Category Taxation in North America

IRS Leniency Program to be Extended

September 21, 2009 Offshore BankingTaxation in EUTaxation in SwitzerlandTaxation in USA  No comments

The US Internal Revenue Service (IRS) will extend the deadline for those wishing to apply for the offshore account declaration leniency program.

Originally scheduled to end on the 23rd of September, the IRS’s leniency program promised to reduce penalties paid by those declaring their UBS accounts. Applications for the program have significantly increased following a settlement between the IRS and Swiss bank UBS, which saw the details of 4,450 American owned accounts promised to the IRS. According to IRS officials, over 3,000 applications for the leniency program have been received since the institution of the program. The IRS has stated that approximately 10,000 cases are expected to arise in regards to UBS, half of these will be through the voluntary disclosure program.

Typically, the ...

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Tax Information Exchange Agreement Update

September 10, 2009 International Tax CooperationOffshore BankingTax HavensTaxation in AustraliaTaxation in British Virgin IslandsTaxation in CanadaTaxation in Cayman IslandsTaxation in EUTaxation in FranceTaxation in GermanyTaxation in IrelandTaxation in LiechtensteinTaxation in MonacoTaxation in New ZealandTaxation in Turks & Caicos IslandsTaxation in UKTaxation in USA  No comments

Since the April G20 summit, over 50 new TIEA agreements have been signed across the globe.

The London G20 Summit, held on the 2nd of April this year, heralded an unprecedented wave of Tax Information Exchange Agreement (TIEA). In what was described as “revolutionary” by Angel Gurría, OECD Secretary-General, the number of completed TIEAs has almost doubled since their inception in late 2000.
Since the G20 summit, and subsequent global push for greater tax transparency and compliance, the following 53 agreements have been signed.

United States – Monaco (8 September 2009)
Denmark – Turks & Caicos Islands (7 September 2009)
Netherlands – Antigua & Barbuda (2 September 2009)
Denmark – Gibraltar (2 September 2009)
Denmark – Anguilla (2 September 2009)
Germany – Liechtenstein (2 September ...

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Monaco and US Sign Tax Agreement

September 9, 2009 International Tax CooperationOffshore BankingTaxation in MonacoTaxation in USA  No comments

Monaco and the US signed a bilateral Tax Information Exchange Agreement on the 8th of September.

The Taxation Information Exchange Agreement (TIEA) between the city-state of Monaco and the US will allow each jurisdiction a greater set of capabilities in fighting cross border tax evasion. The agreement will allow either nation to request bank, tax and other information from the other jurisdiction on the grounds that there have already been reasonable attempts made to obtain it by other means. The agreement also extends to allow officials from one country to enter the other for the purpose of conducting necessary interviews. Although, these capabilities are restricted to a case by case basis and have absolutely no scope “information fishing”...

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Canada to Follow US with UBS

August 27, 2009 International Tax CooperationOffshore BankingTaxation in CanadaTaxation in Switzerland  No comments

The Canadian Revenue Agency have announced that they will enter into discussion with Swiss bank UBS in regards to possible tax evasion information.

Following swiftly upon news that the US Government and UBS had reached a settlement in their offshore account tax evasion dispute, the Canadian Revenue Agency (CRA) has announced that they too will engage in discussions with UBS in regards to divulging information about Canadian national tax evaders.

On the 21st of August it was announced by Jean-Pierre Blackburn, Canadian National Revenue Minister, that the Canadian Government will approach UBS in an effort to uncover information about Canadians using offshore accounts with UBS to evade their tax liability. The meetings have been scheduled for the 2nd of September...

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UBS US Case Agreement Revealed

August 20, 2009 International Tax CooperationOffshore BankingTaxation in SwitzerlandTaxation in USA  No comments

The US Senate and the Swiss bank UBS, have revealed details of their tax evasion case agreement.

An end has come to the long running legal dispute between the Inland Revenue Service (IRS) and UBS, an agreement has been reached, the details of which have now been revealed. The data behind 4,450 accounts held by US residents with UBS will be handed over to the IRS, all connected with tax evasion suspicions. Current IRS valuations of assets held in the accounts are at approximately US$18 billion, if valued at their peak over the last six years. No word has yet come from the IRS as to penalties that will be charged to any found to be evading tax, although, no possibility of a new leniency programs has yet been voiced by the IRS...

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