Articles & Video
Hot off the Press: On SRIP trusts, Singapore blinks… Or, is that a wink?
On 18 July, Singapore published adjustments to its OECD CRS FAQs (available here), featuring modification of the guidance on settlor reserved investment power (SRIP) trusts. In the prior version of the FAQ (as analysed in my blog of 25 April), the Inland Revenue Authority of Singapore (IRAS) stated in FAQ B.5 that a SRIP trust would not qualify as an FI because the manager of the assets held by the trust (i.e., the settlor) would not itself be an FI. The revised version is no longer so certain.
GFOS' Responses To The Further Consultation Paper Of 19th August
The UK is the world’s leading financial centre and is a destiny of choice for many ultra-high net worth (UHNW) individuals
If the UK wishes to capitalise on its strengths and send a consistent and clear message to the world that it is open for business, it needs to understand where it is, where it wishes to go and how to get there, post Brexit.
Client Notifications Concerning International Tax Compliance
International Tax Compliance: Regulations have been issued requiring financial institutions and service providers, such as tax advisers, to issue notifications to those who are ‘specified clients’ on 30 September 2016.
Onshore Vs Offshore Jurisdictions – Is There Really A Battle?
Over the past few months the issue of offshore jurisdictions and the role they play in the global economy has come under extreme scrutiny, especially from onshore governments seeking to increase tax revenues. The recent Panama Papers Leak has only served to fuel the flame and has resulted in more people who know very little or nothing at all about offshore jurisdictions calling for their demise.
Worldwide Disclosure Facility: Offshore Assets Last Chance New Disclosure Facility Offers ‘Last Chance’ For Those With Undeclared Offshore Interests
Last week HMRC launched the new Worldwide Disclosure Facility (WDF) – a new online facility which provides a ‘last chance’ to those who want to disclose a UK tax liability that relates wholly or partly to offshore interests. Unlike previous facilities, the WDF offers very little in the way of carrot, and rather more in the way of stick given the new sanctions that are set to be introduced in 2018.
AEOI: Status of Implementation in Switzerland
Last month, the Swiss Federal Tax Administration (SFTA) published the much anticipated draft version for the Guideline: Standard for the Automatic Exchange Of Information with regard to financial accounts - Common Reporting Standard ("Draft AEOI-Guideline").
The Stiglitz Factor
Now we have the unfortunate resignation in August of Messrs. Stiglitz and Pieth from the Panama Papers committee, an embarrassment to the Panamanian government and which has been widely covered by television, blogs and newspapers.
Sinister! CRS & Kidnap
I met with Jane Gilbert, a friend of mine for breakfast. She is an expert in kidnap and extortion insurance and we met to discuss the kidnap of Bernie Ecclestone’s mother.
Whilst kidnapping for ransom continues to be an everyday occurrence in many parts of the world, the crime continues to develop. Today, for example, a virtual kidnap. Virtual kidnapping is going global; it is now endemic through Latin America and Mexico and has spread to the Middle East.
CRS & Investment Entities: Guernsey issues guidance on classification of investment entities for the Common Reporting Standard
On 29 July 2016, the States of Guernsey Income Tax ("ITO") published their latest bulletin on guidance in relation to the implementation of the Common Reporting Standard ("CRS") in Guernsey. Bulletin 2016/6 repeats the text of the definition of Investment Entity, as set out in Section VIII A(6) of the CRS and affirms the Supplementary Guidance Notes published in draft on 24 December 2015 in relation to the CRS.
HNWIs, FATCA & CRS: Is Privacy Dead?
FATCA & CRS: For many UHNW families privacy is very important, and I can already see more and more of them making arrangements to protect it.
Wealth Planning For The Multinational Family
Multinational families are often challenged by a wide range of complex tax and reporting rules, including the Foreign Account Compliance Tax Act (FATCA) and the Common Reporting Standards (CRS).
Cayman Islands: Confidential Relationships Law To Be Repealed
Confidential Relationships Law: The Government of the Cayman Islands has this week gazetted a bill to repeal the statute that has frequently and mistakenly
Panama Papers: What’s Wrong With Panama?
There is currently a lot of press on the Panama leaks from leading local law firm Mossak Fonseca. This worries many people in the financial services industry and it should. It should however not worry everyone.
Defending the Indefensible!
Since the abolition of exchange controls in 1979, money can move anywhere in the world. It is hardly surprising therefore that it finds its way to places where it is taxed the least – offshore financial centres