International Trade Finance & Banking Tax

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Worldwide Exchange of Tax Information: OECD Expands upon FATCA to Add New Requirements

While the Foreign Account Tax Compliance Act (FATCA) has focused worldwide attention on U.S. efforts to create a mandatory cross-border exchange of tax information, the enactment of FATCA was not an isolated occurrence. For...more

Currency Conversion Concerns: New York Issues Guidance on Virtual Currencies

On December 5, 2014, the New York Department of Taxation and Finance (Department) released TSB-M-14(5)C, (7)I, (17)S. This (relatively short) bulletin sets forth the treatment of convertible virtual currency for sales,...more

Bank Leumi Enters Into DPA with U.S. Department of Justice

A major Israeli international bank admitted that it conspired to aid and assist U.S. taxpayers to prepare and present false tax returns to the Internal Revenue Service (IRS) by hiding income and assets in offshore bank...more

UK Targets Corporate Profits Of Multinational Enterprises With Sweeping Tax Changes

On December 3, the UK Government announced its intention to introduce a new “diverted profits tax” (DPT) to take effect on April 1, 2015. Draft legislation was published on December 10 and is now subject to a public...more

Highlights of Final Regulations for Reporting of Specified Foreign Financial Assets

The Treasury Department has issued final regulations relating to reporting of specified foreign financial assets on Form 8938. The highlights include...more

IRS Simplifies Tax Reporting for Individuals With Canadian Retirement Plans

Under Article XVIII(7) of the United States-Canada Tax Treaty, a U.S. citizen or resident may elect to defer U.S. income taxation on income accruing under a Canadian registered retirement savings plan (RRSP) or registered...more

FCA Dismisses Lord Black’s Tax Appeal

Earlier this year, in Black v. HMQ (2014 TCC 12), Lord Conrad Black unsuccessfully argued in the Tax Court of Canada that, due to his U.K. residency status, he should not be subject to Canadian tax on certain income and...more

Hybrid Mismatches – UK Proposals for Implementing the BEPS Recommendations

The United Kingdom made its first substantive commitment arising out of the base erosion and profit shifting (BEPS) initiative on 3 December 2014, with the release of a consultation paper on implementing the agreed G20-...more

Spotlight On Federal Tax Developments In 2014

This article highlights a number of interesting federal tax developments that were brought to the table during the 2014 calendar year. Developments discussed in this article include the 18-month transitional period for the...more

2014 Year-End Tax Update

I. A LOOK BACK AT 2014 TAX MATTERS: A. Some Random Observations - ..1. This year’s update is brought to you by the letter “I,” as in “inversions.” ..2. Tired of waiting for Congress to address what they...more

FATCA Update: Treasury Extends Time for Jurisdictions with Agreed-in-Substance IGAs to be Treated as if They Had an IGA in Effect

On December 1, 2014, Treasury and the IRS issued Announcement 2014-38 which provides relief to those countries which have reached FATCA Intergovernmental Agreements (IGAs) in substance, but have not signed such agreements....more

The Financial Report - Volume 3, No. 22 • December 11, 2014 (Global)

Discussion and Analysis - Earlier this week, The Wall Street Journal published a special Journal Report entitled “CEO Council.” The tag line for the report ominously states: “At the annual meeting of The Wall Street...more

Diverted Profits Tax – First Thoughts

The UK Government intends to introduce a 25% “diverted profits tax” (DPT) from 1 April 2015. The tax is designed to catch the artificial erosion of the UK corporate tax base by multi-nationals that avoid establishing a...more

Via Libera Alla Voluntary Disclosure: Gli Aspetti Principali Della Disciplina In Attesa Della Pubblicazione In G.U.

E' in attesa di pubblicazione sulla Gazzetta Ufficiale il testo di legge approvato giovedì 4 dicembre dal Senato in materia di rientro dei capitali dall'estero (c.d. Voluntary Disclosure o Collaborazione Volontaria). Oltre...more

“Deoffshorization” measures

On 24 November 2014 the Russian President signed Federal Law No. 376-FZ “On amending parts one and two of the Tax Code of the Russian Federation (in the part related to taxation of profits of controlled foreign companies and...more

"UK Government Announces New 25 Percent Diverted Profits Tax"

On Wednesday, the U.K. Government released draft legislation to be effective on 1 April 2015, which will impose a “diverted profits tax” (DPT) at 25 percent of the amount of profits deemed to have been diverted from the U.K....more

Tax Alert: Commissionnaires and Other PE Structures under Scrutiny as Part of BEPS

The OECD has recently published a discussion draft on the portion of its BEPS action plan dealing with permanent establishments and has titled this paper, “Preventing the Artificial Avoidance of PE Status 1 The title itself...more

Singapore Signs FATCA IGA

On December 9, 2014, Singapore’s Inland Revenue Authority announced that Singapore and the United States had on that day entered into a Model 1 FATCA IGA. ...more

Cyprus and US sign FATCA IGA

On 2 December 2014, the US and Cyprus governments signed an intergovernmental agreement (IGA) to implement the Foreign Account Tax Compliance Act (FATCA). There are two types of IGAs known as "Model 1" and "Model 2". The...more

Autumn Statement 2014

Yesterday, the Chancellor of the Exchequer delivered the UK 2014 Autumn Statement. Below we summarise some of the main announcements: Taxation of multi-nationals - Diverted profits tax (aka the "Google tax")...more

FATCA in Cayman: Deadline Approaches

The deadline for compliance with both US FATCA and UK FATCA fast approaches. Cayman entities which are classified as Financial Institutions are within the scope of FATCA. A typical Cayman fund will fall within the...more

FATCA — Final Deadline to Obtain a GIIN for Model 1 IGA FFIs

Under transitional relief, certain non-U.S. investment funds, including Cayman Islands funds, that qualify as foreign financial institutions (FFIs), have been permitted to certify their status under the U.S. Foreign Account...more

Autumn Statement 2014

On December 3, 2014, George Osborne delivered his Autumn Statement. Traditionally, the purpose of this has been to update economic projections and department spending allocation, but increasingly it includes statements...more

2014 Proskauer Hedge Funds and Other Private Funds Annual Review

This year we saw a flurry of regulatory activity targeting investment advisers and hedge funds, private equity funds and other private funds (collectively, private funds). The following annual review is a summary of some of...more

Scheel-Utvalgets Utredning - Kapitalbeskatning I En Internasjonal Økonomi

Regjeringen Stoltenberg II nedsatte 15. mars 2013 et ekspertutvalg for å vurdere selskapsbeskatningen i lys av den internasjonale utviklingen. Den 2. desember 2014 la Scheel-utvalget frem sin innstilling. Innstillingen vil...more

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