Archive for Europe, Middle East

United Arab Emirates – Actively Helping FATCA Express Move On Through

In March 2013 United Arab Emirates Central Bank Governor, Sultan bin Nasser Al Suwaidi, announced that the UAE was considering signing an IGA with the United States in order to facilitate compliance with FATCA. He stressed the need for the UAE regulatory authorities to prepare procedures to facilitate FATCA compliance and set clear instructions for financial institutions under their supervision. Very recently, the UAE Central Bank issued Notices to financial institutions in the Emirates that clearly move the FATCA express steadily along its inevitable path of destruction.

While no IGA has yet been signed, all indications are that this may happen pretty soon. The Model that would be implemented with the UAE would apparently be a so-called “Model 1B IGA” – which is “nonreciprocal”. This means that only the UAE would provide Read More

Written by | Posted in Europe, Middle East • FATCA • IRS

Irish Tax Treatment of Contracts For Difference (CFD)

Recently I’ve received a number of queries relating to the Irish tax treatment of CFDs or Contracts for Difference. Although the information available is plentiful and appears to be straight forward, it’s important to be aware that each situation is different and as a result the tax treatment may vary considerably.

Firstly, what is a Contract for Difference?

Essentially it’s a contract between two parties i.e. the investor and the CFD Provider. At the close of the contract, the parties exchange the difference between the opening and closing prices of a specified financial instrument, including individual equities, currencies, commodities, market indices, market sectors, etc. In other words, two parties take opposing positions on the difference between the opening and closing value of a contract i.e. the price Read More

Written by | Posted in Europe, Middle East • Tax Policy

Monday Was The Swiss Bank’s Deadline to Reveal Hidden US Accounts To The IRS!

Approximately 300 Swiss Banks had until the end of Monday December 16, 2013, to decide whether to turnover their records to the Internal Revenue Service. “I can confirm that the deadline is this evening, at the end of the business day, “a spokesman for Swiss financial market regulator FINMA, told AFP, refusing to say how many banks had already signed up to take part in the program.

On Thursday, August 29, 2013, we previously posted “Swiss Banks Agree to Plan to End Past US Tax Evasion Issues!“) where we discussed that under a deal reached between Bern and Washington, Swiss banks are ready to pay big fines for sheltering United States tax fugitives under the terms of a new deal approved by the Swiss Government. Read More

Written by | Posted in Europe, Middle East • FATCA • FBAR • International • Tax Fraud/Evasion/Crimes

United Kingdom Announces New Tax

United Kingdom Announces New Tax On Equity Compensation To Global Employees

The United Kingdom published a draft legislation recently that the tax treatment of all employment related securities be the same for all globally mobile employees. Accordingly a portion of any equity award paid to such employees should be apportioned to United Kingdom income based on the number of United Kingdom days in such financial year.

This legislation can create additional costs to the internationally mobile employee and should be reviewed carefully.

Read More

Written by | Posted in Europe, Middle East • Tax Policy

FATCA – U.S. And France Agree To Combat Offshore Tax Evasion

The United States Department of the Treasury announced today that the United States has signed an intergovernmental agreement (IGA) with France to implement the Foreign Account Tax Compliance Act (FATCA). Enacted in 2010, FATCA aims to curtail offshore tax evasion by facilitating the exchange of tax information.

With today’s agreement, 10 FATCA IGAs have been signed to date.

“France has been an enthusiastic supporter of our effort to promote global tax transparency and critical to drafting a model of FATCA implementation,” said Deputy Assistant Secretary for International Tax Affairs Robert B. Stack. “This agreement demonstrates the growing global momentum behind FATCA and strong support from the world’s most important Read More

Written by | Posted in Europe, Middle East • FATCA

France Signs On To FATCA Compliance – Financial Institutions Still Not Prepared

France just hopped on the FATCA express November 14, becoming the 10th nation to sign an Intergovernmental Agreement (IGA) with the United States. FATCA, as the “Foreign Account Tax Compliance Act” is commonly called, was enacted in 2010, but has been implemented in stages. It has seen several delays and while many hold hope it will never be finally implemented, all indications are that FATCA’s momentum is unstoppable.

Generally, FATCA requires foreign (non-US) financial institutions (FFI) to sign an agreement with the US government to report information about accounts held by US persons or accounts held by foreign entities in which US persons have a substantial interest. If the FFI Read More

Written by | Posted in Europe, Middle East • FATCA

Tina Turner – By Adopting Foreign Citizenship Are You Still Subject To The United States Exit Tax?

According to an “activity” report from the U.S. Embassy in Bern, Switzerland, long-time Swiss resident Tina Turner” was in the embassy October 24 to sign her “Statement of Voluntary Relinquishment of U.S. Citizenship under Section 349 (a)(1) of the INA” — the Immigration and Naturalization Act.

She has merely ‘relinquished’ her United States citizenship rather than formally ‘renouncing’ it, by adopting citizenship of her long-time home Switzerland.

She apparently hopes to avoid the USA’s exit tax on all her worldwide property, but she will be disappointed! Read More

Written by | Posted in Europe, Middle East

British Territories Are No Longer “Tax Havens”!

Do you have a Secret Account in One of the UK Tax Havens?

United Kingdom Prime Minister David Cameron made the following announcement in the House of Commons: “I do not think it is fair any longer to refer to any of the Overseas Territories or Crown Dependencies as tax havens.

They have taken action to make sure that they have fair and open tax systems”. The Prime Minister’s comments follow the progress made on tax transparency at the G8 and G20 summits, and come just weeks after the publication of an extensive report highlighting Jersey’s overall value to the UK economy.

The Isle of Man government has welcomed comments releasing the Crown dependencies Read More

Written by | Posted in Europe, Middle East • Tax Fraud/Evasion/Crimes

Hungary Initials Model 1 IGA

TaxConnections Blog PostExchange of information on tax issues between Hungary and the USA

Representatives of Hungary and the United States of America initialed an agreement to improve international tax compliance and assist the implementation of FATCA regulations.

According to the initialed version of the agreement, the data compiled from financial institutions will be forwarded to the tax authority of the US and information will also be received by the relevant authority of the country instead of the financial institutions involved. With the initialing of the agreement the phase of professional negotiations has been finalized and the document will be signed officially after the treaty has been endorsed by the Government.

Every country – among them Hungary — and several international organizations have recently placed special emphasis on combating international tax evasion and fraud. Among the measures introduced and initiated which are aimed to counter spreading tax abuse there are several solutions which Hungary intends to apply.

On the basis of the regulation based on the automatic exchange of information enacted by the USA which is designed to combat international tax evasion (Foreign Account Tax Compliance Act or FATCA), payments to financial institutions which do not provide information on the accounts held by United States citizens are subject to withholding tax of 30 percent. Read More

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Ireland Post – Finance (No. 2) Bill 2013 – Part III

TaxConnections Blog PostFor the beginning of the Post, please see Part I.

There were a number of other budget changes which will have a huge impact on our economy:

One Parent Family Tax Credit

• The One Parent Family Tax Credit was replace by a new Single Person Child Carer Tax Credit.

• This takes effect from 1st January 2014.

• There is no change to the value of the credit or the additional standard rate band.

• The new credit will only be available to the principal carer of the child.

Medical Insurance Tax Relief

• The Bill restricted the Medical Insurance Tax Relief.

• The maximum amount of the Medical Insurance Premium which can qualify for relief at the standard tax rate will be €1,000 for an adult and €500 per child. Read More

Written by | Posted in Europe, Middle East • Tax Policy

Ireland Post – Finance (No. 2) Bill 2013 – Part II

TaxConnections Blog PostFor the beginning of the Post, please see Part I.

The construction and building sectors saw the introduction of welcome changes:

I LIVING CITY INITIATIVE – The urban regeneration initiative has been extended to include residential properties constructed up to and including 1914 and covers the cities of Cork, Dublin, Galway and Kilkenny.

The aim is to stimulate regeneration of retail and commercial districts as well as to encourage families to return to historic buildings in Irish city centres.

II HOME RENOVATION INCENTIVE – This is a new incentive for home owners who:

1. carry out repair, renovation or improvement work on their principal private residence

2. from 25th October 2013 to 31st December 2015.

3. Qualifying expenditure carried between 1st January 2016 and 31st March 2016 can be treated as having been incurred in 2015 if planning permission was granted before 31st December 2015. Read More

Written by | Posted in Europe, Middle East • Tax Policy
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