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Archive for OECD

More Than 1,000 Relationships Now In Place To Automatically Exchange Information Between Tax Authorities

William Byrnes

As a further step to implement the OECD Common Reporting Standard (CRS), the first series of bilateral automatic exchange relationships were established among the first batch of jurisdictions committed to exchanging information automatically as of 2017.

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IRS Provides Legal Advice When Data Exchange With Foreign Countries is Confidential

Ronald Marini

In Legal Advice Issued by Associate Chief Counsel 2016-004, the IRS has given its opinion on the exact moment when information that it provides to and receives from foreign tax administrations via the Organization for Economic Cooperation and Development’s Common Transmission System becomes protected under the Code’s confidentiality rules. Legal Advice Issued by Associate Chief Counsel 2016-004.

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Tax Policy Reforms Driven By Focus On Boosting Growth

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While fiscal consolidation was the key driver of tax reforms in the years following the global economic crisis, the main emphasis of recent tax reforms has shifted back to tax measures aimed at boosting economic growth, according to a new OECD report.

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Pakistan Becomes the 104th Country to Signs OECD Convention on Mutual Administrative Assistance in Tax Matters

Ronald Marini

On August 29, 2016, we posted OECD Adds 5 More Countries To Its CbC Automatic Exchange Agreement where we discussed that on June 30, the Organization for Economic Co-operation and Development (OECD) announced that 5 new countries have signed the Multilateral Competent Authority Agreement for the automatic exchange of tax information.

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Singapore is Now Automatically Sharing Your Account Information!

Ron Marini

On July 25, 2016, we posted Tax Havens Coming Clean and Becoming Transparent where we discussed that the Inland Revenue Authority of Singapore has issued an e-Tax Guide on the territory’s general anti-avoidance rule in Section 33 of the Income Tax Act. The guide, issued on July 11, 2016, explains the three tests to determine whether the GAAR should apply.

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OECD Adds 5 More Countries To Its CbC Automatic Exchange Agreement

Ron Marini

On June 30, the Organization for Economic Co-operation and Development (OECD) announced that 5 new countries have signed the Multilateral Competent Authority Agreement for the automatic exchange of country-by-country (CbC) reports (CbC MCAA), which facilities the exchange of certain confidential transfer pricing information recommended under Action 13 of the G20/OECD project to target base erosion and profit shifting (BEPS). It brings the total number of signatories to 39 countries.

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U.S. Treasury Seeks Comments On Form 8975—CbC Reporting Form

Ron Marini

On May 5, 2016, we posted Possible CbC Optional Reporting for 2016 Under Consideration by US Treasury, which discussed that the Treasury and IRS were working towards a solution that would allow optional country-by-country (CbC) reporting for 2016. Also, more work would be needed to ensure that allowing optional filing for 2016 in the US would be effective in obviating the need for local filing. The Treasury and IRS also requested that U.S. multinational corporations (MNCs) to engage in the global debate to ensure optional CbC reporting will be enough to protect U.S. MNCs from becoming subject to secondary reporting requirements.

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Part 1: Tax Treaties, Determining “Tax Residence” And New OECD Common Reporting Standard

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An article from Stikeman Elliot includes the following:

For CRS purposes, the term ‘reportable person’ generally refers to a natural person or entity that is resident in a reportable jurisdiction (excluding Canada and the United States) under the tax laws of that jurisdiction, or an estate of an individual who was a resident of a reportable jurisdiction under the tax laws of that jurisdiction immediately before death, other than: (i) a corporation the stock of which is regularly traded on one or more established securities markets; (ii) any corporation that is a related entity of a corporation described in clause (i); (iii) a governmental entity; (iv) an international organization; (v) a central bank; or (vi) a financial institution. See definitional subsection ITA 270 (1).

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US Escapes The OECD’s Blacklist Of “Non-Cooperative Jurisdictions”

Ron Marini

The Organization for Economic Cooperation and Development has asked the G20 governments to approve its proposed three-step formula for deciding which international financial centers are to be blacklisted as non-cooperative.

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101 Countries Now Committed To OECD Common Reporing Standards

Ron Marini

According to an OECD announcement on May 12, 2016 global tax transparency forum, Panama, Vanuatu, Bahrain, Lebanon, and Nauru have now formally committed to share financial account information automatically with other countries using the Common Reporting Standard (CRS). This raises to 101 the number of jurisdictions committed to implement information sharing in accordance with the OECD’s Common Reporting Standard.

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Tax Havens Coming Clean and Becoming Transparent

Ron Marini

The Cayman Islands has gazetted the Confidential Information Disclosure Law 2016, thereby repealing the Confidential Relationships (Preservation) Law with immediate effect as of June 2016. The old law was seldom used but was often cited as evidence of Cayman’s secrecy. The new law returns liability for breach of confidence to the common law and rules of equity, as in the United Kingdom.

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European Group Discloses the Role of U.S. as a “Tax Haven”

Ron Marini

In February, we discussed the growing sentiment that the U.S. is the new tax haven, a notion underpinned by the increasing number of international families moving their assets out of traditional offshore jurisdictions and into trusts in certain states in the U.S. We also discussed that some level of secrecy is still available in the U.S. because Washington has not signed up to the OECD Common Reporting Standard (CRS) for international information exchange, preferring instead its own Foreign Account Tax Compliance Act (FATCA).

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