DLA Piper - International Tax News

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.

Find out more.


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.

Find out more.


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.

Topics:  Australia, Banks, EU, Foreign Bank Accounts, Income Taxes, IRS, Tax Evasion, Tax Treaty, Voluntary Disclosure

Published In: General Business Updates, Finance & Banking Updates, International Trade Updates, Tax Updates

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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