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26 May 2017

Written by John Richardson | Posted in International

Part 2: OECD CRS: Tax Residence And The Tax Treaty Tiebreaker

This is Part 2 – a continuation of the post about “tax residency under the Common Reporting Standard.”

That post ended with:

Breaking tax residency to Canada can be difficult and does NOT automatically happen if one moves from Canada. See this sobering discussion in one of my earlier posts about ceasing to be a tax resident of Canada. (In addition, breaking tax residency in Canada can result in being subjected to Canada’s departure tax. I have long maintained that paying Canada’s departure tax is clear evidence of having ceased to be a tax resident of Canada.)

No comments | Tags: Canada, Common Reporting Standards, OECD, tax residents, Tax Treaty Tie Breaker

10 Apr 2017

Written by William Byrnes | Posted in Common Reporting Standard • Common Reporting Standards • Exchange of Information • FATCA

How The U.S. Can Leverage FATCA Bilateral Process

TaxConnections Member Professor William Byrnes examines whether it is prudent for taxpayers to trust the governments of the 117 countries that scored a fifty or below on Transparency International’s corruption index. The complete information system invoked by the Foreign Account Tax Compliance Act (FATCA) encourages, even prolongs, the bad behavior of black hat governments by providing fuel (financial information) to feed the fire of corruption and suppression of rivals. Professor Byrnes recommends that the United States leverage a “carrot-stick” policy tool to incentivize bad actors to adopt best tax administration practices.

Article download at https://ssrn.com/abstract=2916444

No comments | Tags: Common Reporting Standards, Exchange of Information, FATCA, OECD

14 Feb 2017

Written by Ronald Marini | Posted in Europe

BEPS Project May Have Set Backs – EU’s Apple Decision

In September, 2016, we discussed that the European Commission’s probe into Apple, which resulted in an order for the tech giant to pay up to €13 billion ($14.5 billion) in back taxes to Ireland, was prompted by a U.S. Senate investigation, European Union Competition Commissioner Margrethe Vestager said on Friday.

No comments | Tags: Apple, Back Taxes, european commission, Ireland, OECD, tax sovereignty

28 Dec 2016

Written by William Byrnes | Posted in International

Monaco Strengthens International Tax Co-operation

Monaco today deposited its instrument of ratification for the Convention on Mutual Administrative Assistance in Tax Matters (“the Convention”). By doing so, Monaco underlines its commitment to fighting tax evasion and avoidance and takes another important step in implementing the Standard for Automatic Exchange of Financial Account Information in Tax Matters developed by the OECD and G20 countries as well as automatic exchange of Country-by-Country Reports under the OECD/G20 Base Erosion and Profit Shifting (BEPS) Project.

No comments | Tags: BEPS, CRS Multilateral Competent Authority Agreement, Monaco, OECD, Tax Matters

14 Jul 2016

Written by William Byrnes | Posted in Europe • Tax Law Changes • Tax Legislation • Tax Updates

The Major Contenders For London’s Relocating European Financial Center

As I hear it, if the Netherlands were to substantively amend its ‘maximum 20% bonus of salary’ regulation, then the relocation decision for many EU facing funds would be an easy choice. But because of that regulation, it has created an opportunity for other cities to pitch to the institutions for the funds and trading business relocation.

No comments | Tags: Amsterdam, Brexit, Dublin, European Financial Center, Frankfurt, Luxembourg, OECD, William Byrnes

09 May 2016

Written by Ronald Marini | Posted in OECD

Possible CbC Optional Reporting for 2016 Under Consideration by US Treasury

Speaking at a April 28,2016 transfer pricing symposium held by the University of San Diego School of Law, Robert Stack, US Treasury Deputy Assistant Secretary (International Tax Affairs) addressed the “gap-year” issue arising from the implementation of CbC reporting in some jurisdictions for tax years beginning on or after 1 Read more

No comments | Tags: CBC, MNEs, Multi Nationals, OECD, Optional Reporting, Ronald Marini Tax Advisor

20 Apr 2016

Written by Ronald Marini | Posted in FATCA • IRS

US Pressured For Beneficial Ownership Rules

We previously posted, Get Ready For The US Proposed Plan to Require Banks to Identify Owners of Shell Companies! where we discussed that the United States government is close to issuing a rule that will for the first time require banks and other financial institutions to find out the identities of people hidden behind shell companies.

The rule is meant to close a major loophole in the American Read more

No comments | Tags: Beneficial Ownership Rules, Common Standard On Reporting, FATCA, Foreign Accountant Tax Compliance Act, IRS, Mossack Fonseca, OECD

19 Apr 2016

Written by Ronald Marini | Posted in OECD

Mandatory Public CbC Reporting Proposed by the OECD!

On April 12, 2016 the European Commission presented a proposal that would require all large Multinational Enterprises with operations in the European Union to Publicly Disclose certain tax-related information for all their entities in the EU and in designated tax havens on a country-by-country (CbC) basis.

The European Commission has indicated that it will establish a common EU list of tax haven jurisdictions as soon as possible. Read more

No comments | Tags: OECD

18 Apr 2016

Written by Ronald Marini | Posted in International

Panamanian Police Raid The Law Offices of Mossack Fonseca Just 10 Days After Leek!

On April 4, 2016 we posted Huge Leak From the Panamanian Law Firm Mossack Fonseca! where we discussed that, the offshore planning world was set on fire with the news that 11 million documents were leaked from the Panamanian law firm Mossack Fonseca.

They showed how Mossack Fonseca has helped clients launder money, dodge sanctions and evade tax. The company says it has Read more

No comments | Tags: JITSIC, Joint International Tax Shelter Information and Collaboration, OECD, Panamanian Law Firm

14 Apr 2016

Written by Ronald Marini | Posted in International • JITSIC • OECD

OECD Ready to Act on Leaks From Panamanian Law Firm Mossack Fonseca

Government officials from around the world have called on the OECD to convene a special project meeting of the Joint International Tax Shelter Information and Collaboration (JITSIC) Network to explore possibilities of co-operation and information-sharing, identify tax compliance risks and agree collaborative action, in light of the “Panama Papers” revelations.

The so-called “Panama Papers” refer to the Huge Leak From the Read more

No comments | Tags: International Consortium of International Journalists, JITSIC, Leaks, Mossack Fonseca, OECD, Panama

11 Apr 2016

Written by William Byrnes | Posted in BEPS • FATCA • OVDP

Commentary on the The Panama Papers & The Disclosure of 14,000 Clients’ 214,000 Offshore Companies Files and Assets

A leak of searchable 11.5 million files, that’s 2.6 terabytes of data, from the embattled offshore services provider Mossack Fonseca. Every email, client note, asset and income statement, instruction, communication, .. since 1977! 2.6 terabytes of data, 11.5 million files, is a lot of files and scanned documents to comb through, so this leak is potentially, and probably, more significant than the 2014 ICIJ reported on leak or even the HSBC and UBS’ leaks. Read more

No comments | Tags: CRS, FATCA, mossack, OECD, offshore, panama papers

08 Jan 2016

Written by Ronald Marini | Posted in BEPS • G20 • OECD • Tax Legislation • Transfer Pricing

Transfer Pricing Moves Ahead: OECD and G20 Broaden Intra-Group Services Provisions

Transfer pricing methodologies are beginning to spread far beyond the narrow confines of section 482. Consider two very recent examples:

• Argentina had enacted revenue raising measures designed to penalize companies that would shift profits from Argentina to a tax haven. Argentina used an OECD BEPS transfer pricing rationale in enacting these anti-tax-haven provisions. Most Argentinian enterprises that make use of tax havens use Panama for that tax haven purpose, in part because of the commonality of language. Panama sued Argentina, arguing that the Argentinian tax restrictions are an artificial trade constraint. Panama brought suit at the World Trade Organization (WTO). Other countries are now involved. Panama won the initial round at the WTO, but Panama has joined the OECD’s Global Forum, a measure that would ultimately bring the country into compliance with the OECD’s Transfer Pricing Guidelines. Panama’s attack is similar to the attack on DISC before GATT three decades ago

No comments | Tags: Argentina, BEPS, company penalizations, EDITPA, G20, intra-group, language comminality, multinational, OECD, OECD BEPS, Panama, pricing rationale, services provisions, transfer pricing

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