modify the international withholding, backup withholding and information reporting rules that apply outside the scope of FATCA. FATCA generally… – Continue reading
The Russian Finance Ministry will offer companies based offshore but with operations in Russia a choice: either disclose their ultimate beneficiaries and maintain their zero tax rate, or pay taxes at the higher Russian rate. Under Russia’s current corporate tax structure, offshore beneficiaries of Russian companies are treated as de-facto… – Continue reading
As noted in our previous post, the recently signed Inter-Governmental Agreement between the Canada and the U.S. relating to FATCA (the IGA) will modify the FATCA reporting obligations for Canadian financial institutions. Under the IGA, the term “Financial Institution” (or “FI”) includes custodial institutions, depository institutions, investment entities and specified insurance companies. For… – Continue reading
Authorities aren’t waiting for new reporting laws to go into effect to track down Americans who they say owe money The US needs money — and it’s willing to go to the ends of the earth, including Israel, to track down deadbeats who are evading their taxes. Israel was named… – Continue reading
March 24 –July 1 is a hard and fast deadline for implementation of the Foreign Account Tax Compliance Act, Internal Revenue Commissioner John Koskinen told tax practitioners. Koskinen, speaking March 24 at the Tax Executives Institute midyear conference, said the agency will be understanding when financial intermediaries that are building… – Continue reading
Credit Suisse Group , Switzerland’s second biggest bank, went to great lengths to assist US customers trying to open Swiss bank accounts and evade taxes, entertaining them at a Swiss-themed ball in New York and golf tournaments in Florida and opening a branch in the Zurich airport to serve Americans… – Continue reading
The Foreign Account Tax Compliance Act (“FATCA”) requires foreign financial institutions (“FFIs”) to disclose the foreign accounts of U.S. taxpayers to the Internal Revenue Service (“IRS”). FFIs that fail to comply with FATCA will be subject to a 30% withholding tax on certain U.S. source income starting July 1, 2014…. – Continue reading
Kiwis could be forced to surrender their private details to United States authorities as part of a deal to combat tax-dodging. Those affected could include high-profile New Zealanders in entertainment, sports and business who have previously lived in the US. The Government has stressed the law changes to override New… – Continue reading
UTI International (Singapore) chief executive officer Praveen Jagwani says the asset manager had to remove American investors because of the compliance burden Foreign Account Tax Compliance Act (Fatca) brings. The regulation requires financial institutions to use enhanced due diligence to identify US citizens that have invested in either non-US financial… – Continue reading
The Island is a step closer to sealing the landmark FATCA tax-sharing agreement with the United States. Treasury minister Eddie Teare has won Tynwald support for measures to enshrine it in Manx law. The Foreign Account Tax Compliance Act was signed by the Isle of Man and the United States… – Continue reading
The Treasury Department and the Internal Revenue Service released a final package of regulations Thursday to implement the Foreign Account Tax Compliance Act and amend the regulations to align them with existing tax rules. FATCA was included as part of the HIRE Act of 2010, with the goal of combating… – Continue reading
The United States is pushing measures to close tax evasion loopholes with global co-operation at the G-20 summit in Sydney, Australia, where the group of 20 advanced and emerging economies are meeting. The U.S. is bent on reducing the loopholes used by MNCs to avoid tax. Just ahead of the… – Continue reading
The battle against offshore tax evasion is gaining momentum after Australia and the US struck a deal to combat tax-dodgers and G20 members prepared to sign off on a scheme for the automatic exchange of tax information. American Treasury Secretary, Jack Lew, and federal Treasurer, Joe Hockey, announced in Sydney… – Continue reading
It’s a u-turn, but unavoidable: bankers and politicians are preparing for the automatic exchange of tax information. Switzerland has helped develop the new standard, which the OECD wants to fast-track worldwide. The days when Swiss finance ministers said banking secrecy was non-negotiable and carved in stone are over. Switzerland has… – Continue reading
INTRODUCTION On 31 January 2014 the Crown Dependencies of Guernsey and Jersey jointly issued draft Guidance Notes (in conjunction with the Isle of Man) on the implementation of obligations arising under the intergovernmental agreements (“IGAs“) signed by each island with the UK in October 2013 and with the US in… – Continue reading
International Business Minister, Donville Inniss recently announceed that the Barbados Government and the United States of America have agreed to start negotiations with respect to an Inter-Governmental Agreement (IGA) that will give effect in Barbados to the provisions of the Foreign Account Tax Compliance Act (FATCA). FATCA, enacted by the… – Continue reading
The law’s onerous provisions are scheduled to go into effect in the coming year. However, even as this regulatory reckoning approaches, a group of US citizens residing abroad is making progress pushing for repeal. The looming United States Foreign Account Tax Compliance Act (“FATCA”), intended to prevent tax cheating, is… – Continue reading
In a huge publicity coup as protests grow against America’s controversial Foreign Account Tax Compliance Act (FATCA), Canada has finally signed an intergovernmental agreement to swap tax information with the US. Canada signing up for FATCA is a huge political and publicity coup for the US government as the Republican… – Continue reading
Local commercial banks and near banks regulated by the Bank of Jamaica (BOJ), as well as other entities regulated by the Financial Services Commission (FSC), which are counted as Foreign Financial Institutions (FFIs) under US law, should now be engaged in registering online with the United States Internal Revenue Service… – Continue reading
The U.S. and Britain have got themselves in another fine mess over populist measures against tax havens that don’t work and smack of hypocrisy Obama has set off once more on his crusade against foreign tax havens. His tactic is to extend the jurisdiction of the IRS to cover the… – Continue reading
Canada has signed a tax-information sharing agreement with the U.S. Treasury Department ahead of a new U.S. law that will crack down on offshore tax avoidance, senior Canadian finance officials said on Wednesday. The agreement, which is one of 22 so-called intergovernmental agreements (IGA) between Washington and individual countries, comes… – Continue reading
