Monthly Archives: May 2017

• a series of additional CRS-related Frequently Asked Questions; and
• the second edition of the Standard for Automatic Exchange of Financial Account Information in Tax Matters (also available in French and Spanish), which expands the last part on the CRS XML Schema User Guide. It also sets out additional technical guidance on the handling of corrections and cancellations within the CRS XML Schema, as well as a revised and expanded set of correction examples. The other parts remain unchanged relative to the first edition that was issued in 2014.

 Still Have Undeclared Income from Offshore Banks or 

Companies Located in One of These Reportable Jurisdictions?

 

 

 

Want to Know if the OVDP Program is Right for You?

 

Contact the Tax Lawyers at 

Marini& Associates, P.A.  

 

 

for a FREE Tax Consultation

at: www.TaxAid.com or www.OVDPLaw.com or

Toll Free at 888-8TaxAid (888) 882-9243

  

Two weeks before the first OECD Common Reporting Standard (CRS) reporting deadline of  May 31, Barbados, Curacao, and Niue and Trinidad and Tobago have been withdrawn from the OECD list of reportable jurisdictions for 2017, and have been moved to the list of reportable jurisdictions for 2018.

The following are now the Reportable Jurisdictions for the 2017 reporting year, in respect of 2016 reportable accounts:

1. Austria,
2. Argentina,
3. Belgium,
4. Bulgaria,
5. Colombia,
6. Croatia,
7. Cyprus,
8. Czech Republic,
9. Denmark,
10. Estonia,
11. Faroe Islands,
12. Finland,
13. France,
14. Germany,
15. Gibraltar,
16. Greece,
17. Greenland,
18. Guernsey,
19. Hungary,
20. Iceland,
21. India,
22. Ireland,
23. Isle of Man,
24. Italy,
25. Jersey,
26. Korea,
27. Latvia,
28. Liechtenstein,
29. Lithuania,
30. Luxembourg,
31. Malta,
32. Mexico,
33. Montserrat,
34. Netherlands,
35. Norway,
36. Poland,
37. Portugal,
38. Romania,
39. San Marino,
40. Seychelles,
41. Slovakia,
42. Slovenia,
43. South Africa,
44. Spain,
45. Sweden, and
46. the UK.

The UK tax authority is advising financial institutions that have already compiled their files to submit them anyway if they are unable to remove data on financial accounts for the four jurisdictions that have been withdrawn from the 2017 OECD list, until 2018.

Sources

• HMRC

According to various news reports, US multinationals are "pushing" the US government to further reduce the tax rate on offshore profits. Major U.S. multinationals are pushing the Trump administration to deepen the tax break it has already tentatively proposed on $2.6 trillion in corporate profits being held offshore by more than 500 U.S. companies.
 
Nearly a third of that is held by 10 companies, including Apple, Microsoft Corp, Pfizer Inc and General Electric Co, the firm said.

These companies and hundreds of others could bring their foreign profits into the United States at any time, but they do not in order to avoid paying the 35-percent tax due.
 
President Trump's tax reform proposed to reduce the tax rate on the repatriation of offshore profits to 10 percent from 35 percent. However, lobbyists are making an aggressive case that cutting the tax rate on offshore profits to 10, as the administration has indicated it may favor, is not enough.
 
They propose a bifurcated rate of 3.5 percent on earnings already invested abroad in illiquid assets, and 8.75 percent on cash and liquid assets.  Lobbyists are telling the White House and Treasury Department that if companies are forced to bring home, or repatriate, foreign earnings, they want a sharply reduced tax rate".
 
The deferral rule has incentivized multinationals to park profits offshore and about $2.6 trillion in earnings is being held overseas by more than 500 U.S. companies, according to Audit Analytics, a corporate research firm.
 
Nearly a third of that is held by 10 companies, including Apple, Microsoft Corp, Pfizer Inc. and General Electric Co. All four of those companies declined to comment. These companies and hundreds of others could bring their foreign profits into the United States at any time, but they do not in order to avoid paying the current 35-percent tax due.
                                 

If the $2.6 trillion overseas were repatriated at once, two things would happen. First, Washington would get a big jolt of tax revenue. Second, repatriated profits not collected by the Internal Revenue Service could be put to use in the economy.

The repatriation tax break now being discussed differs from Bush's: repatriation would not be voluntary, but mandatory, so foreign profits would have to be brought home.

In addition, lobbyists said they have talked to the administration about ending deferral and exempting foreign profits from taxation. The administration has floated this as an option. Lobbyists said there has been discussion about limiting that exemption to 95 percent of repatriated foreign earnings. 

Sources:


Reuters
CNBC
President Trump (Contract with the American Voter, PDF)