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Tag Archive for Common Reporting Standard

Global Forum Publishes Ratings On Tax Transparency

The Global Forum on Transparency and Exchange of Information for Tax Purposes (the Global Forum) published the first 10 outcomes of a new and enhanced peer review process aimed at assessing compliance with international standards for the exchange of information on request between tax authorities.

The new round of peer reviews – launched in mid-2016 – follows a six-year process during which the Global Forum assessed the legal and regulatory framework for information exchange (Phase 1) as well as the actual practices and procedures (Phase 2) in 119 jurisdictions worldwide.

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Tax Residency In Canada: Deemed VS. Factual Resident

John Richardson

Tax Residency is becoming an increasingly important topic. Every country has its own rules for determining who is and who is not a “tax resident” of that country. The advent of the OCED CRS (“Common Reporting Standard”) has made the determination of “tax residence” increasingly important.

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

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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2015 Posts the Deepest Decline in Offshore Investments in 10 years!

Companies invested $221 billion into shell companies last year and investment flows to offshore tax havens such as the Cayman Islands and the British Virgin Islands fell somewhat, to $72 billion, according to the United Nations Conference on Trade and Development reported on May 3, 2016.

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