Sweden – Intergovernmental agreement under FATCA
The US and Sweden have reached substantial agreement on the content of an intergovernmental agreement (IGA) in relation to the US FATCA regulations. The aim of such agreements is to allow the relevant information required by FATCA to be exchange
See MoreUS and Hong Kong- tax information exchange agreement (TIEA)
On April 25 2014 Hong Kong gazetted the tax information exchange agreement (TIEA) with the United States. The agreement will take effect after the relevant legislative procedures have been completed. The OECD has been encouraging the conclusion of
See MoreFATCA agreement between Australia and United States signed
Australia and the United States signed an agreement relating to US Foreign Account Tax Compliance Act (FATCA) on 28 April 2014. These intergovernmental agreements are being concluded by the US in connection with the implementation of the FATCA in
See MoreUS : Persons holding PFIC stock through tax-exempt organizations or accounts will be exempt from Form 8621 filing requirements
In the US the definition of a shareholder for the purpose of the Section 1291 regulations has been amended by Notice 2014-28. Under this section a special tax and interest charge is levied on a US person has shares in a passive foreign investment
See MoreUS: ATR finds that Obama has proposed 442 tax hikes
The organization known as Americans for Tax Reform (ATR) has calculated that since 2009 President Obama has proposed 442 tax increases. This figure results from a survey of the budgets for the fiscal years 2010 to 2015. In addition to these tax
See MoreUS – More taxpayers e-filing from home computers
An internal report issued by the Treasury Inspector General for Tax Administration (TIGTA) indicates that more US taxpayers are using e-filing to submit their tax returns and that more tax refunds are being issued. By 7 March 2014 more than 90
See MoreUS – IRS issues 2014 foreign housing tax deduction limits
In the US the Internal Revenue Service (IRS) has issued Notice 2014-29. The Notice sets out the inflation-adjusted limitations in respect of foreign housing expenses for tax year 2014. The figures included in the Notice show that Hong Kong, Moscow,
See MoreUS: GAO Reports that Large Partnerships are Avoiding the IRS Net
In a preliminary report from the United States Government Accountability Office (GAO) it is shown that the IRS is currently conducting a tax audit in respect of only around one percent of the largest partnerships in the US. The GAO report suggests
See MoreUS: Annual study shows heavy tax compliance burdens
According to the US National Taxpayers Union (NTU) the US has lost billions of hours of productivity owing to the burden of compliance with the complex tax code. The NTU has computed the total cost of tax compliance at USD224.3bn a year. This
See MoreUS: Budget proposals for 2015 have implications on inbound investors
In March 2014, the Obama Administration (the Administration) released its fiscal year 2015 Budget proposals (the Budget). In addition to the transfer pricing rules the earnings stripping rules also apply to transactions with foreign related parties
See MoreUS: Tax Foundation Considers Future of US Tax Breaks
The Tax Foundation (TF) in the US considers that a number of corporate and individual tax breaks should be recognized as fulfilling a beneficial purpose, even though the US government is currently considering their abolition. Many of the tax breaks
See MoreUS: IRS Gives Bonuses to Tax-Delinquent Employees
In the US the Treasury Inspector General for Tax Administration (TIGTA) provides independent oversight of the activities of the Internal Revenue Service (IRS). TIGTA aims to ensure economy and efficiency of administration within the IRS and is
See MoreFATCA agreement between Belgium and the US
An intergovernmental agreement (IGA) between Belgium and the US is to be signed on 23 April 2014 in relation to the implementation of the US Foreign Account Tax Compliance Act (FATCA). The IGA requires the tax administrations of the two countries to
See MoreItaly Consults on FATCA Agreement with US
Italy commenced a consultation on 23 April 2014 on the content of the inter-governmental agreement (IGA), concluded on 10 January 2014, to carry out the requirements of the Foreign Account Tax Compliance Act (FATCA) between Italy and the United
See MoreUS: IRS Should Improve Efficiency to Counteract Reduced Funding
The United States Government Accountability Office (GAO) is an independent agency that reports to the Congress and is often referred to as the congressional watchdog. The organization is headed up by the Comptroller General of the United States and
See MoreUS Pension Uptake Lags Despite Tax Incentives
In order to encourage taxpayers to make provision for their pensions various incentives are provided by the tax system. The US Government Accountability Office (GAO) has however reported that the number of new pension plans taken out by individuals
See MoreTax Freedom Day Comes Later For US Taxpayers
An organization known as the Tax Foundation (TF) computes the date of a day called Tax Freedom Day each year. This date is found by applying the average tax burden, expressed as a percentage, to the number of days in the year. The Tax Freedom Day is
See MoreUS: IRS Confirms Deductibility of Puerto Rican Excise Tax
The IRS has confirmed in a document published recently (Letter 2014-0006) that the IRS will not challenge the claim that Puerto Rico’s manufacturers excise tax is a tax that can be credited against United States federal income tax. In October
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