FATCA Reporting Woes

The Internal Revenue Service is having trouble dealing with the information it’s getting from foreign banks about U.S. taxpayer assets under the Foreign Account Tax Compliance Act because of problems with the data, various mismatches and missing or inaccurate Taxpayer Identification Numbers provided by the foreign banks. Furthermore, the IRS lacks access to consistent and … Read More

The Global Intangible Low-Taxed Income (‘GILTI’) regime, enacted as part of Congress’s 2017 tax reform initiative, effectively subjects any US citizen, green card holder, and other US tax resident (a ‘US Person’) to US income tax on the worldwide earnings of any non-US corporation (i) in which the US Person himself or herself holds a … Read More

Since 2010, HMRC have raised an additional £2.9 billion through its focus on offshore non-compliance, giving HMRC increased powers to assess older liabilities, charge higher behaviour-related penalties and to mount criminal prosecutions for the facilitation of tax evasion. HMRC’s success has also been boosted by several information sharing agreements with off-shore jurisdictions and the Common … Read More

Entrepreneurs Relief Changes

Previously, in order to qualify for Entrepreneurs’ Relief, an individual must have held shares which represented five percent of the ordinary share capital which entitled them to five percent of the voting rights. From 29 October 2018, the shares must also entitle the holder to five percent of the company’s distributable profits and five percent … Read More

Spring Statement 2019

The Chancellor’s 2019 Spring Statement gave the government the opportunity to consider the longer-term fiscal challenges ahead of Brexit, and initiate consultations on how these can be addressed. Following this, we have put together a PDF which provides an overview of the updated forecasts for the UK economy and public finances, which we trust you … Read More

Rebasing election

• If you have paid the remittance basis charge in any of the previous years you can rebase your foreign assets as of 5 April 2017. If you have not paid the RBC, there may still be an opportunity to rectify this. • The assets must have been located outside the UK throughout the period … Read More

This is an issue that is very current and which people should pay attention to, with the strength of the dollar against sterling. Americans who have non-US dollar mortgages and change the terms of their mortgage or make capital repayment on their mortgages, such transactions are deemed a taxable event for US tax purposes and … Read More

The U.S. Internal Revenue Service has finally updated its voluntary disclosure procedures following the closure of the Offshore Voluntary Disclosure Program (the “OVDP”) earlier this year. The updated procedures will apply to all voluntary disclosures made after September 28, 2018. Prior to its closure, the OVDP provided non-compliant taxpayers with a fixed civil penalty framework … Read More