Attorneys at Law. 11th Annual International Estate Planning Institute New York City, 12 & 13 March 2015
|
|
- Lucy Wiggins
- 6 years ago
- Views:
Transcription
1 FATCA Implementation Attorneys at Law 11th Annual International Estate Planning Institute New York City, 12 & 13 March 2015 Presenters: Anthony Cetta: Citi Trust Wealth Planner, Citigroup (New York, NY) Peter A. Cotorceanu, Of Counsel, Anaford Attorneys at Law, Zurich, Switzerland 0
2 Heads Up These slides were prepared by Peter Cotorceanu of Anaford Attorneys at Law The views expressed in this presentation are the presenters alone and do not necessarily reflect the views of their respective firms 1
3 Goals of Presentation Compare and contrast how FATCA and OECD GATCA apply to the trust industry Discuss select practical issues that have arisen in FATCA s implementation KISSS: Stupid, (Keep it Simple (and Slow) but still pitched at 3 levels 2
4 Part 1 FATCA and OECD Global FATCA (GATCA)
5 GATCA Coming soon (very, very soon) to a country near you... Early adopters : 01/01/2016 go-live date for newaccount onboarding; first reports due in Other non-early adopters have committed to same date. Yet others (including Singapore and Switzerland) have committed to 01/01/2017 go-live date for new-account onboarding; first reports due in Heavily based on FATCA, esp. reciprocal Model 1 IGA 4
6 GATCA 45 Early Adopters Argentina Finland Liechtenstein Seychelles U.K. OTs: Belgium France Lithuania Slovenia Anguilla Bulgaria Germany Malta South Africa Colombia Greece Mexico Spain BVI Croatia Hungary Netherlands Sweden Bermuda Caymans Cyprus Iceland Norway U.K. Montserra t Czech Republic India Poland U.K. CDs: T&Cs Denmark Ireland Portugal Isle of Man Note: Not Gibraltar Estonia Italy Romania Guernsey Faroe Islands Latvia Seychelles Slovakia Jersey 5
7 GATCA On 29 October 2014, 51 countries signed a Multi- Lateral Competent Authority Agreement. As of 19 November 2014, the number had increased to 52. In addition to most of the early adopters group (but not Bulgaria, India, or Seychelles), the following countries have signed the agreement: Albania, Aruba, Austria, Curaçao, Gibraltar, Korea, Luxembourg, Mauritius, San Marino, Switzerland 6
8 GATCA 4 Basic Elements: Model (Reciprocal) Competent Authority Agreement (CAA): Contains some definitions Details information to be exchanged, time and manner of exchange, etc. Common Reporting Standard (CRS): Contains due diligence requirements (e.g., new and pre-existing accounts, individual and entity accounts) Many more definitions Some Non-Reporting FI categories 7
9 GATCA Commentaries on both CAA and CRS (approx. 150 pages) Various Annexes, e.g., Multilateral and Non- Reciprocal versions of CAA, CRS Schema, etc. 8
10 GATCA FATCA GATCA Reciprocal Model 1 IGA Model CAA Annex I CRS Annex 2 CRS Guidance Notes Commentaries 9
11 GATCA and FATCA Compared All reporting to home country (a là Model 1 IGA) Under GATCA, no central registration (but individual countries may require) No GIIN under GATCA No withholding under GATCA 10
12 GATCA and FATCA Compared GATCA has fewer deemed compliant/nonreporting categories (e.g., no sponsored categories but does include Trustee- Documented Trusts and possibility of using third-party service providers) Under GATCA, IE FIs in non-participating jurisdictions treated as passive NFEEs (but U.S. gets a pass! Or does it? And what about real passive NFFEs in non-participating jurisdictions?) 11
13 GATCA and FATCA Compared GATCA based on residency only (citizenship irrelevant) GATCA has no USD 50,000 exclusion for preexisting individual accounts. Under GATCA and Model 1 IGA, USD 250,000 exclusion for pre-existing entity accounts allowed only if participating country permits (under Model 2 IGA, exclusion is at election of FI) 12
14 GATCA and FATCA Compared Under GATCA, different start dates depending on when country enters into agreements with different countries potential for huge mess if not replaced with Big Bang start Under GATCA, need to report date of birth (not required under FATCA) GATCA has no standardised forms such as W- 8BEN-E and W-8IMY 13
15 GATCA and FATCA Compared Definition of managed Investment Entity FIs: GATCA uses Regs version (i.e., both Managed By and Gross Income tests), not IGA version (only Managed By test) Protectors who are Controlling Persons of FI trusts: select Model 1 IGA Guidance: Only protectors with power to hire and fire GATCA all protectors 14
16 GATCA and FATCA Compared Discretionary benes as account holders in FI trusts: FATCA Regs and Model 2 IGAs: Only if receive a distribution Model 1 IGAs: All discretionary benes (except as modified by local implementing law/guidance) GATCA: Only if distribution has been paid or made payable 15
17 GATCA and FATCA Compared Discretionary benes as Controlling Persons of passive NFFE trusts: IGAs: Interpret consistently with FATF Recs., i.e., benes described by class or characteristics can be identified at time of payout or when bene intends to exercise vested rights GATCA: Same, but country may allow local FIs to align definition with definition of account holder in FI trust (i.e., discretionary benes included only if distribution has been paid or made payable ) 16
18 Part 2 Select Implementation Issues under FATCA
19 Key Implementation Issues under FATCA Which FATCA rules apply? In general In defining U.S. Controlling Persons of passive NFFEs Entity classification, e.g., PTCs, corporate directors Accounts in FFI trusts Substantial U.S. Owners/ U.S. Controlling Persons of passive NFFEs 18
20 Questions? (Note: I am in Singapore all this week) 19
21 Contact information Peter A. Cotorceanu Attorney-at-Law (U.S.A. (Md. & Va.)) Barrister and Solicitor (New Zealand) Of Counsel Anaford AG Tödistr Zurich (0) (Main) +41 (0) (Direct) +41 (0) (Mobile) +41 (0) (Fax) 20
22 Disclaimer This Presentation is intended solely for information purposes. The views contained in this Presentation may be altered at any time. Although Anaford AG has taken all reasonable care to ensure that the information contained in this presentation is accurate at the time of publication, the details in this presentation do not represent decision-making aids for legal, tax or other matters. Before taking any action, you should consider the suitability of the action to your particular circumstances and discuss with your professional advisers as necessary the specific risks as well as the tax, legal, regulatory, and other implications. Anaford AG would be pleased to provide you with any legal and tax advice on these matters upon your request. 21
23 Copyright All rights reserved. 22
STANDARD FOR AUTOMATIC EXCHANGE OF FINANCIAL ACCOUNT INFORMATION. Philip Kerfs, OECD
STANDARD FOR AUTOMATIC EXCHANGE OF FINANCIAL ACCOUNT INFORMATION Philip Kerfs, OECD Overview Background, context and timeline The Standard: basic approach and key features Next steps: implementing the
More informationIntercontinental Trust Ltd COMMON REPORTING STANDARD
Intercontinental Trust Ltd COMMON REPORTING STANDARD 1 Conspectus The OECD, working in collaboration with G20 and in close co-operation with the EU, has developed a global standard for automatic exchange
More informationTHE COMMON REPORTING STANDARD ("CRS") UPDATE FOR OCORIAN CLIENTS
JERSEY BRIEFING November 2015 THE COMMON REPORTING STANDARD ("CRS") UPDATE FOR OCORIAN CLIENTS At present 93 countries will implement CRS over a two year period commencing 1 January 2016. The CRS initiative
More informationOECD Common Reporting Standard Getting into the Detail STEP / GAT
OECD Common Reporting Standard Getting into the Detail STEP / GAT Jo Huxtable Martin Popplewell 11 February 2016 Agenda Introduction CRS and the wider regulatory environment CRS latest developments and
More informationTAXATION (IMPLEMENTATION) (CONVENTION ON MUTUAL ADMINISTRATIVE ASSISTANCE IN TAX MATTERS) (AMENDMENT OF REGULATIONS No. 3) (JERSEY) ORDER 2017
Taxation (Implementation) (Convention on Mutual Regulations No. 3) (Jersey) Order 2017 Article 1 TAXATION (IMPLEMENTATION) (CONVENTION ON MUTUAL ADMINISTRATIVE ASSISTANCE IN TAX MATTERS) (AMENDMENT OF
More informationTRUST AND SETTLEMENT DETAILS FORM
FOR USE IN CAYMAN, DUBLIN AND JERSEY TRUST AND SETTLEMENT DETAILS FORM IMPORTANT: ALL SECTIONS MUST BE COMPLETED Name of proposed new entity: (if known) Name of trust: Date trust established: Proper law
More informationFATCA Update May 2014
www.pwc.com The Basics Foreign Account Tax Compliance Act Purpose of Prevent and detect offshore tax evasion by US citizens Increased information reporting Enforced by withholding tax Effective begins
More informationWebinar: Common Reporting Standard. Game Plan for Compliance December 10, 2015
Webinar: Common Reporting Standard Game Plan for Compliance December 10, 2015 Presenters Moderator: Sara Pereda Director DMS Offshore Investment Services Roman Ipfling Director DMS International Tax Compliance
More informationUPDATE. COMMON REPORTING STANDARD IN THE CAYMAN ISLANDS. What is CRS? Participating Jurisdictions
www.kensington-trust.com UPDATE COMMON REPORTING STANDARD IN THE CAYMAN ISLANDS The Cayman Islands Tax Information Authority (International Tax Compliance) (Common Reporting Standard) Regulations, 2015
More informationCOMPANY DETAILS FORM
FOR USE IN JERSEY COMPANY DETAILS FORM IMPORTANT: ALL SECTIONS MUST BE COMPLETED Name of proposed new entity: (if known) Name of applicant company: Company type: (please tick one box) Quoted on a stock
More informationWhen will CbC reports need to be filled?
Who will be subject to CbCR? Country by Country Reporting (CbCR) applies to multinational companies (MNCs) with a combined revenue of euros 750 million or more When will CbC reports need to be filled?
More informationTax certification for Entities FATCA and CRS
Schroder Investment Management Australia Limited Level 20, Angel Place 123 Pitt Street Sydney, NSW 2000 www.schroders.com.au AFSL 226473 ABN 22 000 443 274 Tax certification for Entities FATCA and CRS
More informationCOMPANY DETAILS FORM
FOR USE IN MAURITIUS COMPANY DETAILS FORM IMPORTANT: ALL SECTIONS MUST BE COMPLETED Name of proposed new entity: (if known) Name of applicant company: Company type: (please tick one box) Quoted on a stock
More informationFATCA: Developments & perspectives
FATCA: Developments & perspectives Automatic Exchange of Information 22 May 2014 FATCA evolves into CRS a multilateral automatic exchange of information 2010 The Foreign Account Tax Compliance Act (FATCA)
More informationPARTNERSHIP DETAILS FORM
FOR USE IN SINGAPORE PARTNERSHIP DETAILS FORM IMPORTANT: ALL SECTIONS MUST BE COMPLETED Name of proposed new entity (if known) Name of applicant partnership Form of applicant partnership Partnership Limited
More informationFACT SHEET. Automatic exchange of information (AEOI)
FACT SHEET Automatic exchange of information (AEOI) In a joint statement, a number of countries, including all major financial centres and Liechtenstein, have announced that they will introduce the new
More informationTHE MULTILATERAL CONVENTION ON MUTUAL ADMINISTRATIVE ASSISTANCE IN TAX MATTERS AND THE PATH TO THE OECD-STANDARD ON AUTOMATIC EXCHANGE OF INFORMATION
THE MULTILATERAL CONVENTION ON MUTUAL ADMINISTRATIVE ASSISTANCE IN TAX MATTERS AND THE PATH TO THE OECD-STANDARD ON AUTOMATIC EXCHANGE OF INFORMATION Dr. Achim Pross Head of International Cooperation and
More informationForeign Account Tax Compliance Act (FATCA)
Foreign Account Tax Compliance Act (FATCA) Andrea Garcia Castelao November 18, 2013 Foreign Account Tax Compliance Act (FATCA) 0 2013 Deloitte Tax LLP FATCA Update Final FATCA regulations were released
More informationMEXICO - INTERNATIONAL TAX UPDATE -
TTN Conference May 2017 MEXICO - INTERNATIONAL TAX UPDATE - Arturo G. Brook Main Taxes Income Tax Value Added Tax Others Agenda DTTs and TIEAs FATCA (IGA) and CRS Choice of Vehicles Income Tax - General
More informationAUTOMATIC EXCHANGE OF INFORMATION (AEOI)
AUTOMATIC EXCHANGE OF INFORMATION (AEOI) As the world becomes increasingly globalised, money can be transferred from one jurisdiction to another with ease. While this may help to facilitate trade and boost
More informationSpain France. England Netherlands. Wales Ukraine. Republic of Ireland Czech Republic. Romania Albania. Serbia Israel. FYR Macedonia Latvia
Germany Belgium Portugal Spain France Switzerland Italy England Netherlands Iceland Poland Croatia Slovakia Russia Austria Wales Ukraine Sweden Bosnia-Herzegovina Republic of Ireland Czech Republic Turkey
More informationFACT SHEET. Automatic exchange of information (AEOI)
FACT SHEET Automatic exchange of information (AEOI) In a joint statement, a number of countries, including all major financial centres and Liechtenstein, have announced that they will introduce the new
More informationArgentina Tax amnesty: the day after
Argentina Tax amnesty: the day after Walter C. Keiniger December 2016 YES to amnesty: exchange of Information DTTs (Art. 26 OECD Model) Provisions or agreements signed by Argentina Bilateral Agreements
More informationRSM AND HFMWEEK CRS/FATCA SURVEY HOW DO FUNDS INTEND TO ADDRESS CRS AND FATCA COMPLIANCE CHALLENGES?
RSM AND HFMWEEK CRS/FATCA SURVEY HOW DO FUNDS INTEND TO ADDRESS CRS AND FATCA COMPLIANCE CHALLENGES? During the third quarter of 2016, RSM and Hedge Fund Management Week (HFMWeek) surveyed chief operating
More informationTAXATION (IMPLEMENTATION) (INTERNATIONAL TAX COMPLIANCE) (COMMON REPORTING STANDARD) (JERSEY) REGULATIONS 2015
Arrangement TAXATION (IMPLEMENTATION) (INTERNATIONAL TAX COMPLIANCE) (COMMON REPORTING STANDARD) (JERSEY) REGULATIONS 2015 Arrangement Regulation 1 Interpretation... 3 2 Meaning of relevant date and relevant
More informationCOMBATTING OFFSHORE TAX EVASION FROM THE FINANCIAL INSTITUTION S PERSPECTIVE
GLOBAL INVESTIGATIONS & COMPLIANCE ELLEN ZIMILES Financial Services Advisory and Compliance Segment Leader Head of Global Investigations and Compliance +1.212.554.2602 ellen.zimiles@navigant.com RICHARD
More information- Act Nr. XXXVII of 2013 on certain regulation connected with the international administrative cooperation on tax and other public burdens.
Dear Customer, The Hungarian Parliament introduced the Common Reporting Standards, CRS on the automatic financial data exchange with the effect of 01.01.2016. The aim of the regulation is to hinder the
More informationCOSTAS TSIELEPIS & CO LTD
COSTAS TSIELEPIS & CO LTD TAX UPDATE Authored By: ALEXIS TSIELEPIS, Director, Head of Taxation VOLUME 5, ISSUE 2 knowledge Facts, information and skills acquired through experience or education; the theoretical
More informationConvention on Mutual Administrative Assistance in Tax Matters
Convention on Mutual Administrative Assistance in Tax Matters Strasbourg, 25.I.1988 Annex B Competent authorities (*) European Treaty Series - No. 127 States From A to F Albania Argentina Australia Austria
More informationSAINT CHRISTOPHER AND NEVIS STATUTORY RULES AND ORDERS. No. 32 of 2016
1 SAINT CHRISTOPHER AND NEVIS STATUTORY RULES AND ORDERS No. 32 of 2016 Common Reporting Standard (Automatic Exchange of Financial Account Information) Regulations The Minister, in exercise of the powers
More informationFATCA. Its Implications for the Financial Services Industry in Belize (A Banking Perspective) February 19, 2015 Aldo J. Salazar
FATCA Its Implications for the Financial Services Industry in Belize (A Banking Perspective) February 19, 2015 Aldo J. Salazar Introduction The Foreign Account Tax Compliance Act (FATCA) was signed into
More informationA guide to FACTA and the new Common Reporting Standard. For advisers use only.
A guide to FACTA and the new Common Reporting Standard For advisers use only. Contents 01 Introduction 01 Background 02 How are we complying with FACTA in the UK? 02 How are we complying with FACTA in
More informationForeign Account Tax Compliance Act (FATCA)
Foreign Account Tax Compliance Act (FATCA) Impact Assessment on the Financial Services (Banking and Insurance) sectors and businesses in Trinidad and Tobago Presentation by the Bankers Association of Trinidad
More informationApproach to Employment Injury (EI) compensation benefits in the EU and OECD
Approach to (EI) compensation benefits in the EU and OECD The benefits of protection can be divided in three main groups. The cash benefits include disability pensions, survivor's pensions and other short-
More informationFATCA: THE NEXT PHASE Thursday 05 March 2015
FATCA: THE NEXT PHASE Thursday 05 March 2015 Martin Popplewell & Paul Woodman (Deloitte) Lorraine Wheeler (First Names Group) - Chair STEP Jersey is sponsored by: STEP Jersey FATCA The Next Phase Martin
More informationCRS Form for Tax Residency Self Certification For Individuals, Joint Accounts (CRS I)
For Individuals, Joint Accounts (CRS I) Please read these instructions carefully before completing the form Chapter XIIA of Income Tax Rules, 2002 and Regulations based on the OECD Common Reporting Standard
More informationFATCA: The final regulations have landed let the games begin
FATCA: The final regulations have landed let the games begin By Anthony Quinn In January the United States Treasury Department released the final regulations relating to the U.S. Foreign Account Tax Compliance
More informationSummary of key findings
1 VAT/GST treatment of cross-border services: 2017 survey Supplies of e-services to consumers (B2C) (see footnote 1) Supplies of e-services to businesses (B2B) 1(a). Is a non-resident 1(b). If there is
More informationTAX TRANSPARENCY THE NEW GLOBAL REPORTING STANDARD
TAX TRANSPARENCY THE NEW GLOBAL REPORTING STANDARD 2 TAX TRANSPARENCY THE NEW GLOBAL REPORTING STANDARD A COMMON REPORTING STANDARD ACROSS THE WORLD The goalposts in international tax reporting are moving
More informationTax Game Changers Yair Zorea, Tax Partner, PwC Israel Yitzhak Zahavy, Tax Supervisor, PwC Israel November 2015
www.pwc.com/il Tax Game Changers Yair Zorea, Tax Partner, Yitzhak Zahavy, Tax Supervisor, November 2015 Agenda FATCA Common Reporting Standard IRS Audit Trends A look under the hood 2 FATCA 3 Foreign Account
More informationFiduciary and Investment Risk Management Association 28 th National Risk Management Training Conference
Fiduciary and Investment Risk Management Association 28 th National Risk Management Training Conference Foreign Account Tax Compliance Act: Considerations for Trusts April 30, 2014 Michael Shepard Principal
More informationRev. Proc Implementation of Nonresident Alien Deposit Interest Regulations
Rev. Proc. 2012-24 Implementation of Nonresident Alien Deposit Interest Regulations SECTION 1. PURPOSE Sections 1.6049-4(b)(5) and 1.6049-8 of the Income Tax Regulations, as revised by TD 9584, require
More informationConvention on Mutual Administrative Assistance in Tax Matters as amended by the 2010 Protocol
European Treaty Series - No. 127 Convention on Mutual Administrative Assistance in Tax Matters as amended by the 2010 Protocol Strasbourg, 1.VI.2011 Annex B Competent authorities (*) States From A to F
More informationThe Global Tax Reset 2017 Audit Committee Symposium
The Global Tax Reset Copyright 2017 Deloitte Development LLC. All rights reserved. 2017 Audit Committee Symposium Anticipate. Navigate. Focus. 1 The Global Tax Reset General context Multinational companies
More informationIRS Reporting Rules. Reference Guide. serving the people who serve the world
IRS Reporting Rules Reference Guide serving the people who serve the world The United States has and continues to maintain a policy of not taxing the deposit interest earned by United States (US) nonresidents
More informationFATCA Update: Final Regulations, IGAs and their Impact on Trusts and Trust Companies
FATCA Update: Final Regulations, IGAs and their Impact on Trusts and Trust Companies June 2013 Background On March 18, 2010, President Obama signed the Hiring Incentives to Restore Employment Act of 2010
More informationDouble tax considerations on certain personal retirement scheme benefits
www.pwc.com/mt The elimination of double taxation on benefits paid out of certain Maltese personal retirement schemes February 2016 Double tax considerations on certain personal retirement scheme benefits
More informationVinodh & Muthu. Tax Alert. Insight. Chartered Accountants. Country by Country Reporting & Master File
Vinodh & Muthu Chartered Accountants Tax Alert Country by Country Reporting & Master File Insight The Organisation for Economic Cooperation and Development ( OECD ) report on Action 13 of Base Erosion
More informationAPA & MAP COUNTRY GUIDE 2017 DENMARK
APA & MAP COUNTRY GUIDE 2017 DENMARK Managing uncertainty in the new tax environment DENMARK KEY FEATURES Competent authority Danish Tax Office ( SKAT ) APA provisions/ guidance Types of APAs available
More informationGENERAL ANTI AVOIDANCE RULE RECENT CASE LAW IN ARGENTINA
GENERAL ANTI AVOIDANCE RULE RECENT CASE LAW IN ARGENTINA Leandro M. Passarella Passarella Abogados TTN Conferences Latin America 2014 Buenos Aires November 17, 2014 Background Past structures Case Law
More informationGUERNSEY. Sections 75C and 75CC of the Income Tax (Guernsey) Law, 1975
GUERNSEY Sections 75C and 75CC of the Income Tax (Guernsey) Law, 1975 75C. Notices under section 75A and 75B: requests for information. 75CC. Implementation of approved international agreements by regulation.
More informationGuide to Treatment of Withholding Tax Rates. January 2018
Guide to Treatment of Withholding Tax Rates Contents 1. Introduction 1 1.1. Aims of the Guide 1 1.2. Withholding Tax Definition 1 1.3. Double Taxation Treaties 1 1.4. Information Sources 1 1.5. Guide Upkeep
More informationCayman Islands - FATCA and CRS Top tips & pitfalls to avoid in 2018
Cayman Islands - FATCA and CRS Top tips & pitfalls to avoid in 018 In this article we share our tips for reporting success for a Cayman Investment Entity Financial Institution (FI) and common pitfalls
More informationGlobal Forum on Transparency and Exchange of Information for Tax Purposes. Statement of Outcomes
Global Forum on Transparency and Exchange of Information for Tax Purposes Statement of Outcomes 1. On 25-26 October 2011, over 250 delegates from 84 jurisdictions and 9 international organisations and
More informationFATCA: THE 2014 HORIZON
FATCA: THE 2014 HORIZON Breakout Session 5C FIBA 2014 AML Compliance Conference February 21, 2014 Gabriel Caballero, Esq. Gunster, Yoakley & Stewart, P.A. 2 South Biscayne Boulevard Suite #3400 Miami,
More informationPENTA CLO 2 B.V. (the "Issuer")
THIS NOTICE CONTAINS IMPORTANT INFORMATION OF INTEREST TO THE REGISTERED AND BENEFICIAL OWNERS OF THE NOTES (AS DEFINED BELOW). IF APPLICABLE, ALL DEPOSITARIES, CUSTODIANS AND OTHER INTERMEDIARIES RECEIVING
More informationFATCA: Developments & Perspective
www.pwc.de FATCA: Developments & Perspective Luxembourg May 5, 2014 Agenda Section 1: Section 2: Section 3: Section 4: Section 5: Introduction Update to the Financial Account Tax Compliance Act Update
More informationFATCA, Foreign Trusts and Estate Planning: Navigating Complex Reporting and Withholding Requirements
Presenting a live 90-minute webinar with interactive Q&A FATCA, Foreign Trusts and Estate Planning: Navigating Complex Reporting and Withholding Requirements TUESDAY, SEPTEMBER 22, 2015 1pm Eastern 12pm
More informationReporting practices for domestic and total debt securities
Last updated: 27 November 2017 Reporting practices for domestic and total debt securities While the BIS debt securities statistics are in principle harmonised with the recommendations in the Handbook on
More informationEU-28 RECOVERED PAPER STATISTICS. Mr. Giampiero MAGNAGHI On behalf of EuRIC
EU-28 RECOVERED PAPER STATISTICS Mr. Giampiero MAGNAGHI On behalf of EuRIC CONTENTS EU-28 Paper and Board: Consumption and Production EU-28 Recovered Paper: Effective Consumption and Collection EU-28 -
More informationSTOXX EMERGING MARKETS INDICES. UNDERSTANDA RULES-BA EMERGING MARK TRANSPARENT SIMPLE
STOXX Limited STOXX EMERGING MARKETS INDICES. EMERGING MARK RULES-BA TRANSPARENT UNDERSTANDA SIMPLE MARKET CLASSIF INTRODUCTION. Many investors are seeking to embrace emerging market investments, because
More informationKPMG s Individual Income Tax and Social Security Rate Survey 2009 TAX
KPMG s Individual Income Tax and Social Security Rate Survey 2009 TAX B KPMG s Individual Income Tax and Social Security Rate Survey 2009 KPMG s Individual Income Tax and Social Security Rate Survey 2009
More informationDouble Tax Treaties. Necessity of Declaration on Tax Beneficial Ownership In case of capital gains tax. DTA Country Withholding Tax Rates (%)
Double Tax Treaties DTA Country Withholding Tax Rates (%) Albania 0 0 5/10 1 No No No Armenia 5/10 9 0 5/10 1 Yes 2 No Yes Australia 10 0 15 No No No Austria 0 0 10 No No No Azerbaijan 8 0 8 Yes No Yes
More informationFATCA: More than a Five Letter Word NACUBO Tax Forum 2014
FATCA: More than a Five Letter Word NACUBO Tax Forum 2014 Presented by: Nicole Bencik, Partner, Crowe Horwath LLP John Kelleher, Partner Crowe Horwath LLP Joel Levenson, Associate Director: Tax Compliance,
More informationTRANS WORLD COMPLIANCE, INC. CARIBBEAN ASSOCIATION OF BANKS, INC. & BARBADOS INTERNATIONAL BUSINESS ASSOC. Presents: FATCA compliance update
TRANS WORLD COMPLIANCE, INC. IN PARTNERSHIP WITH CARIBBEAN ASSOCIATION OF BANKS, INC. & BARBADOS INTERNATIONAL BUSINESS ASSOC. Presents: FATCA compliance update AGENDA Current FATCA status / update FATCA
More informationFrequently Asked Questions (FAQ) CRS
Frequently Asked Questions (FAQ) CRS Contents General... 1 Accounts of Individuals... 3 Accounts of Legal Entities... 6 Glossary... 9 General What is the Standard for Automatic Exchange of Financial Information
More informationa closer look GLOBAL TAX WEEKLY ISSUE 249 AUGUST 17, 2017
GLOBAL TAX WEEKLY a closer look ISSUE 249 AUGUST 17, 2017 SUBJECTS TRANSFER PRICING INTELLECTUAL PROPERTY VAT, GST AND SALES TAX CORPORATE TAXATION INDIVIDUAL TAXATION REAL ESTATE AND PROPERTY TAXES INTERNATIONAL
More informationAgreements with other countries
Agreements with other countries - Introduction 070310 070313 Agreements with other countries Introduction 070310 The United Kingdom has reciprocal agreements with both European Economic Area countries
More informationCB CROSS BORDER YOUR GOAL. OUR MISSION.
CB CROSS BORDER YOUR GOAL. OUR MISSION. Your Chosen Counsel Because We care We are an international private wealth advisory We specialize in providing offshore solutions crossborderworldwide.com What we
More informationImplications of FATCA for legal entities
Implications of FATCA for legal entities April 2015 Introduction FATCA and its context Page 3 Section 1 Application variants and entities concerned Page 4 Section 2 Classification of entities under FATCA
More informationMalta s Double Tax Treaties
Malta s Double Treaties February 216 In order to encourage the growth of international trade including that of financial services, successive Maltese governments have sought to conclude double tax treaties
More informationFATCA FAQS FATCA AND THE MOVEMENT TO HARMONISE INTERNATIONAL TAX COMPLIANCE AND TRANSPARENCY
FATCA FAQS FATCA AND THE MOVEMENT TO HARMONISE INTERNATIONAL TAX COMPLIANCE AND TRANSPARENCY The last decade has seen an extraordinary number of tax information exchange agreements (TIEAs), which the Organisation
More informationCountry-by-Country Reporting:
-by- Reporting: Notifications Last updated: December 5, 2017 Notifications OECD Model Rule, Article 3. Notifications. Where a Constituent Entity of an MNE Group that is... not the Ultimate Parent Entity
More informationUpdate on Jurisdictions Treated as Having an IGA in Effect and on FATCA Financial Institution Registration
Part IV Items of General Interest Update on Jurisdictions Treated as Having an IGA in Effect and on FATCA Financial Institution Registration Announcement 2014-17 Since the 2012 release of the Model 1 and
More informationMalta s Double Tax Treaties
Malta s Double Tax Treaties November 216 In order to encourage the growth of international trade including that of financial services, successive Maltese governments have sought to conclude double tax
More informationBULGARIAN TRADE WITH EU IN THE PERIOD JANUARY - APRIL 2017 (PRELIMINARY DATA)
BULGARIAN TRADE WITH EU IN THE PERIOD JANUARY - APRIL 2017 (PRELIMINARY DATA) In the period January - April 2017 Bulgarian exports to the EU increased by 8.6% 2016 and amounted to 10 418.6 Million BGN
More informationBULGARIAN TRADE WITH EU IN THE PERIOD JANUARY - MAY 2017 (PRELIMINARY DATA)
BULGARIAN TRADE WITH EU IN THE PERIOD JANUARY - MAY 2017 (PRELIMINARY DATA) In the period January - May 2017 Bulgarian exports to the EU increased by 10.8% 2016 and added up to 13 283.0 Million BGN (Annex,
More informationMalta Country Profile
Malta Country Profile EU Tax Centre June 2017 Key tax factors for efficient cross-border business and investment involving Malta EU Member State Yes. Double Tax Treaties With: Albania Australia Austria
More informationThe European Union Savings Tax Directive. An historic guide
The European Union Savings Tax Directive An historic guide Do you have any questions? This guide will tell you more If you are resident in an EU Member State and earn interest on deposits or investments
More informationa closer look GLOBAL TAX WEEKLY ISSUE 204 OCTOBER 6, 2016
GLOBAL TAX WEEKLY a closer look ISSUE 204 OCTOBER 6, 2016 SUBJECTS TRANSFER PRICING INTELLECTUAL PROPERTY VAT, GST AND SALES TAX CORPORATE TAXATION INDIVIDUAL TAXATION REAL ESTATE AND PROPERTY TAXES INTERNATIONAL
More informationNinth Annual Domestic Tax Conference. 24 April 2014 New York City
Ninth Annual Domestic Tax Conference 24 April 2014 New York City Information reporting and withholding Impact of FATCA on USWA IRS Circular 230 disclosure Any US tax advice contained herein was not intended
More informationOrganisation de Coopération et de Développement Économiques Organisation for Economic Co-operation and Development
Unclassified English/French Unclassified Organisation de Coopération et de Développement Économiques Organisation for Economic Co-operation and Development 25-Sep-2009 English/French COUNCIL Council DECISION
More information55/2005 and 78/2005 Convention on automatic exchange of information
INCOME TAX TREATIES AND AGREEMENTS ON THE TAXATION OF INCOME FROM SAV- INGS (IN FORCE, SIGNED, INITIALLED OR IN NEGOTIATING PROCESS, SITUATION ON 25th April 2018) Country Year of conclusion Number in the
More informationTotal Imports by Volume (Gallons per Country)
3/7/2018 Imports by Volume (Gallons per Country) YTD YTD Country 01/2017 01/2018 % Change 2017 2018 % Change MEXICO 54,235,419 58,937,856 8.7 % 54,235,419 58,937,856 8.7 % NETHERLANDS 12,265,935 10,356,183
More informationGeneral introduction on FATCA
General introduction on FATCA By Dr. Zhan Hao and He Shan from AnJie Law Firm At present, most Chinese financial institutions are paying quite close attention to the ongoing process of Chinese participation
More informationOpen Day 2017 Clearstream execution-to-custody integration Valentin Nehls / Jan Willems. 5 October 2017
Open Day 2017 Clearstream execution-to-custody integration Valentin Nehls / Jan Willems 5 October 2017 Deutsche Börse Group 1 Settlement services: single point of access to cost-effective, low risk and
More informationReport Penalties and measures imposed under the UCITS Directive in 2016 and 2017
Report Penalties and measures imposed under the Directive in 206 and 207 4 April 209 ESMA34-45-65 4 April 209 ESMA34-45-65 Table of Contents Executive Summary... 3 2 Background and relevant regulatory
More informationItaly amends white list
26 August 2016 Global Tax Alert Italy amends white list EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: www.ey.com/taxalerts Executive
More informationRegistration of Foreign Limited Partnerships in the Cayman Islands
Registration of Foreign Limited Partnerships in the Cayman Islands Preface This publication has been prepared for the assistance of those who are considering registration of a foreign limited partnership
More informationFinancial wealth of private households worldwide
Economic Research Financial wealth of private households worldwide Munich, October 217 Recovery in turbulent times Assets and liabilities of private households worldwide in EUR trillion and annualrate
More informationEuropean Advertising Business Climate Index Q4 2016/Q #AdIndex2017
European Advertising Business Climate Index Q4 216/Q1 217 ABOUT Quarterly survey of European advertising and market research companies Provides information about: managers assessment of their business
More informationTotal Imports by Volume (Gallons per Country)
10/5/2017 Imports by Volume (Gallons per Country) YTD YTD Country 08/2016 08/2017 % Change 2016 2017 % Change MEXICO 51,349,849 67,180,788 30.8 % 475,806,632 503,129,061 5.7 % NETHERLANDS 12,756,776 12,954,789
More informationJapan s DTA Strategy and its Implications to Developing Countries. April 9 th, 2015 Kentaro Ogata
Japan s DTA Strategy and its Implications to Developing Countries April 9 th, 2015 Kentaro Ogata Table of Contents Role of DTA DTA strategy: basics JP and DC perspectives New initiatives Growing focus
More informationTotal Imports by Volume (Gallons per Country)
1/5/2018 Imports by Volume (Gallons per Country) YTD YTD Country 11/2016 11/2017 % Change 2016 2017 % Change MEXICO 50,994,409 48,959,909 (4.0)% 631,442,105 657,851,150 4.2 % NETHERLANDS 9,378,351 11,903,919
More informationEU BUDGET AND NATIONAL BUDGETS
DIRECTORATE GENERAL FOR INTERNAL POLICIES POLICY DEPARTMENT ON BUDGETARY AFFAIRS EU BUDGET AND NATIONAL BUDGETS 1999-2009 October 2010 INDEX Foreward 3 Table 1. EU and National budgets 1999-2009; EU-27
More informationMalta Country Profile
Malta Country Profile EU Tax Centre June 2018 Key tax factors for efficient cross-border business and investment involving Malta EU Member State Yes. Double Tax Treaties With: Albania Andorra Australia
More informationREPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS
EUROPEAN COMMISSION Brussels,.4.29 COM(28) 86 final/ 2 ANNEXES to 3 ANNEX to the REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE
More informationTax Management International Journal
Tax Management International Journal Reproduced with permission from Tax Management International Journal, 43 TMIJ 540, 09/12/2014. Copyright 2014 by The Bureau of National Affairs, Inc. (800-372- 1033)
More informationTotal Imports by Volume (Gallons per Country)
11/2/2018 Imports by Volume (Gallons per Country) YTD YTD Country 09/2017 09/2018 % Change 2017 2018 % Change MEXICO 49,299,573 57,635,840 16.9 % 552,428,635 601,679,687 8.9 % NETHERLANDS 11,656,759 13,024,144
More informationTotal Imports by Volume (Gallons per Country)
2/6/2019 Imports by Volume (Gallons per Country) YTD YTD Country 11/2017 11/2018 % Change 2017 2018 % Change MEXICO 48,959,909 54,285,392 10.9 % 657,851,150 716,916,480 9.0 % NETHERLANDS 11,903,919 10,024,814
More information