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Here’s to the Crazy One’s (CRS OECD)

Borrowing from Apple (Think Different), this is a way to bring awareness to the changes that happen in the world.

Quite frequently we deal with people that deny the reality that things change until it is already a fact. After it happens it’s impossible to deny it, but until then or during the transitional period the resistance is incredible, practically superhuman. It’s such a complex matter and at the same time so simple that it always amazes us. Afterword’s it seems so obvious and we usually hear: “Off course that happened?” or “How come I didn’t think about this?”.

Most people don’t like change, they take us from our comfort zone and we become insecure of how the future will be but that doesn’t change the fact the it will happen and only the ones who analyze the situation rationally and in detail take the necessary actions to adapt to the new reality. Think about Venezuela, how many people had the chance to move out the country, protect their wealth, and even their very lives? How many who had the opportunity really took the chance and how many didn’t? In the financial world we hear the term “smart money”, the one that moves first in front of everyone else, takes initiative, prepares themselves better and most importantly executes when the time needs.

We insist on details because they make all the difference, so we are back calling everyone’s attention to the Common Reporting Standards of the OECD while everyone is concerned about FATCA, it will go unnoticed to most people in the beginning of next year. What we usually hear when we discuss the matter with attorneys, advisors and their clients is they will worry about it in 2017 or 2018 when the exchange of information starts, but shies away from their attention the fact that the collection of information will start January 1st of 2016 when the due diligence process will follow the new rules contained in the multilateral treaties. This detail changes everything because the time frame for restructuring to comply with CRS and ensuring client privacy is extremely short, it’s less than 80 days for the most brutal change in global transparency ever seen.

Think differently, don’t be stuck to the thought of the masses waiting for the obvious to happen, protect your privacy and your wealth.

FATCA is in effect between Brazil and USA

As we noted on a previous post, FATCA IGA was heading for a fast approval on the Brazilian Congress. Last week we had the publication of the Decree nº 8.506 that puts the agreement into effect immediately. That means that this the beginning of the automatic exchange of information of tax matters in Brazil.

The first exchange will occur right on the next month, September, as financial institutions had until today to send the information to local authorities for them to exchange with the foreign authorities as of tomorrow.
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FATCA and CRS increase pressure

We have being talking for some time about the FATCA and CRS impacts on people’s lives and however as incredible as it seems most prefer to think that they won’t be hit (the syndrome of it will not happen with me) and shove their heads in a hole or worse are very badly advised by their consultants and lawyers who continue taking advantage of the trust of their customers to push the problem under the carpet. The world is changing and fiscal transparency is here to stay, as well as reduction of privacy. To stay protected it will be necessary to raise the sophistication of structures to remain in compliance with the rules. But let’s not spend much time just talking and let’s get it to the facts.
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Brazil – FATCA

Brazil approved the IGA (Intergovernmental Agreement) for the implementation of FATCA (Foreign Account Tax Compliance Act) agreement to exchange tax information and Improving International Tax Compliance with the United States on July 25th. The article was approved at an accelerated rate due to the meeting between President Dilma and US President Barack Obama at the end of the month.

The matter reached the Senate as Legislative Decree Project International Agreements 257/15 and was dispatched for analysis of the Foreign Relations Commission (CRE), where it obtained a favorable opinion for its approval, and then forwarded to the Senate and got unanimous approval.
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Switzerland and Brazil to exchange more information

It is known that the automatic exchange of tax information between the two countries will take place in 2018 (end of 2017 for Brazil and 2018 for Switzerland), but the conversations between the two for the signature of a bilateral treaty are well advanced and should be signed well before the OECD agreement be operational.

Philippe Nell (head of the Americas division of SECO, the State Secretary for Economic Affairs of Switzerland), passed the information that the Swiss government is in advanced negotiations for a bilateral agreement with Brazil. This commitment includes the exchange of information, as foreseen by the OECD agreement, but also to free trade.
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Swiss Banks freezing accounts and blocking withdrawals

For the past months we have being receiving information that Italian clients were having some problems transferring or withdrawing assets from Swiss banks. Since this information was getting almost zero repercussion outside Italy we decided to explain what is happening.

As you may already know about the global shift to tax compliance, usually you hear more US related news. This time Italians are under scrutiny from their government and Swiss deposits are the top priority. Anyone thinking that this won’t happen to many other countries think again. Belgium and France are on the same path.

To their defense, Swiss banks are adopting measures to safeguard their interests and operations (just to make sure that you all understood, THEIR interests not their client’s). Some of them are only allowing transfers to accounts in white listed countries that are already under OECD tax information standards, only under the clients personal name and after the client went to the bank in person, with his lawyer to sign documents saying that he is tax compliant in his home country reliving that bank of any misconduct. Of course the client has to convince the receiving bank that his funds are tax compliant as well. Cash withdrawals are also being blocked and recent court cases are backing the right of the banks to do so (don’t you read the bank account contract’s small letters??). Credit Suisse and BSI (recently acquired by BTG Pactual) are among those taking this measures.
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Panama Bearer Shares no longer available

Back in August 2013 Panama’s National Assembly approved legislation (Law No. 47 of 6 August 2013) immobilizing bearer shares in Panama companies, with the new law becoming effective on 7 August 2015.

The original proposal was approved allowing for a three-year transition period for existing companies. However, on 23 April 2015 the Panama National Assembly amended the bearer share legislation through Law No. 18 2015, reducing the transition period from three years to less than five months.

Requirements summary:

All bearer shares in Panamanian Companies must be placed in the custody of an authorized custodian.

Companies that have bearer shares in circulation prior to the effective date of 7 August 2015 must place their certificates with an authorized custodian by 31 December 2015.

Companies that issue bearer shares after the effective date of 7 August 2015 will have to place their certificates with an authorized custodian within 20 days of the shares being issued.

Companies depositing bearer shares into custody require the authorization of a resolution of the Board of Directors or Shareholders, which must be registered in the Public Registry of Panama.

Companies that have bearer shares in circulation prior to 7 August 2015 must register this resolution before 31 December 2015, or they will be deemed automatically to prohibit the issuance of bearer shares.

As one of the few places in the world that still had this type of structure, Panama takes an important step towards a more compliant classification.

Brazil Receita Federal forgives Swiss HSBC account holders.. Such nice guys.

The Brazilian Internal Revenue Service (Receita Federal) already have the leaked Swiss HSBC data in their hands and they have successfully identified 7.243 individual tax payers as account holders. Interesting enough they say they will forgive these people for any tax evasion. Can you believe that? That would be great news for a lot of people I’m sure if that wasn’t a lie. What they will do is only consider the period from 2011 to 2014 for that purpose, but because they can only charge tax payers for a period of 5 years back, not what you were expecting right?

There’s another catch, when you don’t declare offshore money there’s the possibility of another crime involved one called unreported remittance of currency and for that there’s no 5 years limitation period. Penalty can go from 2 to 6 years of jail time.
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BVI Updates FATCA Reporting Guidance

The British Virgin Islands has published revised guidance notes on the international tax compliance requirements under its intergovernmental agreements with the United States and the United Kingdom.

The original version, dating back to July 2014, has been updated to reflect subsequent developments. Attention is drawn to the revised deadline of June 30, 2015, (extended from May, 31, 2015) for financial institutions to report with respect to the 2014 reporting year under the US Foreign Account Tax Compliance Act (FATCA).
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No Discount

Russia is following the steps of other countries like the US and Italy on the way of approving a law to allow taxpayers to regularize previously undeclared assets held offshore.

The Russian Government said on March 27, 2015, that the law, “On the Voluntary Declaration of Property and Bank Accounts (Deposits) by Individuals,” will allow taxpayers to repatriate assets taken out of the country in violation of tax, currency, and/or customs laws with a waiver on penalties.

The Government has said that information received will be treated as confidential, and an amnesty will be provided for criminal or administrative offenses committed.

The main goal is to retrieve taxes that were unpaid so as it happened in the US and Italy the Russian government will not press criminal charges on those who volunteer but will charge in full taxes, penalties and interest.
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