US-SWISS VOLUNTARY DISCLOSURE PROGRAM: DEADLINES ARE LOOMING – SWISS BANKS NEED NOT PANIC, BUT MUST ACT SWIFTLY AND THOUGHTFULLY
By Michael Legamaro, Peter Zeidenberg and Dominique Christin*
The recently announced voluntary bank disclosure program between Switzerland and the US offers worried Swiss banks the possibility of peace of mind from future prosecution. The question now confronting Swiss banks is whether to take advantage of this program and, if so, how best to enter the program.
While these decisions are, of course, extremely important, Swiss banks should not necessarily be feeling a sense of panic or dread. Department of Justice guidelines and policies dictate that it consider a broad set of factors before determining to bring a prosecution. Only after analyzing the results of a careful, internal review can a bank realistically consider the potential risk it is facing and whether the new program is a wise option. The threshold question a Swiss bank should confront is whether it should even enter the program.
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FAVORABLE IRS RULING FOR US TAXPAYER ON APPLICATION OF US-CYPRUS TAX TREATY
By Eric D. Ryan and Anil Kalia
In a recent internal legal memorandum, the IRS concluded that a US individual was entitled to treat dividends received from a Cypriot holding company with no Cypriot ownership as qualified dividend income, and thereby is eligible for reduced US income tax rates.
Cyprus, a member of the European Union, is generally regarded as a favorable finance and holding company location, due to its relatively low income tax regime and favorable withholding tax network.
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AUSTRALIA: GOVERNMENT UPDATES TAX PROPOSALS: KEY POINTS FOR BUSINESS
By Jock McCormack, Matthew Cridland, James Newnham and Anshu Maharaj
In the past 12 years, the Australian government has announced 96 tax measures which have still not been legislated. Some of these measures have created uncertainty for taxpayers, who must decide whether they should arrange their tax affairs based on an announced proposal or existing legislation.
This month, Australia’s treasurer and assistant treasurer issued a join press release outlining the government’s intentions regarding almost all of these measures.
The measures deal with a broad range of issues, among them corporate tax, R&D incentives, Managed Investment Trust rules and superannuation.
In this alert, we review these tax measures that are of the greatest relevance to business. Find out more here.
* Dominique Christin is a partner with BCCC, based in Geneva and Lausanne.