#USA Archives - Law firm Finance Business Service: offshore registration, tax planning, legal services

First Citizens to buy SVB after biggest failure since 2008

Published: Ольга Зубко | 29.03.2023 |

First Citizens BancShares Inc. agreed to buy Silicon Valley Bank after a run on deposits wiped out the company in the biggest US bank failure in more than a decade. Source:https://www.bloomberg.com/news/articles/2023-03-27/first-citizens-to-buy-silicon-valley-bank-after-run-on-lender?srnd=premium-europe The deal to settle SVB’s fate could help tamp down some of the turmoil that has engulfed the financial world, and shares of regional banks rallied on the news, with First Citizens up 44%. The acquisition transforms First Citizens into one of the top 15 US banks, according to Bloomberg Intelligence, with help from some favorable terms. First Citizens is buying about $72 billion of SVB’s assets at a discount of $16.5 billion, according to an FDIC statement. This leaves about $90 billion in securities and other SVB assets in the hands of the FDIC, and an estimated cost of the failure to the Deposit Insurance Fund of about $20 billion. First Citizens said it will assume $56 billion in deposits, and 17 legacy branches will begin operating as Silicon Valley Bank, a division of First Citizens. There will be no immediate change to customer accounts. The transaction is the second...

Legal Regulation of Blockchain

Published: Olena Kamenetska | 07.11.2017 | blog

Legal regulation of blockchain. Latest changes and prospects for the development of legislation Blockchain Technology is a developing technology on which basis new applications in the field of finance appear daily. Regulators of some countries have already reported their intentions to study the use of blockchain technology, which is also called distributed ledger technology (DLT). The new technology is potentially attractive to the regulators because of the increased level of transaction security and risk reduction of manipulation, but, at the same time, it creates complex legal problems that regulators are trying to understand and resolve. In this article, we will try to make a brief analysis of the approach of regulatory authorities to blockchain technology. Regulation in the USA The regulators in the USA are seriously monitoring the development of blockchain and other DLT (as well as cryptocurrency, in circulation on the basis of such registers). Some express concern about their impact on financial stability and market integrity. At the same time, the US Securities and Exchange Commission (SEC) is actively exploring the potential possibilities of the use of blockchain and...

The Commission of US recommends anti-Chinese trade laws

Published: Sergey Panov | 22.11.2016 |

The US Congress and the US-China Economic and Security Review Commission in its report 2016, has recommended strengthening of the American procedures of a labor dispute and the legislation for counteraction of China of "refusal to support the liabilities of the World Trade Organization". In 2015, the American trade deficit of goods with China increased by 6.5 percent to record 367.2 billion US dollars. Last year the United States had essential, but much more a smaller positive trading balance with China in services of 29.5 billion US dollars. The commission says that China continues to brake on liberalization of key sectors in which the United States are competitive in the world market on services. Also, the Commission specified that "within the last 20 years, anti-dumping (AD) and the countervailing duty (CVD) were often pushed against China, about more than 1000 cases of AD initiated against China around the world since 1995. The Commission also considered demand of China, about its provision on market economy (ME) till December 11 of this year, and also the Commission confirmed that the US Commerce Department is now responsible for determining "whether is a country ME (market...

Kevin Brady:” The American tax reform won’t influence the income of the state”

Published: Sergey Panov | 18.11.2016 |

The representative of the budget committee Houses of Representatives Kevin Brady pointed out, that the American tax reform, which he expects to offer at the beginning of 2017, "will break even" on a dynamic basis of winning, which is additional revenue from increased economic growth. During a television interview with Fox News on November 16, Brady discussed how the Republican faction and president-elect Donald Trump will "co-operate to ensure for pro-growth tax reform." He explained that "we provide tax code so honestly and simply, that 95 percent of Americans will be able to use a file with a card system. Second, we reduce the rates for our local businesses and redesigning the way they are taxed, so that they can compete and win anywhere in the world, but especially here at home. And finally ... we propose to destroy the IRS, to redesign it in a much smaller, bespoke agency focused on customer service. This is our 'Built for Growth' tax plan." He told that the plan instead of reducing the tax revenue and to increase the American financial deficit, "will become profitable within the budget, knowing that from it the economy will grow. By our estimates, it will raise economy in...

A large number of emigrants refuse passports and green cards

Published: Sergey Panov | 11.11.2016 |

1,380 US taxpayers give up their passports or green cards in the third quarter of 2016, which is the second highest quarterly report, according to Treasury statistics, published in the Federal Register. A record number of 1,426 people was seen in the third quarter of last year. In the second quarter of this year, only 508 people abandoned their passports or green cards, as compared to the total amount of the second quarter in 2015 of 460 citizens. Treasury said that so far this year, 3,046 taxpayers renounced their citizenship, that is, less than 3,221 citizens who have done so in the first three quarters of 2015, and 3,415 taxpayers have given up everything in 2014. Increasing the number of people who refuse citizenship, especially from 2013, coincided with increased actions by the Treasury and the Internal Revenue Service, to track US undeclared assets and held abroad income in particular, through the application of Foreign Account Tax Compliance Act (FATCA) and the requirement to file a report of foreign bank and financial accounts. According to the authorities, Americans who live abroad are becoming more aware of their US tax reporting obligations. In particular, American...

ATR warns about a new property tax

Published: Sergey Panov | 03.11.2016 | news

1 November, the president of "Americans for Tax Reform" (ATR), Grover Norquist submitted a comment to the letter dated US Treasury Secretary Jacob Lew, counteracting the proposed decision, which will lead to an increase in the property tax (or "tax on death," as it is called). Under the current tax rules of real estate in accordance with Section 2704 of the Code of Internal Revenue, the fair market value of a share in the family business, which shall be held no current market - is not available on the basis of the test is "ready-seller willing-buyer". However, the proposed changes would allow the Internal Revenue Service in the future to produce much higher estimates, limiting the use of discounts. Norquist explained that "for families affected by the tax on the death of the two allowed discounts when determining the value of their property, lack of control discount and lack sold off. The lack of control discount can be claimed when the family has a minority ownership stake in the asset as a result of then a lower cost on the open market in holding the asset. The lack of marketability discounts apply when the asset is owned by the family and can not be easily eliminated due to...

Clinton and Trump on election policy

Published: Sergey Panov | 21.10.2016 | news

October 19 at the third and final debate before the election in the United States, the Republican candidate Donald Trump and the Democratic candidate Hillary Clinton confirmed each their widely differing tax policies, without providing any further details. In response to a question on tax policy, Clinton wants to provide a means for economic growth and "support of the middle class families," stating that "the rich should pay their fair share." He reiterated, however, that "will not raise taxes for those earning USD250,000 and a dime will no longer pay the state." In contrast, he said, the plan "Trump created for large tax cuts, which have ever been. His plan is to give the biggest tax breaks for all the rich and the great corporations, adding USD20 trillion of our debt. This action is not justified . We tried to do it, did not work." Trump said that his plan to raise taxes - it's a disaster. ... We're going to cut taxes massively. We will reduce taxes on business and on a large scale. We're going to return to USD2.5 trillion in the country that have left as a result of offshore business. We're going to start this process. He also said that he would re-negotiate the existing trade...

US Senate Progresses pension reforms

Published: Sergey Panov | 26.09.2016 |

Senate Finance Committee unanimously approved a bipartisan bill layout - improved savings and retirement Act 2016 - to make some changes in the pension provisions of the tax legislation. For example, in accordance with the present law, a person who has reached the age of 70.5, before the end of the year can not make contributions to a traditional individual retirement account (IRA). The law will revoke this ban. Ron Wyden (D - OR), Ranking Member of the Committee, said that the renewal provisions of the retirement age "is essential, especially because so many Americans are living longer, if they can afford to save for retirement, they must get permission to do that" . The second proposal is to change the calculation of the dollar limit amount on a non-refundable tax credit, currently provided for beginners small entrepreneur's cost adopted new qualified pension plan, a simple IRA plan (or SEP), provided that the cover of the plan, at least one is not of the strongest workers' compensation. Calculation of the three-year loan, currently less than USD500 per year, or 50 percent of qualified start-up costs. Under the proposed changes, a fixed amount of dollars for the fiscal year...

US Treasury limits the foreign tax credits

Published: Sergey Panov | 20.09.2016 |

The US Treasury and the Internal Revenue Service (IRS) issued a notice 2016-52, which declares its intention not to allow the US multinational, which has been the subject of foreign-initiated adjustment of the tax the use of foreign tax credits with no corresponding income repatriation. The notice was issued subsequent retroactive studies by the European Commission (EC), against US tax practices of transnational corporations, state aid, since a claim against Apple in the amount of up to EUR13 billion (USD14.5 billion), plus interest. Treasury Secretary Jack Lew has recently pointed out that the EC 'actions also threaten to undermine the corporate tax base of the United States. US companies can claim foreign tax credits to the account of the United States tax for any tax-related payments to the Member States." IRS will negate any attempt to divide the affected company additional taxes payable of related income, and thereby reduce their US tax bills. Separation of probable foreign taxes from the corresponding revenues will now be prevented, as a rule, putting the right to request loans is income not included in the taxable income of the United States. New rules in the...

Ireland drew US attention to changes in the agreement on double taxation

Published: Sergey Panov | 29.08.2016 |

Department of Finance of Ireland began meeting on the changes in the tax agreement with the United States. The Department explained that the update is seen as necessary in accordance with the decision of the United States to upgrade its model tax treaty. The United States took into account the recommendations on the update within reduce their tax base and shift profits. For example, in 2016, the model does not reduce withholding taxes on payments to highly mobile income - income that taxpayers can easily shift around the globe through deductible payments such as royalties and interest rates - which are made by persons who enjoy low or no tax in respect of income in accordance with the preferential tax regime. In addition, a new article obliges the partners to the extent necessary to make changes to the contract, if the changes cause a doubt one of the partners in the domestic law. Model 2016 also includes measures to reduce the tax benefits of corporate inversions. The update also included the US regulations, which provide that disputes between countries in the application of a double taxation agreement should be resolved through binding arbitration through the "last best...

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