The Swiss Supreme Court has provided some guidance on the ambit of a ‘fishing expedition’ under OECD provisions related to exchange of information; and set out in Article 26 of the OECD Model Tax Agreement. Since 2012, when the OECD Model was amended to reflect the current formulation of Article 26 on Exchange of … More Exchange of Confidential Tax-Payer Information: No Name? No Problem
I AM NOT A FAN OF THE USE OF UNILATERAL MEASURES IN international diplomacy; including the use of tax haven or other types of blacklists related to compliance with global norms on transparency and information exchange. Although we often think of this kind of state action in the context of armed conflict where there are … More OP-ED: Why Europe is Ill-Suited For The Business of Blacklisting So-Called ‘Non-Cooperative’ Jurisdictions.
The European Commission published on Thursday a list of 81 countries and jurisdictions that have a higher chance of facilitating tax avoidance and may be subject to further screening and even sanctions if all EU states agree. The “scoreboard” is the first step in a process that should be concluded next year with the first European … More ALERT: EU Issues Tax Haven Blacklist of 81 Countries Highly Likely to Facilitate Tax Avoidance
(Jane Ellison, Financial Secretary to the Treasury) Here is Why You Need to Know Now. Suppose: John Combos devises a tax avoidance scheme aimed at contractors and freelancers, requiring them to become employees of a special purpose employer and to receive money in the form of loans. A company is created to become the employer of … More Are You a Tax Avoidance ‘Enabler’?
FRANHENDY ATTORNEYS WEEKLY REPORT TAX Big banks are backing a proposed law that would require companies to disclose more information about their ownership, citing the help this would provide in fighting financial crime as the same time as it might reduce compliance costs. The Clearing House Association, a payments and advocacy organization owned by some of … More FHA Weekly Report (August 11, 2016)
FRANHENDY ATTORNEYS WEEKLY REPORT TAX Is Africa now being carved up by a complicated web of offshore accounts, tax havens and tricky paper trails? New research seems to suggest this is exactly what’s going on. Offshore companies connected to 44 of Africa’s 54 countries disturbingly appear in the Panama Papers leak. Over 1,400 companies in the … More What You May Have Missed This Week…
First a FATCA refresher: FATCA is the acronym for the provisions under the the US Foreign Account Tax compliance Act which became law in March 2010. FATCA targets tax non-compliance by U.S. taxpayers with foreign accounts. FATCA focuses on reporting by U.S. taxpayers about certain foreign financial accounts and offshore assets by foreign financial institutions about … More FATCA Update.