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U.S. taxpayers who failed to file disclosure forms were alerted by the U.S. Treasury on September 21, 2009 of a one-time extension of time to October 15, 2009 to comply with the special voluntary disclosure requirements of the Internal Revenue Service for Americans with unreported income from bank accounts situated outside the United States. As a result, after the deadline passed, many amnesty filings were made with the U.S. Treasury.
The total amount of tax, interest and penalties assessed and collected were so significant to the Treasury that another voluntary tax amnesty program and period would be offered with less favorable terms.According to the latest information from the U.S. Treasury, more than 15,000 amnesty filings were made on or before the 15th day of October 2009. The IRS and the IRS Commissioner, Douglas Shulman, disclosed that even after the above deadline, an additional 3,000 taxpayers came forward to be in compliance with America’s tax laws in relation to foreign bank accounts.
IRS Commissioner Shulman stated:
"As I've said all along, the goal is to get people back into the U.S. tax system. Combating international tax evasion is a top priority for the IRS. We have additional cases and banks under review. The situation will just get worse in the months ahead for those hiding assets and income offshore. This new disclosure initiative is the last, best chance for people to get back into the system.", "As we continue to amass more information and pursue more people internationally, the risk to individuals hiding assets offshore is increasing…This new effort gives those hiding money in foreign accounts a tough, fair way to resolve their tax problems once and for all. And it gives people a chance to come in before we find them."
The voluntary amnesty program will be termed the "2011 Offshore Voluntary Disclosure Initiative" (OVDI) and, from what I have seen to date, will incorporate many of the items of the 2009 amnesty, both good and bad. Taxpayers participating in the new initiative must also file all original and amended tax returns and include payment for taxes, interest and accuracy-related penalties by the Aug. 31 deadline.
Tax specialists may make reference to a particular tax rule and continue to state that the rule had so many exceptions that it was like "the tail wagging the dog."
1. The above 25% penalty may be reduced to 5% in very special situations;
2. If your offshore accounts (and assets!) are less than $75,000 in any tax year from 2003 through 2010, then that year will face a reduced penalty from 25% to 12.5%. However, the tax, interest and accuracy related penalties will still apply in full, please see immediately below on the interest and accuracy related penalty.OVDI has increased the penalty to 25% of the amount in the foreign bank accounts in the year with the highest aggregate account balance while looking at a 7-year period, from 2003 through 2010. This 25% penalty will apply to most filers of the OVDI amnesty. In addition, amnesty filers will be required to accept and pay back any and all taxes, interest and accuracy related penalties with a total payoff of these taxes, and interest and penalties on or before the August 31, 2011 deadline.
3. As mentioned in the 2009 amnesty, the IRS continues to solicit compliance with the threat of "possible" criminal prosecution for taxpayers who do not come forward in the 2011 amnesty offering.
4. The 2011 initiative offers clear benefits to encourage taxpayers to come in now rather than risk IRS detection. Taxpayers hiding assets offshore who do not come forward will face far higher penalty scenarios as well as the possibility of criminal prosecution.
Sunday, April 24, 2011
Wednesday, April 20, 2011
Thai Baht Account
Thai Baht Account
Agreements and contracts on Agreements and Contracts
As a matter of fact, non-residents may also open and maintain a Thai Baht account with the authorized agents in Thailand. In addition to a passport, the authorized agents may also require a work permit (if any). What is more, the depositor will be requested to submit certain necessary documentary evidence, such as in the case of a deposit of Thai Baht derived from sale of foreign currency which originated from abroad--the evidence of such sale of foreign currency, or if derived from salary received while working in Thailand--the certificate of income from the employer. Similarly, the minimum amounts required for opening of different types of Thai Baht accounts may also be specified by the authorized agent with which the accounts are to be opened and maintained.
Agreements and contracts on Agreements and Contracts
As a matter of fact, non-residents may also open and maintain a Thai Baht account with the authorized agents in Thailand. In addition to a passport, the authorized agents may also require a work permit (if any). What is more, the depositor will be requested to submit certain necessary documentary evidence, such as in the case of a deposit of Thai Baht derived from sale of foreign currency which originated from abroad--the evidence of such sale of foreign currency, or if derived from salary received while working in Thailand--the certificate of income from the employer. Similarly, the minimum amounts required for opening of different types of Thai Baht accounts may also be specified by the authorized agent with which the accounts are to be opened and maintained.
Monday, March 14, 2011
Network/Social Ties and Supply Chain Links
Network/Social Ties and Supply Chain Links.
A number of recent studies have highlighted the importance of network/social ties and supply chain links in triggering SMEs‟ first internationalization step and extending internationalization processes. Both North American studies particularly reported the stimulating effect on export activity of firms ‟ soft assets, including social and network capital, some of which may have accrued through managers‟ immigrant background and associated links. The study among fish exporters from the Azores Islands, an autonomous Portuguese archipelago in the North Atlantic, some 900 miles from the European mainland, highlighted the importance of family and social ties with emigrant communities in global markets in driving SME internationalization (see Boxes 3 and 4)These include research among American, Australian, Canadian and Portuguese businesses. Kocker and Buhl also observed that taking advantage of collaborative links is a common motive among the firms they investigated across ten OECD countries.
Finally, it is important to mention the value of the linkages back to their birth countries that migrants can bring in arranging exporting opportunities [OECD CFE/SME(2008)5/PART1/REV1].
A number of recent studies have highlighted the importance of network/social ties and supply chain links in triggering SMEs‟ first internationalization step and extending internationalization processes. Both North American studies particularly reported the stimulating effect on export activity of firms ‟ soft assets, including social and network capital, some of which may have accrued through managers‟ immigrant background and associated links. The study among fish exporters from the Azores Islands, an autonomous Portuguese archipelago in the North Atlantic, some 900 miles from the European mainland, highlighted the importance of family and social ties with emigrant communities in global markets in driving SME internationalization (see Boxes 3 and 4)These include research among American, Australian, Canadian and Portuguese businesses. Kocker and Buhl also observed that taking advantage of collaborative links is a common motive among the firms they investigated across ten OECD countries.
Finally, it is important to mention the value of the linkages back to their birth countries that migrants can bring in arranging exporting opportunities [OECD CFE/SME(2008)5/PART1/REV1].
Growth Motives.
Growth Motives.
Growth opportunities associated with international markets were identified as a key driver of firm internationalization in several recent studies. Orser et al. (2008), for example, reports say that after allowing for the impacts of firm size and sector, Canadian legal firms whose owners had expressed growth intentions were more than twice as likely to export, than those whose owners did not indicate growth ambitions. Firms‟ overseas venturing decision also seems to be motivated by a need for business growth, profits, an increased market size, a stronger market position, and to reduce dependence on a single or smaller number of markets. The possibility of growth in other markets and increased profit opportunities from international expansion were highlighted as key stimuli for exporting among the Australian, British, Spanish, Swedish, and US firms investigated in recent studies.
Growth opportunities associated with international markets were identified as a key driver of firm internationalization in several recent studies. Orser et al. (2008), for example, reports say that after allowing for the impacts of firm size and sector, Canadian legal firms whose owners had expressed growth intentions were more than twice as likely to export, than those whose owners did not indicate growth ambitions. Firms‟ overseas venturing decision also seems to be motivated by a need for business growth, profits, an increased market size, a stronger market position, and to reduce dependence on a single or smaller number of markets. The possibility of growth in other markets and increased profit opportunities from international expansion were highlighted as key stimuli for exporting among the Australian, British, Spanish, Swedish, and US firms investigated in recent studies.
Wednesday, February 9, 2011
European Union Direct Taxes
Permanent Establishment is a vital concept in international taxation. While for direct taxes, it is mainly defined by the OECD Model Convention, the European VAT Directive and its implementing Regulation provide an EU-wide approach for VAT.
Difficulties arise as terminology and definitions in indirect and direct tax diverge. Moreover, countries have implemented and interpreted the EU and OECD rules in a different way, impacting on issues like cross-border reorganisations, transfer pricing, taxation of dividends and interest and royalties, tax residence, temporary and permanent transfer of assets, place of supply and VAT liability.
In both direct and indirect tax, the concept of Permanent Establishment has undergone very recent changes: The 2010 changes to the OECD Model Convention and Commentary, and in particular the new Art. 7, will be adopted in national law, as speakers from the Netherlands and Germany will report. The effect of the new definition on treaties with other countries will also be considered.
Some of this topic is addressed in the new book "European Union Direct Taxes", by the International Tax Professor Salvador Trinxet Llorca.
In indirect tax, the current more important issue is the practical consequences of the adoption of the Regulation implementing the EU VAT Directive in January 2011.
Difficulties arise as terminology and definitions in indirect and direct tax diverge. Moreover, countries have implemented and interpreted the EU and OECD rules in a different way, impacting on issues like cross-border reorganisations, transfer pricing, taxation of dividends and interest and royalties, tax residence, temporary and permanent transfer of assets, place of supply and VAT liability.
In both direct and indirect tax, the concept of Permanent Establishment has undergone very recent changes: The 2010 changes to the OECD Model Convention and Commentary, and in particular the new Art. 7, will be adopted in national law, as speakers from the Netherlands and Germany will report. The effect of the new definition on treaties with other countries will also be considered.
Some of this topic is addressed in the new book "European Union Direct Taxes", by the International Tax Professor Salvador Trinxet Llorca.
In indirect tax, the current more important issue is the practical consequences of the adoption of the Regulation implementing the EU VAT Directive in January 2011.
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