United States of America – Offshore Voluntary Disclosure Program (OVDP) will be closing effective September 28, 2018
The IRS rolled out its first Offshore Voluntary Disclosure Program in 2009 in an effort bring taxpayers with undisclosed foreign accounts and assets into compliance with U.S. tax laws. Although the 2009 OVDP ended in October of the same year, the IRS launched subsequent voluntary disclosure initiatives, including the 2011 Offshore Voluntary Disclosure Initiative (OVDI) and the 2012 Offshore...
United States of America – Individual Taxpayer Identification Numbers set to expire
The US Internal Revenue Service (IRS) announced that a number of Individual Taxpayer Identification Numbers (ITINs) will expire by December 31, 2018. The affected ITINs include the middle digits 73, 74, 75, 76, 77, 81, or 82. In addition, ITINs not used at least once on a federal tax return in the past three years will also expire.
Even though these expired ITINs can still be used on...
The Netherlands, U.S., U.K., Canada and Australia form international tax enforcement group
Leaders of tax enforcement authorities from the abovementioned countries have formed a multi-lateral tax enforcement group, Joint Chiefs of Global Tax Enforcement (J5), to collaborate in fighting international and transnational tax crimes and money laundering.
Membership of the J5 includes the heads of tax crime and senior officials from the Dutch Fiscal Information and Investigation Service...
India – Reporting of Existing Foreign Direct Investment (“FDI”) to the Reserve Bank of India (RBI)
With the objective of integrating the extant reporting structures of various types of foreign investment in India, the Reserve Bank will introduce a Single Master Form (SMF). The SMF would provide an online facility for reporting total foreign investment in an Indian entity, and also investment by persons resident outside India in an Investment Vehicle. Prior to the implementation of the SMF,...
Secondment of employees – Final vote reached by EU on equal pay and working conditions
Under the revised rules voted by the European Parliament on May 29, 2018, employees seconded temporarily to another EU country must get equal pay for equal work in the same place. The revised rules aim to ensure better protection for seconded employees and fair competition for companies.
All of the host country’s remuneration rules must apply to these employees. In addition to legal...
Cross border tax advice – New EU Mandatory Disclosure Rules for intermediaries
The Council of the EU came to an agreement on a Council Directive (“Directive”) regarding mandatory disclosure rules for intermediaries such as tax advisors, lawyers and accountants.
The Council adopted the directive for greater transparency in combating cross-border aggressive tax planning. This Mandatory Disclosure Directive has been adopted without debate. On March 13, 2018, the...
The Netherlands – As of January 1, 2019 the maximum period of the 30% ruling may be reduced from 8 to 5 years, for both new and existing cases.
As part of the Tax Plan for 2019, the Dutch State Secretary of Finance has submitted a bill to reduce the maximum term of the 30% ruling from 8 to 5 years.
If approved by the Dutch Parliament, the new rule regarding the 30% ruling will enter into force as of January 1, 2019. The changes will affect both new and existing cases.
This means that an employee who has obtained the 30% ruling for 8...
End of Year Tax planning 2017-18
As the end of another tax year approaches, we are writing with a summary of tax planning ideas which may be of interest to you.
Please call if you would like to discuss anything mentioned in this document, with a view to taking action before 6 April 2018 as we would be delighted to help.
Tax-free allowances on property and trading income
From 6 April 2017, you can get up to £1,000 a...
United States of America – Offshore Voluntary Disclosure Program (OVDP) closes on September 28, 2018
The Internal Revenue Service (IRS) announced that it will begin to ramp down the 2014 Offshore Voluntary Disclosure Program (OVDP) and close the program on September 28, 2018. By alerting taxpayers now, the IRS intends that any U.S. taxpayers with undisclosed foreign financial assets have time to use the OVDP before the program closes.
“Taxpayers have had several years to come into...
Tax advantageous structures to be disclosed by advisors
The OECD issued new model disclosure rules that require lawyers, accountants, financial advisors, banks and any other service providers to inform the tax authorities of any schemes they have put in place for their clients to avoid reporting under the Common Reporting Standard (CRS) or prevent the identification of the beneficial owners of entities or trusts.
As the reporting and automatic...