News & Analysis as of

International Trade Finance & Banking Tax

Read need-to-know updates, commentary, and analysis on International Trade issues written by leading professionals.

UK Criminal Finances Act 2017: A Dechert "Dirty Money" Trilogy

by Dechert LLP on

Part One: "A Fistful of Tax Dollars" - A New Corporate Offence of Failure to Prevent the Facilitation of Tax Evasion.. The Criminal Finances Act 2017 represents a further significant development in the approach to the...more

Traps for the Unwary: Are Financial Institution receiving adequate FATCA consulting and training?

by Foodman CPAs & Advisors on

FATCA is Chapter 4 of the Internal Revenue Code (IRC). It conscripts Foreign Financial Institutions (FFIs) to act as reporting and withholding agents for the U.S. Government. To enforce its conscription, it contains a...more

Applying Overpayments of Tax to Tax and the Offshore Penalty in the OVDP Program

by Charles (Chuck) Rubin on

The OVDP program allows taxpayers to remedy deficient disclosure filings relating to offshore accounts for a fixed penalty amount. As part of the program, taxpayers must file either original or amended tax returns which...more

US Banks wanting to be ahead of the FATCA game must master international tax compliance

by Foodman CPAs & Advisors on

The terms FDAP (Fixed, Determinable Annual and Periodical Income) and ECI (Effectively Connected Income) are expansive terms. They are the backbone behind the tax withholding, and reporting requirements imposed on US Banks...more

The Summons

by Moskowitz LLP on

Coinbase is a San Francisco-based cryptocurrency exchange company that operates bitcoin and other digital asset transactions and storage for over one million users in 190 countries....more

Forfeiture Case Based on Alleged Elaborate $230 Million Russian Laundering and Fraud Scheme to Settle

by Ballard Spahr LLP on

On the eve of trial this past Friday, the government announced an agreement to settle, subject to court approval, a major civil forfeiture action in the Southern District of New York. In the case, United States v. Prevezon...more

Corporate and Financial Weekly Digest - Volume XII, Issue 18

SEC/CORPORATE - US District Court Holds That Discretionary Tax Withholding is Exempt Under 16b-3 - Several companies have received shareholder letters seeking to recover short-swing profits from insiders under Section...more

Corporate Criminal Offence: Failure to Prevent Facilitation of Tax Evasion

The Criminal Finance Act 2017 received Royal Assent on April 27, 2017, making its way onto the statute book before the halting of Parliamentary business ahead of this year’s general election. As well as giving enforcement...more

Ontario Introduces 15% Tax on Foreign Real Estate Buyers

by Dickinson Wright on

The Ontario government announced a new proposal to impose a 15 percent tax on purchases of residential real estate by foreign buyers as part of its Fair Housing Plan. Similar to the foreign buyer tax enacted last year by the...more

Developing a Strategy to Fight FBAR Penalties

by Carlton Fields on

Since 2009, the number of FBAR penalties imposed for failures to report foreign bank accounts and the size of the penalties have both increased dramatically. Originally published in The Tax Advisor....more

Lawyers as “Gate Keepers” – The European Parliament Examines the Roles of Attorneys in Tax Evasion and Laundering Schemes

by Ballard Spahr LLP on

Starting on April 27, and finishing on May 2, the European Parliament (EP)’s Committee of Inquiry into Money Laundering, Tax Avoidance and Tax Evasion (PANA) is holding two meetings to present several related studies which...more

ATO wins Full Federal Court decision on Cross Border Financing - Chevron Australia Holdings case

by DLA Piper on

In a major Australian transfer pricing decision on Friday 21 April 2017, the Full Federal Court dismissed Chevron Australia Holdings Pty Ltd's (CAHPL) appeal related to the deductibility of interest on the Australian dollar...more

Extensions to the double tax treaty passport scheme

by DLA Piper on

The double tax treaty passport (DTTP) scheme was introduced in 2010 as a mechanism to simplify the process by which non-UK lenders could receive interest payments from UK borrowers without deduction for withholding tax under...more

IRS Updates FATCA FAQs, Addresses January Temporary Regulations

by Proskauer - Tax Talks on

On April 6, 2017, the Internal Revenue Service (the IRS) added three new frequently asked questions to its Foreign Account Tax Compliance Act (“FATCA”) compliance page, which is available only online. These additional FAQs...more

Debit cards, Offshore Funds and a John Doe Summons

by Foodman CPAs & Advisors on

IRS remains committed to its priority efforts to stop offshore tax evasion wherever it occurs. It pursues cases in all jurisdictions of the world. Over the years, numerous individuals have been identified as evading US...more

IRS Targets Globally-Mobile Individuals and Businesses: The Importance of Proactive Planning

IRS targets globally-mobile individuals and businesses through its Global High Wealth Industry Group and its Large Business and International Division. Targeted taxpayers find these audits distracting, taking time from...more

Colombia criminaliza la evasión fiscal

by Foodman CPAs & Advisors on

El 12/29/2016, el Congreso de Colombia aprobó la "Ley 1819 de 2016". La nueva legislación es una reforma tributaria estructural encaminada principalmente a aumentar los ingresos para Colombia....more

Turning Tides

by DLA Piper on

Ukraine is typically seen as an emerging country, blighted by crisis. Ukrainians are all gradually helping to change this stereotype. Here we examine key legal reforms aimed at improving the efficiency and safety of...more

Your Daily Dose of Financial News

by Robins Kaplan LLP on

China’s infamous shadow banking industry—an $8.5 trillion marketplace that’s sprung up in reaction to the government’s “campaign against financial leverage”—is back and bigger than ever these days....more

New Due Date for “FBAR” Filings - Report of Foreign Bank and Financial Accounts now due on Tax Day, with auto-extension for six...

Federal law requires U.S. citizens and resident aliens to report world-wide income, including income from foreign trusts, bank and securities accounts. In addition to attaching Schedule B to their tax returns disclosing...more

Government Refuses to Define "willfulness" for FBAR Purposes

by Sanford Millar on

Whether a taxpayer's conduct in failing to report foreign financial accounts is "willful" or "non-willful" makes a huge difference in penalty determination. However the government refuses to publish a definition of...more

Foreign Investment in U.S. Real Property: Gift And Estate Tax Considerations

by Farrell Fritz, P.C. on

Last week, we reviewed the various U.S. federal income tax consequences that may be visited upon a foreign person who owns and operates U.S. real property (“USRP”). Today we will consider the U.S. federal gift and estate tax...more

Two Important New International Tax Filings

by Charles (Chuck) Rubin on

While not the only international reporting changes that are occurring, there are two significant ones that apply for the current filing season for 2016 returns. First is the FBAR, which reports interests in foreign...more

Investment Funds Update - Europe: Legal and regulatory updates for the funds industry from the key asset management centres and...

by Dechert LLP on

CSSF Press Release 17/06 Dated 13 February 2017 - The CSSF confirmed that it follows ESMA on its opinion in relation to the requirements for UCITS share classes....more

Bank of Italy Smooths the Path for Direct Debt Investment into Italy via EU Alternative Investment Funds

by McDermott Will & Emery on

International investment funds are set to benefit from measures issued by the Bank of Italy, aimed at facilitating direct investment into the country by EU alternative investment funds....more

1,766 Results
|
View per page
Page: of 71
Cybersecurity

Follow International Trade Updates on:

"My best business intelligence,
in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
Sign up using*

Already signed up? Log in here

*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
*With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name. Or, sign up using your email address.

Feedback? Tell us what you think of the new jdsupra.com!