John P. Garcia, Targus Group International, Inc. - Speaker at the marcus evans Tax Officers Summit 2012, held in Las Vegas, NV, delivered his presentation entitled A Systematic Approach for Obtaining Foreign Tax Credits
The document provides an overview of Bank of America's Global Corporate & Investment Banking division, including:
1) It combines the Global Business & Financial Services and Global Capital Markets & Investment Banking businesses.
2) For the first half of 2005, the combined business generated $10.2 billion in revenue.
3) The division aims to better serve clients through an integrated operating model and cross-selling opportunities across BofA.
GAO 09 934 International Taxation Study Countries That Exempt Foreign Source...Brian James
The document discusses how several countries approach the taxation of foreign-source corporate income. It finds that while the study countries exempt some types of foreign income from domestic tax, they still face similar compliance risks and burdens as the U.S. These include transfer pricing manipulation, difficulties enforcing anti-avoidance rules due to lack of information exchange, and complexity in reporting foreign tax credits.
SkyLaw was honoured to be invited to be the exclusive author of two articles on Canadian M&A for the highly respected legal publisher Chambers and Partners.
We are very happy to announce that the Chambers Corporate M&A 2021 Global Practice Guide is now available to view online without charge. With Frank Aquila from Sullivan & Cromwell LLP acting as Contributing Editor, the guide covers an impressive 59 jurisdictions.
These are the sections contributed by SkyLaw:
Law and Practice - Pg. 1 to 20
Trends and Developments - Pg. 23 to 27
Author Bios and Firm Info - Pg. 21 to 22, Pg. 28-29
The complete Chambers Corporate M&A 2021 Global Practice Guide can be found at: https://practiceguides.chambers.com/practice-guides/corporate-ma-2021.
This was a presentation to NJTC audience - a Government delegation on Financial Innovation & Supervision, with Tax Evasion, Tax Transparency and how FATCA, CRS solutions addresses tax transparency.
The earnings call transcript summarizes CIT's financial results for the fourth quarter and full year of 2004. Key highlights included core earnings per share of $0.91 for Q4, a return on tangible equity of 14.5%, and strong new business volume growth of 32% for Q4 and 16% for the full year. The CEO discussed progress on strategic initiatives around capital discipline, growth culture, and profitability. Business units reported increased volumes and improving credit trends. The CFO provided additional details on drivers of the financial results.
Morgan Stanley Dean Witter announced record quarterly and full year net income. For the quarter, net income increased 86% to $1.633 billion and diluted earnings per share increased 91% to $2.84. For the full fiscal year, net income increased 57% to a record $4.791 billion and diluted earnings per share increased 66% to $8.20. The company also announced a 2 for 1 stock split, a 67% increase in dividends, and authorization to repurchase an additional $1 billion in stock.
Inbound Real Estate Investment Taxation(United States, Australia, Canada, Br...Chris Cervellera
This document summarizes key taxation concepts related to US and Canadian inbound real estate investment by non-residents. For the US, it defines FIRPTA and USRPI and outlines applicable taxes such as income tax, withholding tax, and capital gains tax. It then discusses common structuring approaches like standard and leveraged blockers. For Canada, it notes trends in foreign investment, defines TCP, and outlines applicable taxes on passive income, business income, and interest deductibility.
Morgan Stanley Dean Witter reported record first quarter net income of $1.5 billion, up 49% from the previous year, with record net revenues of $7.4 billion. Earnings per share were up 52% to $1.34. The Securities division achieved net income of $1.24 billion, up 54%, driven by record results in equities trading, investment banking, and asset management. Asset Management reported a 48% increase in net income to $158 million, with record assets under management of $455 billion. Credit Services net income was up 15% to $142 million, with record transaction volumes and consumer loan balances.
The document provides an overview of Bank of America's Global Corporate & Investment Banking division, including:
1) It combines the Global Business & Financial Services and Global Capital Markets & Investment Banking businesses.
2) For the first half of 2005, the combined business generated $10.2 billion in revenue.
3) The division aims to better serve clients through an integrated operating model and cross-selling opportunities across BofA.
GAO 09 934 International Taxation Study Countries That Exempt Foreign Source...Brian James
The document discusses how several countries approach the taxation of foreign-source corporate income. It finds that while the study countries exempt some types of foreign income from domestic tax, they still face similar compliance risks and burdens as the U.S. These include transfer pricing manipulation, difficulties enforcing anti-avoidance rules due to lack of information exchange, and complexity in reporting foreign tax credits.
SkyLaw was honoured to be invited to be the exclusive author of two articles on Canadian M&A for the highly respected legal publisher Chambers and Partners.
We are very happy to announce that the Chambers Corporate M&A 2021 Global Practice Guide is now available to view online without charge. With Frank Aquila from Sullivan & Cromwell LLP acting as Contributing Editor, the guide covers an impressive 59 jurisdictions.
These are the sections contributed by SkyLaw:
Law and Practice - Pg. 1 to 20
Trends and Developments - Pg. 23 to 27
Author Bios and Firm Info - Pg. 21 to 22, Pg. 28-29
The complete Chambers Corporate M&A 2021 Global Practice Guide can be found at: https://practiceguides.chambers.com/practice-guides/corporate-ma-2021.
This was a presentation to NJTC audience - a Government delegation on Financial Innovation & Supervision, with Tax Evasion, Tax Transparency and how FATCA, CRS solutions addresses tax transparency.
The earnings call transcript summarizes CIT's financial results for the fourth quarter and full year of 2004. Key highlights included core earnings per share of $0.91 for Q4, a return on tangible equity of 14.5%, and strong new business volume growth of 32% for Q4 and 16% for the full year. The CEO discussed progress on strategic initiatives around capital discipline, growth culture, and profitability. Business units reported increased volumes and improving credit trends. The CFO provided additional details on drivers of the financial results.
Morgan Stanley Dean Witter announced record quarterly and full year net income. For the quarter, net income increased 86% to $1.633 billion and diluted earnings per share increased 91% to $2.84. For the full fiscal year, net income increased 57% to a record $4.791 billion and diluted earnings per share increased 66% to $8.20. The company also announced a 2 for 1 stock split, a 67% increase in dividends, and authorization to repurchase an additional $1 billion in stock.
Inbound Real Estate Investment Taxation(United States, Australia, Canada, Br...Chris Cervellera
This document summarizes key taxation concepts related to US and Canadian inbound real estate investment by non-residents. For the US, it defines FIRPTA and USRPI and outlines applicable taxes such as income tax, withholding tax, and capital gains tax. It then discusses common structuring approaches like standard and leveraged blockers. For Canada, it notes trends in foreign investment, defines TCP, and outlines applicable taxes on passive income, business income, and interest deductibility.
Morgan Stanley Dean Witter reported record first quarter net income of $1.5 billion, up 49% from the previous year, with record net revenues of $7.4 billion. Earnings per share were up 52% to $1.34. The Securities division achieved net income of $1.24 billion, up 54%, driven by record results in equities trading, investment banking, and asset management. Asset Management reported a 48% increase in net income to $158 million, with record assets under management of $455 billion. Credit Services net income was up 15% to $142 million, with record transaction volumes and consumer loan balances.
This article highlights 15 top-performing mutual funds over the past 5 years. It begins by discussing the difficult market environment for funds since 2005, with the average annual return just 2% compared to inflation. However, some funds delivered much better returns. The top-performing fund highlighted is the Yacktman fund, which returned 40% over 5 years compared to just 4,000% for a market index fund. The article then examines the BlackRock Global Allocation fund in more detail as the top global fund. It achieved an average annual return of 7.7% over 15 years by taking advantage of market downturns to buy stocks and bonds at lower prices. The fund aims to limit risk by diversifying across
GEO NECF 2015 - Exploring the Challenges of Tax Compliance and the W-8BENAndrea Huck-Esposito
With the many complex brokerage challenges servicing international participants - foreign jurisdictional restrictions, FATCA compliance, IRS guidelines and many more, having an understanding of the shared ownership between you and your broker can help navigate the difficulties of ensuring your participants’ compliance with tax regulations. In this presentation, Andrea Kagan, Solium, will be joined by Brian Burke of TD Ameritrade and Andrew Gerwirtz of KPMG. The trio will discuss their views on the shared ownership of understanding the in and outs of the W-8 and how it impacts international employees and a mobile workforce.
Plymouth - Essential 6-monthly Finance Directors' Update – Nov/Dec 2016 PKF Francis Clark
Our six-monthly Finance Seminars provide a high level overview of the most important technical developments in financial reporting and taxation. The seminars address the key topical financial matters, the opportunities they present, how they affect your business and the pitfalls you can avoid.
The document provides an overview of Macquarie Infrastructure Company's fourth quarter and full year 2011 earnings conference call. It discusses positive cash generation trends, with proportionately combined free cash flow of $145.1 million for 2011. Segment performance is reviewed for IMTT, The Gas Company, District Energy, and Atlantic Aviation. Guidance is also provided for expected 2012 performance at each business. Debt profiles and compliance with debt covenants are summarized.
- Rossi Residencial is a Brazilian real estate developer focused on residential properties. It has been operating since 1980 and went public in 1999.
- The presentation provides an overview of Rossi's historical background, business model, track record, competitive advantages, and financial performance.
- Key details include Rossi's expansion through new regional offices, product lines focused on different income segments, and its adherence to high corporate governance standards.
The document is an introduction to a training program on the Foreign Account Tax Compliance Act (FATCA) for Latin American firms. It outlines the agenda for the training, which covers the historical background of FATCA, its key aims and objectives, milestones, impact, and the three pillars of classification, reporting and withholding that FATCA implements. The training will be held in Panama City and Santo Domingo in February 2015 and presented by consultant Rodrigo Zepeda.
The document provides a detailed summary of the author's experience traveling along the Diva Vasai rail corridor between Mumbai and Surat. Some key points:
1) The author describes the scenic views along the corridor, including large curved sections of track and views of the surrounding landscape as the sun sets.
2) Specific stations like Dombivali, Bhivandi Road, and Vasai Road are mentioned, along with observations of other trains and infrastructure like bridges and catenary work.
3) While the track is in good condition, freight traffic often causes delays, and the scenic journey averages only 30 kph.
An advisory firm delivering services to the investors may help you in this sector. They use to provide such professionals who give such tips and hints which benefits the traders and help them to achieve the desired success.
El padre encuentra una nota de su hijo en la que dice que se está fugando con su nuevo novio Gerardo y que ha descubierto que le gustan los hombres. Sin embargo, al final de la nota, el hijo revela que todo era mentira y que en realidad está en la casa de una compañera de clase. El padre se asusta al leer la primera parte de la nota pero luego se alivia al leer el final.
The US-China Business Council's publication China Business Review has provided expert analysis of the US-China business relationship for nearly 40 years. It has an exclusive audience of over 12,000 readers, including executives from companies in industries like manufacturing, consulting, and banking. The publication has both print and online components, with the website receiving over 600,000 page views per month. Advertising packages are available for print, online, and webinar sponsorships.
السلام عليكم ورحمة الله وبركاته
Assalam-O-Alikum-Wa-RahmatULLAH-i-Wa-Barakaatuh
محاسن اسلام
پاکستان کا بھترین ماھانہ اسلامی میگزین " محاسن اسلام " کو پڑھیں دیکھیں سوچیں ، فیصلہ کریں اوراسکو پھیلائیں
کیا آپ جانتے ھیں کہ ایک مسلمان کے لئے بہترین تحفہ کیا ھے؟ وہ بہترین تحفہ دینی علوم ھیں ،لھذا آپ اپنے رسالہ ماھنامہ محاسن اسلام ملتان جو کہ خالصتا دینی علمی تحقییقی اکابرین بزرگان دین صوفیائےو علمائے اکرام ،ولی اللہ ،مشائخ کا پسندیدہ رسالہ ھے۔
اس کو ایسے لوگوں سے شیر کریں جو اسکو آگے بطور صدقہ جاریہ پھیلا سکیں اور پرنٹ لیکر ایسی جگہ رکھئیے جھاں آنے والے دوست احباب رشتہ داروں اور دیگر مھمانان گرامی اس سے کماحقہ فائدہ آٹھا سکیں اور اگر آپ مزید اپنے لئیے صدقہ جاریہ بنانا چاھیں تو کم قیمت پر ادارہ سے خرید کر تقسیم کیجئے یا ادارہ سے ماھانہ قیمت پر لگوالیں اور اپنے دوستوں رشتہ داروں عزیزوں مساجد لائبریریوں کے لئے ایک سال کے لئے جاری کرا دیجئے نیز ان کو مزید خریدار بنانے کے لئے ترغیب بھی دیجئے کیوں کہ یہ دنیاوی کاروبار کی بجائے اللہ سے براہ راست تجارت ھے جسکا منافع اللہ تعالی دنیا اور آخرت میں عطا فرما ئیں
گے کیونکہ یہ کاروبار نھیں دین کے پھیلانے کا ایک عظیم ذریعہ ھے( لاریب فی )
اس دینی اور علم کے تحفے سے فائیدہ اُٹھائیں ۔دین کے کاموں میں ھمیشہ آگے بڑھیں
یا کم ازکم دوسروں سے شئیر کرلیں اور صدقہ جاریہ اور اجروثواب کا باعث بنیں
آ پ نیکی کاکام پھیلانے علم دین اور کتابوں کی اشاعت کا ثواب حاصل کر سکتے ہیں۔
اس کتاب،دینی میٹرئیل ،رسالہ کا مطا لعہ کرنے کے بعد اگر آپ محسوس کریں کہ یہ آپ کے گھر والوں رشتہ داروں دفتر کے ساتھیوں،کاروباری حلقوں اور معاشرے کے دیگر حلقوں اور معا شرے کے دیگر افراد بشمول سکول کالج ،یونیورسٹی اور مدارس کے طلبہ کے لئے مفید ھے تو آپ اُن سے یہ کتاب میگزین آرٹیکل شیئر کریں یہ آخرت میں سرمایہ کاری اور سماجی زمہ داری کی ادائیگی کا حصہ ھوگا۔
لھذا اس
This is a presentation about IEG's evaluation of the Doing Business Indicators. The Doing Business Indicators are the Bank Group's well-known tool for comparing the business regulatory environments of 178 countries.
Legal aspects of it industry investments in the united states slovakia march 7Roger Royse
This document summarizes key legal aspects of IT industry investments in the United States. It discusses considerations for US market entry strategies including establishing a US branch or subsidiary. It also covers important regulatory issues such as intellectual property protection, transfer pricing, taxation, and employment laws that foreign companies should be aware of.
New business opportunities in the us romaniaRoger Royse
This document discusses new business opportunities in the United States and considerations for foreign companies looking to enter the US market. It covers topics such as choosing an entity structure, intellectual property protection, taxation, transfer pricing, and employment issues. The document provides an overview of the large US market and regulatory environment, and outlines strategies for setting up operations and structuring intercompany agreements to minimize tax liability.
The document discusses opportunities in fintech and focuses on invoice trading. It notes that invoice trading platforms help unlock cash from unpaid invoices. Workinvoice is an Italian invoice trading platform that has funded over €30 million in invoices. It outsources some functions like credit ratings, payments, and collections to specialized providers to increase flexibility and efficiency in a regulated environment. The document emphasizes that invoice trading addresses the large amount of commercial receivables generated in Italy that are sitting on corporate balance sheets.
GFI Group provides a hybrid brokerage model for trading tax liens through their Distressed Asset Receivables Trading (DART) platform and experienced brokers. This creates liquidity and matches buyers and sellers in the otherwise fragmented tax lien market. Buyers benefit from unique investment opportunities and access to data, while sellers benefit from liquidity, transparency, and product analysis. GFI works with over 150 clients globally, including financial institutions, real estate firms, and tax authorities.
Canada’s competition and foreign investment laws are now enforced with more vigour than ever -- the Blakes Competition, Antitrust & Foreign Investment Group provides practical guidance on how to get regulatory approval for mergers, strategic alliances and joint ventures in this increasingly challenging enforcement environment.
1) The document provides an overview of considerations for US market entry and operations for foreign companies, including regulatory environment, intellectual property protection, accounting, taxation, and cross-border structuring strategies.
2) It discusses options for US market entry including establishing a US branch, subsidiary, or holding company and factors that influence the choice such as permanent establishment rules.
3) The document also summarizes key cross-border tax and legal compliance issues such as transfer pricing, intellectual property strategies, capitalization, employment, and international agreements.
Divizend is a software company that automates the process of reclaiming withholding taxes for cross-border dividend investments. Their software simplifies the complex, lengthy, and costly process of reclaiming withholding taxes into a simple 4-step process. They generate revenue through transaction fees of around 17.5% of the reclaimed tax amount. Their goal is to scale internationally and raise a Series A funding round of 5-10 million Euros in 2022 as they see a large untapped market potential in automating the 100 billion USD in unreclaimed withholding taxes each year.
This article highlights 15 top-performing mutual funds over the past 5 years. It begins by discussing the difficult market environment for funds since 2005, with the average annual return just 2% compared to inflation. However, some funds delivered much better returns. The top-performing fund highlighted is the Yacktman fund, which returned 40% over 5 years compared to just 4,000% for a market index fund. The article then examines the BlackRock Global Allocation fund in more detail as the top global fund. It achieved an average annual return of 7.7% over 15 years by taking advantage of market downturns to buy stocks and bonds at lower prices. The fund aims to limit risk by diversifying across
GEO NECF 2015 - Exploring the Challenges of Tax Compliance and the W-8BENAndrea Huck-Esposito
With the many complex brokerage challenges servicing international participants - foreign jurisdictional restrictions, FATCA compliance, IRS guidelines and many more, having an understanding of the shared ownership between you and your broker can help navigate the difficulties of ensuring your participants’ compliance with tax regulations. In this presentation, Andrea Kagan, Solium, will be joined by Brian Burke of TD Ameritrade and Andrew Gerwirtz of KPMG. The trio will discuss their views on the shared ownership of understanding the in and outs of the W-8 and how it impacts international employees and a mobile workforce.
Plymouth - Essential 6-monthly Finance Directors' Update – Nov/Dec 2016 PKF Francis Clark
Our six-monthly Finance Seminars provide a high level overview of the most important technical developments in financial reporting and taxation. The seminars address the key topical financial matters, the opportunities they present, how they affect your business and the pitfalls you can avoid.
The document provides an overview of Macquarie Infrastructure Company's fourth quarter and full year 2011 earnings conference call. It discusses positive cash generation trends, with proportionately combined free cash flow of $145.1 million for 2011. Segment performance is reviewed for IMTT, The Gas Company, District Energy, and Atlantic Aviation. Guidance is also provided for expected 2012 performance at each business. Debt profiles and compliance with debt covenants are summarized.
- Rossi Residencial is a Brazilian real estate developer focused on residential properties. It has been operating since 1980 and went public in 1999.
- The presentation provides an overview of Rossi's historical background, business model, track record, competitive advantages, and financial performance.
- Key details include Rossi's expansion through new regional offices, product lines focused on different income segments, and its adherence to high corporate governance standards.
The document is an introduction to a training program on the Foreign Account Tax Compliance Act (FATCA) for Latin American firms. It outlines the agenda for the training, which covers the historical background of FATCA, its key aims and objectives, milestones, impact, and the three pillars of classification, reporting and withholding that FATCA implements. The training will be held in Panama City and Santo Domingo in February 2015 and presented by consultant Rodrigo Zepeda.
The document provides a detailed summary of the author's experience traveling along the Diva Vasai rail corridor between Mumbai and Surat. Some key points:
1) The author describes the scenic views along the corridor, including large curved sections of track and views of the surrounding landscape as the sun sets.
2) Specific stations like Dombivali, Bhivandi Road, and Vasai Road are mentioned, along with observations of other trains and infrastructure like bridges and catenary work.
3) While the track is in good condition, freight traffic often causes delays, and the scenic journey averages only 30 kph.
An advisory firm delivering services to the investors may help you in this sector. They use to provide such professionals who give such tips and hints which benefits the traders and help them to achieve the desired success.
El padre encuentra una nota de su hijo en la que dice que se está fugando con su nuevo novio Gerardo y que ha descubierto que le gustan los hombres. Sin embargo, al final de la nota, el hijo revela que todo era mentira y que en realidad está en la casa de una compañera de clase. El padre se asusta al leer la primera parte de la nota pero luego se alivia al leer el final.
The US-China Business Council's publication China Business Review has provided expert analysis of the US-China business relationship for nearly 40 years. It has an exclusive audience of over 12,000 readers, including executives from companies in industries like manufacturing, consulting, and banking. The publication has both print and online components, with the website receiving over 600,000 page views per month. Advertising packages are available for print, online, and webinar sponsorships.
السلام عليكم ورحمة الله وبركاته
Assalam-O-Alikum-Wa-RahmatULLAH-i-Wa-Barakaatuh
محاسن اسلام
پاکستان کا بھترین ماھانہ اسلامی میگزین " محاسن اسلام " کو پڑھیں دیکھیں سوچیں ، فیصلہ کریں اوراسکو پھیلائیں
کیا آپ جانتے ھیں کہ ایک مسلمان کے لئے بہترین تحفہ کیا ھے؟ وہ بہترین تحفہ دینی علوم ھیں ،لھذا آپ اپنے رسالہ ماھنامہ محاسن اسلام ملتان جو کہ خالصتا دینی علمی تحقییقی اکابرین بزرگان دین صوفیائےو علمائے اکرام ،ولی اللہ ،مشائخ کا پسندیدہ رسالہ ھے۔
اس کو ایسے لوگوں سے شیر کریں جو اسکو آگے بطور صدقہ جاریہ پھیلا سکیں اور پرنٹ لیکر ایسی جگہ رکھئیے جھاں آنے والے دوست احباب رشتہ داروں اور دیگر مھمانان گرامی اس سے کماحقہ فائدہ آٹھا سکیں اور اگر آپ مزید اپنے لئیے صدقہ جاریہ بنانا چاھیں تو کم قیمت پر ادارہ سے خرید کر تقسیم کیجئے یا ادارہ سے ماھانہ قیمت پر لگوالیں اور اپنے دوستوں رشتہ داروں عزیزوں مساجد لائبریریوں کے لئے ایک سال کے لئے جاری کرا دیجئے نیز ان کو مزید خریدار بنانے کے لئے ترغیب بھی دیجئے کیوں کہ یہ دنیاوی کاروبار کی بجائے اللہ سے براہ راست تجارت ھے جسکا منافع اللہ تعالی دنیا اور آخرت میں عطا فرما ئیں
گے کیونکہ یہ کاروبار نھیں دین کے پھیلانے کا ایک عظیم ذریعہ ھے( لاریب فی )
اس دینی اور علم کے تحفے سے فائیدہ اُٹھائیں ۔دین کے کاموں میں ھمیشہ آگے بڑھیں
یا کم ازکم دوسروں سے شئیر کرلیں اور صدقہ جاریہ اور اجروثواب کا باعث بنیں
آ پ نیکی کاکام پھیلانے علم دین اور کتابوں کی اشاعت کا ثواب حاصل کر سکتے ہیں۔
اس کتاب،دینی میٹرئیل ،رسالہ کا مطا لعہ کرنے کے بعد اگر آپ محسوس کریں کہ یہ آپ کے گھر والوں رشتہ داروں دفتر کے ساتھیوں،کاروباری حلقوں اور معاشرے کے دیگر حلقوں اور معا شرے کے دیگر افراد بشمول سکول کالج ،یونیورسٹی اور مدارس کے طلبہ کے لئے مفید ھے تو آپ اُن سے یہ کتاب میگزین آرٹیکل شیئر کریں یہ آخرت میں سرمایہ کاری اور سماجی زمہ داری کی ادائیگی کا حصہ ھوگا۔
لھذا اس
This is a presentation about IEG's evaluation of the Doing Business Indicators. The Doing Business Indicators are the Bank Group's well-known tool for comparing the business regulatory environments of 178 countries.
Legal aspects of it industry investments in the united states slovakia march 7Roger Royse
This document summarizes key legal aspects of IT industry investments in the United States. It discusses considerations for US market entry strategies including establishing a US branch or subsidiary. It also covers important regulatory issues such as intellectual property protection, transfer pricing, taxation, and employment laws that foreign companies should be aware of.
New business opportunities in the us romaniaRoger Royse
This document discusses new business opportunities in the United States and considerations for foreign companies looking to enter the US market. It covers topics such as choosing an entity structure, intellectual property protection, taxation, transfer pricing, and employment issues. The document provides an overview of the large US market and regulatory environment, and outlines strategies for setting up operations and structuring intercompany agreements to minimize tax liability.
The document discusses opportunities in fintech and focuses on invoice trading. It notes that invoice trading platforms help unlock cash from unpaid invoices. Workinvoice is an Italian invoice trading platform that has funded over €30 million in invoices. It outsources some functions like credit ratings, payments, and collections to specialized providers to increase flexibility and efficiency in a regulated environment. The document emphasizes that invoice trading addresses the large amount of commercial receivables generated in Italy that are sitting on corporate balance sheets.
GFI Group provides a hybrid brokerage model for trading tax liens through their Distressed Asset Receivables Trading (DART) platform and experienced brokers. This creates liquidity and matches buyers and sellers in the otherwise fragmented tax lien market. Buyers benefit from unique investment opportunities and access to data, while sellers benefit from liquidity, transparency, and product analysis. GFI works with over 150 clients globally, including financial institutions, real estate firms, and tax authorities.
Canada’s competition and foreign investment laws are now enforced with more vigour than ever -- the Blakes Competition, Antitrust & Foreign Investment Group provides practical guidance on how to get regulatory approval for mergers, strategic alliances and joint ventures in this increasingly challenging enforcement environment.
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2) It discusses options for US market entry including establishing a US branch, subsidiary, or holding company and factors that influence the choice such as permanent establishment rules.
3) The document also summarizes key cross-border tax and legal compliance issues such as transfer pricing, intellectual property strategies, capitalization, employment, and international agreements.
Divizend is a software company that automates the process of reclaiming withholding taxes for cross-border dividend investments. Their software simplifies the complex, lengthy, and costly process of reclaiming withholding taxes into a simple 4-step process. They generate revenue through transaction fees of around 17.5% of the reclaimed tax amount. Their goal is to scale internationally and raise a Series A funding round of 5-10 million Euros in 2022 as they see a large untapped market potential in automating the 100 billion USD in unreclaimed withholding taxes each year.
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Fabrice Grinda's video at LeWeb 2011: http://youtu.be/EvfyUb42tuc
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Corporate inversions occur when a corporation reincorporates in another country to reduce its tax burden from income earned abroad. The U.S. has the highest corporate tax rate among OECD countries, incentivizing inversions. Legislation in 1984 and 2004 attempted to curb inversions, but many still occur to take advantage of lower foreign tax rates. The Stop Corporate Inversions Act of 2014 aimed to further limit inversions by increasing the foreign ownership threshold, but was opposed by business groups and Republicans concerned about lost jobs and competitiveness. Views on inversions differ, with some seeing them as unpatriotic and others as a natural response to tax incentives.
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Taunton - Essential 6-monthly Finance Directors' Update – Nov/Dec 2016PKF Francis Clark
Our six-monthly Finance Seminars provide a high level overview of the most important technical developments in financial reporting and taxation. The seminars address the key topical financial matters, the opportunities they present, how they affect your business and the pitfalls you can avoid.
Exeter - Essential 6-monthly Finance Directors' Update – Nov/Dec 2016 PKF Francis Clark
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Why Own Safeguard?
- Full Value Yet to be Realized
- Ownership Stakes in Exciting Partner Companies
- Top Performance of Proven Team
- Financial Strength, Flexibility and Liquidity
- Strong Alignment of Interests
Forward-Looking Statements
Statements contained in this presentation that are not historical facts are forward looking statements which involve certain risks and uncertainties including, but not limited to, risks associated with the uncertainty of managing rapidly changing technologies, limited access to capital, competition, the ability to attract and retain qualified employees, our ability to execute our strategy, the uncertainty of the future performance of our partner companies, acquisitions and dispositions of additional partner companies, the inability to manage growth, government regulation and legal liabilities and the effect of economic conditions in the business sectors in which our partner companies operate, negative media coverage and other uncertainties as described in our filings with the Securities and Exchange Commission, including our Annual Report on Form 10-K.
Safeguard does not assume any obligation to update any forward looking statements or other information contained in this presentation.
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Why Own Safeguard?
- Full Value Yet to be Realized
- Ownership Stakes in Exciting Partner Companies
- Top Performance of Proven Team
- Financial Strength, Flexibility and Liquidity
- Strong Alignment of Interests
Forward-Looking Statements
Statements contained in this presentation that are not historical facts are forward looking statements which involve certain risks and uncertainties including, but not limited to, risks associated with the uncertainty of managing rapidly changing technologies, limited access to capital, competition, the ability to attract and retain qualified employees, our ability to execute our strategy, the uncertainty of the future performance of our partner companies, acquisitions and dispositions of additional partner companies, the inability to manage growth, government regulation and legal liabilities and the effect of economic conditions in the business sectors in which our partner companies operate, negative media coverage and other uncertainties as described in our filings with the Securities and Exchange Commission, including our Annual Report on Form 10-K.
Safeguard does not assume any obligation to update any forward looking statements or other information contained in this presentation.
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A Systematic Approach for Obtaining Foreign Tax Credits - John P. Garcia, Targus Group International, Inc.
1. John P Garcia CPA, MBA
P. Garcia, CPA
HEAD OF GLOBAL TAX
TARGUS GROUP INTERNATIONAL, INC.
ANAHEIM, CA
November 10, 2012
Red Rock Casino – Las Vegas, NV
Vegas
2. Targus is the world’s best selling notebook
carrying case brand, and the leading provider of
accessory products for the mobile lifestyle
lifestyle.
Targus has 45 offices worldwide and direct
distribution in over 145 countries.
2
3. John Garcia, CPA, MBA is the Tax Director for
Targus Group International, Inc. and has been
Head of Global Tax at Targus for 6 years. He
oversees the filing of Targus’s federal consolidated
tax return, international tax returns, transfer pricing
p g
studies and various consolidated and separate
state tax returns. He has also prepared the g
p p global
tax provisions necessary for FAS 109 compliance.
3
4. Our primary objective is to review the
Foreign Tax Compliance process in general
and to explore the withholding tax process
in some detail in order to help you
understand the process and develop an
effective approach to the compliance
pp p
process for your firm or your client’s firm.
4
5. 1. Introduction
2. US Perspective of Global Withholding
Tax Model
3. 4 Approaches to Compliance
4. The Integrated Database Solution
5
7. Economic activity across borders creates tax
liabilities:
Withholding Tax
Income
Sales
Valued Added Tax (VAT)
Property Tax
7
8. Questions You Need to Ask
1. Do we know how much our company paid in
withholding taxes on a world wide basis last
g
year?
2.
2 How do we know that we paid the correct
amount?
3. Can we recover more money in (from)
withholding tax?
8
9. Typically occurs when a purchaser (payer)
conducts business with a supplier (payee) who
is not registered in the supplier’s jurisdiction
Governments impose withholding tax in order to
insure that non-resident recipients of resident
based income pay the appropriate tax
Typically, the obligation of withholding the
proper amount of tax lies with the resident
purchaser
9
10. Non-related 3rd party transactions are
often correct.
Withholding tax has a tendency to be
incorrect when the counter-parties are
related.
related
10
11. Example
US Parent Co.
Canadian
LENDER
Wholly-Owned
Subsidiary Co
$1MM Loan @ 5%
No presence in the US
h
BORROWER
US-Canada Treaty Rate = 10% withholding interest
The Canadian statutory non-treaty rate = 25%
y y
11
12. Income Flows That Attract Withholding Tax
1. Dividends
2. Interest
3. Royalties
4. Capital Gains
5. Sales
6. Technical / Management Service Fees
g
7. Insurance
8. Rental Income
12
13. Number of Possible Scenarios
X = Number of Countries where the
enterprise has operations
Y = Income Streams the company has which
require withholding tax
Z = Number of Operating Entities
Universe = X * Y * Z
THIS IS A VERY, VERY LARGE NUMBER
13
14. Imagine the US Parent
income flows… Corporation
Hong Kong
g g Canadian
Sourcing Sales
Company Subsidiary
Chinese Singapore
Sales
S l Sales
S l
Company Company
14
15. Universe = X * Y * Z
5 – Countries
x 2 – Revenue Streams (Interest and Sales)
x 5 – Legal Entities
= 50 Potential Revenue Streams Daily!
15
16. Penalties in selected countries for failure to
withhold income taxes:
ithh ld i t
Country Penalty
Canada 10% (20% if missed more
than once)
)
China 50%
Hong Kong 10%
Singapore 5%
16
18. The best a corporate taxpayer can do is 35%
after foreign tax credits.
ft f i t dit
This is postponed until earnings are repatriated
absent application of Subpart F rules.
fS
U.S. corporate tax rate is the highest in the
world
This affords great potential savings for U.S
based multinational corporations.
These potential savings have limited life, making
time of the essence.
18
19. One TRILLION dollars
of unremitted foreign
earnings indefinitely
reinvested overseas.
This artificially distorts
utilization of capital
for the US
corporation.
ti
19
20. Diverse and complex
complex.
Timely withholding, filing and remittance are
essential
Withholding taxes are transactional based
and can be voluminous.
20
21. Lack of technical competency in the finance
area.
Tax burdens are significant.
Rules change daily with little advance notice.
Increased audits of these transactions.
Volatility of the global environment creates
planning challenges.
21
22. With th
there b i l kl t returns i d
being lackluster t in developed
l d
economies, capital is seeking returns in less
stable more rapidly growing countries
countries.
Globalization has produced an increase in
p
intercompany activity.
22
23. Ease of Trading
2013 Forecast
Country Across Borders
GDP Growth
(1 185)
(1-185)
Brazil 4% 123
Russia 4% 162
India 6% 127
China 8% 68
USA 2% 22
23
24. Developing nations often lack fully-developed
governmental institutions and proper reporting
systems.
Examples of 2012 changes:
Argentina terminated treaties with Switzerland,
Chile, and Spain.
Beginning 2013, South Africa exempted from
withholding non-resident interest received from in-
g
country sources.
US – Chile Tax Treaty has been awaiting U.S.
Senate approval since February, 2010.
24
26. 1.
1 Do Little or Nothing Approach
2. Costly Consultant Approach
3. Ad Hoc Approach – Research Software
Supplemented by Consultants
pp y
4. Integrated Database Solution
26
27. Costly
2–C l C
Costly Consultant
l 3 – Ad Hoc
• Decentralized • Centralized
• Use Experts
• p
Use Experts
• I house Software
In h S ft
• External Research Tools Solution
• Reactive • Pro- Active
Inefficient
ffi i Efficient
1 – Do Little or Nothing 4 – Integrated Database
• Decentralized
D t li d Solution
• No experts Centralized
• Rarely Use Experts
• Google
• Real time Database
• Reactive • Pro-Active
Low Cost 27
29. Convert data to information
Capture data, analyze the data and determine
payment and reporting requirements on a timely
basis.
29
30. Daily
Rates Documents
Events
Interest &
Treaties and
Penalty
y Due Dates
Protocols
Rates
Withholding International
I t ti l
Forms and FX Rates
Tax Rates Receipts
30
32. Recovered Withholding Tax
Avoid Double Taxation
Correct and Ti l Withholding
C t d Timely Withh ldi
Reduced Interest & Penalties
Foreign Tax Credit Support
More Efficient and Eff ti Audits
M Effi i t d Effective A dit
Verifiable Audits
32
33. Reduce tax preparation expense
Better management of cash
Planning and Projections
Pl i d P j ti
Track expiring tax credits
Identify areas of exposure quickly
Scalability
S l bilit
33
34. Do you have the capability?
Do current accounting systems properly identify the
intercompany transactions?
Are all legal Entities / Accounts / Centers properly
identified?
All entities in accounting enterprise system
Special purpose entities
Disregarded entities
Are all like kind intercompany income flows treated
the same?
34