May 18th, 2012
It is well known in the international tax forums that US citizens tax planning is an impossible mission.
As reported in the LA Times: Facebook’s Eduardo Saverin gives up citizenship: Shrewd tax move?
“Here’s a tax tip for Mark Zuckerberg: Give up your U.S. citizenship. The 27-year-old Facebook Inc. founder could face a tax bill of more than $1 billion after the company’s initial public offering, expected next week. His former Harvard classmate who is known as “the other Facebook founder” may have found a way to cut the bill. Eduardo Saverin, who now lives in Singapore, has given up his U.S. citizenship. Tax experts say it’s a shrewd move. Saverin, who was immortalized in the film “The Social Network” as Zuckerberg’s contentious former friend and business partner, has a 4% stake in the company, according to the Who Owns Facebook? website. His stake could be worth nearly $4 billion after the IPO.
“It’s definitely savvy tax planning,” said Edward D. Kleinbard, a professor of law at USC who specializes in federal tax policy and international taxation. “He can argue that the value of the Facebook shares in September, when he gave up his citizenship, were significantly less than the value that will be set at the IPO next week.”
Saverin’s spokeswoman said his decision to jump ship had nothing to do with the upcoming IPO and the potential tax liability. Read the rest of this entry »
May 16th, 2012
10/05/2012 - The OECD’s Task Force on Tax and Development, meeting in Cape Town, South Africa, has launched the concept of Tax Inspectors Without Borders/ Inspecteurs des impôts sans frontières – a new initiative to help developing countries bolster their domestic revenues by making their tax systems fairer and more effective. Building on that concept, the OECD will establish an independent foundation, to be up and running by the end of 2013, that will provide international auditing expertise and advice to help developing countries better address tax base erosion, including tax evasion and avoidance. The initiative was championed by Oupa Magashula, Commissioner General of the South Africa Revenue Service, Nhlanhla Nene, South Africa’s Deputy Finance Minister and Pascal Saint-Amans, Director the OECD’s Centre for Tax Policy and Administration.
The stakeholders from business, civil society, as well as OECD and developing country governments attending the Tax and Development Task Force unanimously welcomed the initiative which fills a gap in the existing provision of audit assistance. They agreed to work together to launch a sustainably financed independent organisation to host a Tax Inspectors Without Borders secretariat by the end of next year. This initiative complements several efforts by donor agencies, notably USAID, to mobilise expertise. Read the rest of this entry »
May 4th, 2012
As reported by FC Business, Football League clubs took a huge step to self sufficiency when they agreed to the implementation of Financial Fair Play (FFP) regulations last week. Based on the UEFA model, Championship clubs will have until the 2014/15 season to get their house in order or face stiff penalties.
Leagues One and Two will also introduce a version based on limiting a club’s spending on player wages as a proportion of total turnover. A similar rule has been in place in the League Two for a number of years now. Read the rest of this entry »
April 30th, 2012
The average tax burden on earnings in OECD countries continues to rise
Published in OECD Tax News – 25/04/2012
25/04/012 – The average tax and social security burden on employment incomes increased in 26 out of 34 OECD countries in 2011 according to the new OECD Taxing Wages publication. Tax payers in Ireland, Luxembourg, Portugal and the Slovak Republic were among those hit with the largest increases. Those in New Zealand and the United States saw their tax burden fall. In Hungary, the average single worker without children was faced with the largest increase in the tax wedge, but for families with children, it fell.
In most countries the higher overall tax burden was due to personal income tax, rather than increased Social Security Contributions. Only 5 countries raised their statutory tax rates on average earnings. In most cases the rise in the tax burden was due to a higher proportion of earnings being subject to tax because the value of tax free allowances and tax credits fell relative to earnings. In a few countries including the Czech Republic, Hungary and Ireland they were actually reduced in nominal terms.
Taxing Wages provides nationally comparative details about the taxation of employment incomes and the associated costs to employers for different household types and at different earnings levels. These are the key factors in determining the incentives both for individuals to seek work and for businesses to hire workers. Read the rest of this entry »
April 24th, 2012
The latest edition of Tax Justice Focus explores how the Occupy Movement has changed public attitudes, not least to tax justice. In Autumn 2010 demonstrators from UK Uncut started to protest against deals being struck between prominent multinational companies and the British government. Their campaign inspired US Uncut. The latter merged with other groups to create Occupy Wall Street, and suddenly the international political and media establishments began to take notice of tax justice in a way that would have been inconceivable just eighteen months ago.
To reflect this seismic shift in the profile of tax justice we asked the Economics Working Group at Occupy at Saint Pauls in London to act as guest editor for this edition. Working with our new editor, Dan Hind, they have jointly commissioned the four feature articles published here.
In their article, Zoë Young and Jamie Kelsey offer insights into the techniques used in the many Occupy assemblies and working groups around the world. Read the rest of this entry »
April 23rd, 2012
UK Tax Budget 2012 – The Association of Taxation Technicians has produced a Special Report on the March Budget in their April 2012 Newsletter. The full Report is detailed below:
The contents of George Osborne’s third Budget were so well rehearsed that the real thing threatened to be an anti-climax. Was there anything left that the Chancellor could surprise us with, especially as he had such little fiscal room for manoeuvre?
The answer was both yes and no. After all the income tax rumours, Mr Osborne decided to make the change to 45% from April 2013. His 2013/14 increase in the personal allowance allowed him to start phasing out the age allowance – an unexpected revenue-raising ploy.
Income tax bands, rates and personal allowances All income tax rates for 2012/13 will remain at their 2011/12 levels. For 2013/14 the personal allowance will rise from £8,105 to £9,205 and there will be a £2,125 reduction in the basic rate limit from £34,370 to £32,245.
From 2013/14, there will be no increase in the age-related personal allowances and their availability will be restricted to people born before 6 April 1948 for the allowance worth £10,500, and 6 April 1938 for the allowance worth £10,660. The aim is to phase out the age-related allowances within a few years. For 2013/14 the additional rate of tax will be reduced from 50% to 45% (from 42.5% to 37.5% for dividends). The rates of tax for trusts will be similarly reduced.
A cap on unlimited income tax reliefs will apply to income tax reliefs that individuals will be able to claim from 6 April 2013. The cap will apply only to reliefs that are currently unlimited – e.g. qualifying interest payments. For anyone seeking to claim more than £50,000 in reliefs, a cap will be set at 25% of income (or £50,000, whichever is greater). Read the rest of this entry »
April 12th, 2012
05/04/2012 – The Global Forum on Transparency and Exchange of Information for Tax Purposes has just completed peer reviews of another 11 jurisdictions.
Reports on Brazil, Chile, Costa Rica, Cyprus, the Czech Republic, Guatemala, Malta, Mexico, Saint Vincent and the Grenadines and the Slovak Republic evaluate whether their national laws allow transparency and international exchange of tax information (Phase 1). The review of Korea also looked at the effectiveness of Korea’s exchange of information in practice (Phase 1 plus Phase 2). These reports bring to a total of 70 the number of peer review the Global Forum has completed since March 2010.
The Global Forum also issued 3 supplementary reports – for Barbados, Bermuda and Qatar – which assess the whether these jurisdictions have acted upon the Forum’s recommendations to improve agreements and legislation. All three jurisdictions’ compliance with the international standards has progressing significantly. The Phase 2 reviews for Bermuda and Qatar will take place in the second half of 2012 and for Barbados in the first half of 2013. Read the rest of this entry »
April 10th, 2012
On March 30, 2012, the Spanish government announced the 2012 budget. At the same time, the government approved Royal Decree-Law 12/2012, which introduces a number of relevant changes in the corporate tax area, including new limitations on the deductibility of interest expense.
Following a trend started by other European governments, the Spanish government has introduced an interest-capping rule that replaces the existing thin capitalization provisions. The new interest-capping rule, which will apply to both related- and unrelated-party debt, limits tax relief for net interest expense to 30 percent of the taxpayer’s earnings before interest, taxes, depreciation, and amortization (“EBITDA”), with some adjustments. For entities that are part of a tax consolidated group, this 30-percent limit will apply to the EBITDA of the group. Read the rest of this entry »