Int'l Tax News
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Tax Court Holds Corporation Received Dividends From CFC
The Tax Court, sustaining accuracy-related penalties, held that funds a corporation received through a purported reinvestment plan from a controlled foreign corporationwere in substance dividend payments and taxable under section 301 and that the value of property transferred to the corporationwas includable in its income.
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For the opinion, go here. (Subscription required.)
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U.S. Tax Reform: Full-Inclusion Over Territorial System Compelling
Jeffery M. Kadet argues that rather than implementing a territorial system or continuingwith the current deferral system, the United States should implement aworldwide full-inclusion system.
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For the article, go here. (Subscription required.)
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We tried a Tobin tax and it didnt work
Europe is making a mistake. In February, the European Commission published a proposal for a financial transaction tax also called a Tobin orRobin Hood tax in the EU. Eleven states have been granted the right to impose a minimum 0.1 per cent tax on equity and debt transactions and a minimum 0.01 per cent charge on derivatives transactions. If the experience of Sweden's use of such a tax is anything to go by, this move is extremely unwise.
For the article, go here.
For the article, go here.
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UK Shadow Business Secretary Chuka Umunna would not back an FTT without New York
The opposition Labour member of Parliament said itwould belunacy for the UK to unilaterally adopt a financial transaction tax (FTT).
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For the article, go here. (Subscription required.)
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Levin: Corporations should pay fair share
In a USA Today op-ed piece, Sen. Sander Levin (D-MI), argues that loopholes allow some companies to pay no taxes, putting added burden on Americans.
For the article, go here.
For the article, go here.
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Fairness in International Taxation Act Would Limit Treaty Benefits for Some Corporations
The Fairness in International Taxation Act, introduced by Houseways and Means Committee member Lloyd Doggett, D-Texas,would limit treaty benefits for corporations attempting to avoid U.S. taxes.
For the bill, go here.
For the bill, go here.
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Doggett Bill Would Introduce Measures Against International Corporate Tax Avoidance
The International Tax Competitiveness Act of 2013, introduced by Houseways and Means Committee member Lloyd Doggett, D-Texas,would modify the treatment of foreign corporations managed as U.S. domestic corporations and change the tax treatment of royalties received from controlled foreign corporations.
For the bill, go here.
For the bill, go here.
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Stop Tax Haven Abuse Act Would Restrict Use of Offshore Tax Havens
The Stop Tax Haven Abuse Act, introduced by Houseways and Means Committee member Lloyd Doggett, D-Texas,would implement various measures intended to reduce tax evasion through offshore tax havens, including expanded information reporting and increased penalties against tax shelter promoters.
For the bill, go here.
For the bill, go here.
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Doggett Announces Legislation to Combat Tax Haven Abuse
The Stop Tax Haven Abuse Act, the International Tax Competitiveness Act, and the Fairness in International Taxation Actwould each provide measures to crack down on corporations' use of tax havens to avoid U.S. taxes, according to an April 15 release from Houseways and Means Committee member Lloyd Doggett, D-Texas.
For the article, go here.
For the article, go here.
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On Tax Day, Complexity Trumps Competitiveness
Today is tax day in the United States, the deadline for filing income tax returns and making any outstanding tax payments for the previous calendar year. Youwould be hard-pressed to find any U.S. taxpayerwho loves (or even likes) Americas current tax system.what American citizens and companies alike find especially troubling is the systems complexity that increasingly penalizes America in the global economy.
For article, go here.Posted on
CTJ: "The U.S. Continues to Be One of the Least Taxed of the Developed Countries "
The U.S.was the third least taxed country in the Organization for Economic Cooperation and Development (OECD) in 2010, the most recent year forwhich OECD has complete data.
Of all the OECD countries,which are essentially the countries the U.S. tradeswith and competeswith, only Chile and Mexico collect less taxes as a percentage of their overall economy (as a percentage of gross domestic product, or GDP).
For the CTJ report, go here.
Of all the OECD countries,which are essentially the countries the U.S. tradeswith and competeswith, only Chile and Mexico collect less taxes as a percentage of their overall economy (as a percentage of gross domestic product, or GDP).
For the CTJ report, go here.
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"Tech Companies Love Dublin's Tax Rates"
Dublin's Grand Canal Square, just south of the River Liffey, is known as Googletown. In 2011, Google (GOOG),which employs more than 2,500 people in Ireland, bought the neighborhood's 15-story Montevetro building. Nearby is Facebook's (FB) European headquarters, alongwith outposts for LinkedIn (LNKD), Yahoo! (YHOO), and other U.S. technology companies, some of them Dublin fixtures for over a decade. Theyve been drawn to expand there by the strapped government's flat 12.5 percent corporate tax rate.
For the article, go here.
For the article, go here.
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Stakeholders Agree on Approach to Tackling Base Erosion and Profit Shifting
Business representatives and OECD and government officialswho attended a recent Paris meeting on the OECD's base erosion and profit shifting (BEPS) initiative seemed to agree that fundamental international tax standards should be tweaked, not replaced, to combat BEPS, David Ernick of PricewaterhouseCoopers LLP told Tax Analysts April 5.
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For the article, go here. (Subscription required.)
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News Analysis: Is Multinational Tax Planning Over?
In news analysis, Lee A. Sheppard says the European Union's strugglewith aggressive tax planning shows that the OECD base erosion and profit shifting project is genuine and that the golden age for tax planning might be over.
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For the article, go here. (Subscription required.)
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Baucus and Camp: "Tax Reform Is Very Much Alive and Doable "
Everyweek Congress has been in session for the past two years, one of us has made the shortwalk across the Capitol to the other's office.we crowd into a roomwith our policy experts to chart a path to our mutual goal -- comprehensive tax reform.
Whilewe are from different political parties,we agree that America's tax code is broken. That iswhywe have beenworking together as the chairmen of Congress's two-taxwriting committees to make it fairer for families and spark a more prosperous economy.
The last overhaul of the tax codewas more than a quarter century ago, and there is a need to get rid of its unnecessary complexity. Taxpayers spend more than six billion hours filling out documents to complete filings. They struggle to understand the rules,which amount to almost four millionwords. That is neither a productive use of time or resources.we can and must do better.
For the article, go here.
Whilewe are from different political parties,we agree that America's tax code is broken. That iswhywe have beenworking together as the chairmen of Congress's two-taxwriting committees to make it fairer for families and spark a more prosperous economy.
The last overhaul of the tax codewas more than a quarter century ago, and there is a need to get rid of its unnecessary complexity. Taxpayers spend more than six billion hours filling out documents to complete filings. They struggle to understand the rules,which amount to almost four millionwords. That is neither a productive use of time or resources.we can and must do better.
For the article, go here.
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Tax Policy Bulletin: OECD iniative on Base Erosion and Profit Shifting (BEPS)
This bulletin addresses the Base Erosion and Profit Shiftingwork-stream of the Organisation for Economic Cooperation and Development (OECD) and the OECD's progress report on the topic for the G20.
For the article, go here.
For the article, go here.
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International Implications of Corporate Tax Rate Reductions
Corporate tax rates and all that
•what are the international implications of potential U.S. corporate tax rate reductions?
• Thatwould depend, of course, on exactlywhat additional provisions, including revenue enhancing base broadeners, are included alongwith any corporate tax reductions.
• Evidence from OECD tax changes from 1980-2004 is that half the time corporate statutory rate changes are accompanied by base changes, though more often than not tax rate reductions are imposed alongwith base narrowing.
• For now, however, consider only rate changes.
For full presentation go here:
•what are the international implications of potential U.S. corporate tax rate reductions?
• Thatwould depend, of course, on exactlywhat additional provisions, including revenue enhancing base broadeners, are included alongwith any corporate tax reductions.
• Evidence from OECD tax changes from 1980-2004 is that half the time corporate statutory rate changes are accompanied by base changes, though more often than not tax rate reductions are imposed alongwith base narrowing.
• For now, however, consider only rate changes.
For full presentation go here:
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Picking Up the Tab 2013
Some U.S.-based multinational firms and individuals avoid paying U.S.
taxes by using accounting tricks to shift profits made in America to
offshore tax havens countrieswith minimal or no taxes. They benefit
from their access to Americas markets,workforce, infrastructure and
security; but they pay little or nothing for it violating the basic
fairness of the tax system and forcing other taxpayers to pick up the
tab.
For article go here.
For article go here.
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Economic Analysis: U.S. Contract Manufacturing and Dave Camp's Option C
Nearly a decade ago, H. David Rosenbloom of New York University School of Law asked: "Why should U.S. companies be required to situate economic functions abroad to achieve a desirable result?"
Rosenbloomwent on to suggest that the practical
exemption from U.S. tax for foreign-based companies that perform a "middleman
function" should be extended to subsidiaries performing the same function in the
United States. That might erode the U.S. corporate tax base, but, Rosenbloom
countered, itwould eliminate distortions, promote U.S. employment, and have no
detrimental effects on the competitiveness of U.S. multinationals. (Prior
coverage: "Why Not Des Moines? A Fresh Entry in the Subpart F Debate," Tax
Notes, Jan. 12, 2004, p. 274
.)
For article go here.
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Small Businesses Hurt by Tax Breaks For Multinational Firms, Group Complains
Tax havens for multinational corporations are bad for small business, a group opposed to the tax benefits reported April 4.
The U.S. Public Interest Research Group reported that multinational corporations gain an unfair competitive advantage by averting about $90 billion annually in taxes through tax code provisions like the indefinite deferral of taxes on profits earned outside the United States.
For the article, go here. (Subscription required.)
The U.S. Public Interest Research Group reported that multinational corporations gain an unfair competitive advantage by averting about $90 billion annually in taxes through tax code provisions like the indefinite deferral of taxes on profits earned outside the United States.
For the article, go here. (Subscription required.)
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SIFMA Urges Lew to Push Europe To Pare Back Financial Transactions Tax Plan
Treasury Secretary Jacob J. Lew should push European policymakers to pare back plans for a broad financial transactions tax, industry opponents to the tax said in an April 3 letter to Lew.
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For the article, go here. (Subscription required.)
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3M Fighting IRS in Tax Court Over Imputed Royalties; Says Regs Are Invalid
U.S. technology company 3M Co. is taking the IRS to Tax Court over adjustments resulting from the agency's decision to allocate $23.6 million of additional royalty income from the company's Brazilian subsidiary to its U.S. headquarters, even though Brazilian law prohibits payment of the royalties to the parent.
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For the article, go here. (Subscription required.)
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Christian Aid: "Multinational Corporations and the Profit-Sharing Lure of Tax Havens"
In February 2013, the Organisation for Economic Co-operation and Development (OECD) published its report Addressing Base Erosion and Profit Shifting. The report is the OECD's initial response to the mandate it received in 2012 from some political leaders in developed countries,which showed concern about the problem of tax-base erosion and profit shifting by multinational corporations (MNCs).
In the report, the OECD acknowledges that the current international tax system has not kept pacewith developments in the business environment, providing MNCswith plenty of opportunities to exploit legal loopholes and enjoy double non-taxation of income (ie tax-free earnings).
The adoption of profit-shifting strategies by MNCs is identified as one of the main causes of base erosion. According to the OECD, abusive tax avoidance by MNCs raises serious issues of fairness and compliance.
How tax avoidance and evasion can hamper development efforts has been an important area of research in the past few years. This paper contributes to the debate by investigating the link between tax evasion and avoidance, profit shifting and tax havens.
For the paper, go here.
In the report, the OECD acknowledges that the current international tax system has not kept pacewith developments in the business environment, providing MNCswith plenty of opportunities to exploit legal loopholes and enjoy double non-taxation of income (ie tax-free earnings).
The adoption of profit-shifting strategies by MNCs is identified as one of the main causes of base erosion. According to the OECD, abusive tax avoidance by MNCs raises serious issues of fairness and compliance.
How tax avoidance and evasion can hamper development efforts has been an important area of research in the past few years. This paper contributes to the debate by investigating the link between tax evasion and avoidance, profit shifting and tax havens.
For the paper, go here.
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Peterson Institute: "Corporate Tax Reform and U.S. MNCs: Ensuring a Competitive Economy"
The debate about "tax reform," during the 2012 presidential race and congressional budget battles this year has centered on closing loopholes, creating new incentives for growth, and raising revenue through higher personal taxation ofwealthy Americans. But the debate overlooks an important priority for future US economic growth: the urgent need to reform the corporate tax. US-based multinational corporations (MNCs) are hobbled by an outmoded tax structure as they compete in the age of globalization.
For the paper, go here.
For the paper, go here.
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Bank of America Finds Profit in Foreign Tax Credit Moves
Bank of America Corp. more than doubled its profits in 2012 --with some help from the tax code.
What the bank calls restructuring of its non-U.S. operations yielded $1.7 billion in foreign tax credits, or 41 percent of the $4.2 billion the company reported in 2012 earnings, according to securities documents including the form 10-K it filed Feb. 28.while the maneuvers didnt provide an immediate cash tax benefit for Bank of America, the foreign tax credits count toward net income under accounting rules.
The transactions and the banks decision to take some risk that the creditswill expire unused indicate the sometimes contradictory incentives that companies have under the U.S. tax codes treatment of income earned overseas.
For the article, go here.
What the bank calls restructuring of its non-U.S. operations yielded $1.7 billion in foreign tax credits, or 41 percent of the $4.2 billion the company reported in 2012 earnings, according to securities documents including the form 10-K it filed Feb. 28.while the maneuvers didnt provide an immediate cash tax benefit for Bank of America, the foreign tax credits count toward net income under accounting rules.
The transactions and the banks decision to take some risk that the creditswill expire unused indicate the sometimes contradictory incentives that companies have under the U.S. tax codes treatment of income earned overseas.
For the article, go here.
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Economic Analysis: U.S. Contract Manufacturing and Dave Camp's Option C
On March 15 at awashington conference sponsored by the Tax Policy Center and the International Tax Policy Forum, titled "Tax Policy and U.S. Manufacturing in a Global Economy," the conversation focused onwhether manufacturing should get preferential tax treatment. Those in favor said manufacturing is mobile and research-intensive and that there is a strong economic case that mobile capital and research should be tax favored. Opponents said mobile capital and research should be subsidized directly if necessary, not manufacturing generally, and that in any case, the political and administrative difficulties of definingwinners and losers greatly dilute any potential benefits.
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For the article, go here. (Subscription required.)
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Transfer Pricing One of Three Work Areas Under OECD Project, Treasury Official Says
A U.S. Treasury official said March 27 that thework of the Organization for Economic Cooperation and Development's base erosion and profit shifting (BEPS) project has been organized into three clusters—base erosion, jurisdiction to tax, and transfer pricing.
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For the article, go here. (Subscription required.)
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Survey: Majority of Multinationals Expect Worldwide Increase in Transfer Pricing Audits
Multinational corporations are gearing up for increased levels of scrutiny of their transfer pricing policies, and a large majority admit they do not have a clear grasp of how they are treating their intangible assets for tax purposes, according to a survey released March 27 by consulting firm Taxand.
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For the article, go here. (Subscription required.)
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How to Unlock That Stashed Foreign Cash
Here's a novelway to drive up a company's share price: Pay billions of dollars in additional taxes.
Deliberately bloating your own tax bill isnt a common strategy, of course. To the contrary, an army of lawyers, accountants, lobbyists and executives is atwork throughout corporate America, finding legalways to minimize taxes and retain profits. One common approach for multinational corporations is to stash foreign earnings in low-tax countries, keeping the money out of the reach of the Internal Revenue Service.
For the article, go here.
Deliberately bloating your own tax bill isnt a common strategy, of course. To the contrary, an army of lawyers, accountants, lobbyists and executives is atwork throughout corporate America, finding legalways to minimize taxes and retain profits. One common approach for multinational corporations is to stash foreign earnings in low-tax countries, keeping the money out of the reach of the Internal Revenue Service.
For the article, go here.
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How Firms Tap Overseas Cash
U.S. companies say much of their cash is trapped overseas. But that doesn't mean they can't put it to use at home.
With some careful structuring, companies including Hewlett-Packard Co. HPQ+1.10% and General Electric Co. GE+0.09% have set upways to borrow money from their foreign subsidiaries. In some cases, the firms use the funds for daily operations or to buy back stock.
The loans have to be short term. Yetwhen the borrowing is carefully set up to complywith Internal Revenue Service rules and U.S. auditing standards, the funds can be used over and overwithout incurring taxes.
For the article, go here.
With some careful structuring, companies including Hewlett-Packard Co. HPQ+1.10% and General Electric Co. GE+0.09% have set upways to borrow money from their foreign subsidiaries. In some cases, the firms use the funds for daily operations or to buy back stock.
The loans have to be short term. Yetwhen the borrowing is carefully set up to complywith Internal Revenue Service rules and U.S. auditing standards, the funds can be used over and overwithout incurring taxes.
For the article, go here.
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Big Business Spars Over Rewriting Tax Code
The idea of overhauling the corporate-tax code is greetedwith applause by nearly all U.S. big businesses. That unanimity breaks down once the conversation turns to details.
One sign of that is the splintering of big companies into different groups promoting different strains of tax reform. High-tech, pharmaceutical and consumer-products companies, for instance, are eager to change theway overseas profits are taxed. Big domestic retailers, banks and telecommunications firms, in contrast, are more eager to see the corporate-tax rate come down.
For the article, go here.
One sign of that is the splintering of big companies into different groups promoting different strains of tax reform. High-tech, pharmaceutical and consumer-products companies, for instance, are eager to change theway overseas profits are taxed. Big domestic retailers, banks and telecommunications firms, in contrast, are more eager to see the corporate-tax rate come down.
For the article, go here.
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BEPS Solutions Should Target Source of Problems, Rolfes Says
The Treasury Department supports the objectives of the OECD's project on base erosion and profit shifting (BEPS), but itwants to ensure that any suggested solutions target the source of the problems and don't go beyond the scope of the BEPS project, according to Treasury International Tax Counsel Danielle Rolfes.
Speaking at a March 27 Bloomberg BNA Tax Management luncheon inwashington sponsored by Buchanan Ingersoll & Rooney PC, Rolfes said Treasury agrees that some of the international tax rules are outdated and need to be overhauled to better alignwith today's global economy.
For the article, go here. (Subscription required.)
Speaking at a March 27 Bloomberg BNA Tax Management luncheon inwashington sponsored by Buchanan Ingersoll & Rooney PC, Rolfes said Treasury agrees that some of the international tax rules are outdated and need to be overhauled to better alignwith today's global economy.
For the article, go here. (Subscription required.)
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"Internal Ownership Structures of Multinational Firms"
This paper is the first comprehensive analysis of the foreign ownership structures of U.S. multinational firms. Though the vast majority of foreign subsidiaries are ultimatelywholly-owned by their U.S. parents, the authors show that theway these subsidiaries are arrangedwithin ownership structures varies considerably from simple to highly complex, and that much of this variation cannot be explained by basic firm characteristics, such as size, age, industry, or diversification.
For the paper, go here.
For the paper, go here.
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For Dow 30, tax burden isn't what it used to be
Awashington Post analysis found that in the late 1960s and early 1970s, companies listed on the current Dow 30 routinely cited U.S. federal tax expenses thatwere 25 to 50 percent of theirworldwide profits. Now, most are reporting less than half that share.
The reason is not simply a few loopholes tucked deep in the tax code. It's far bigger: the slow but steady transformation of the American multinational after years of globalization. Companies now have an unprecedented ability to move their capital around theworld, and the corporate tax code has not kept upwith the changes.
For the article, go here.
The reason is not simply a few loopholes tucked deep in the tax code. It's far bigger: the slow but steady transformation of the American multinational after years of globalization. Companies now have an unprecedented ability to move their capital around theworld, and the corporate tax code has not kept upwith the changes.
For the article, go here.
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Shay Proposals Would Strengthen Source-Country and Residence-Country Taxation
Stephen Shay, former Treasury deputy assistant secretary for international tax affairs, on March 21 argued that international tax rules must be reformed to address intermediaries that have little economic substance, and he outlined his proposals for doing that by strengthening both source-country and residence-country tax rules.
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For the article, go here. (Subscription required.)
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HM Treasury - Budget 2013 Statement
UK Chancellor of the Exchequer George Osborne delivered the 2013 Budget Statement on March 20.
For the statement, go here.
For the statement, go here.
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Trading Clamps Spur Lobby Effort
High-speed trading firms and exchanges are being forced into the lobbying game by taxes on trades in Europe, proposals for similar levies in the U.S. and beefed-up regulatory scrutiny.
While still far less conspicuous than big banks and their legions of arm-twisters, executives and lobbyists for trading firms and exchanges have stepped up their behind-the-scenes efforts to avert specific rules and legislation, say staff members in Congress and agencies.
For the full article, go here.
While still far less conspicuous than big banks and their legions of arm-twisters, executives and lobbyists for trading firms and exchanges have stepped up their behind-the-scenes efforts to avert specific rules and legislation, say staff members in Congress and agencies.
For the full article, go here.
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Treasure Island Trauma
A couple of years ago, the journalist Nicholas Shaxson published a
fascinating, chilling book titled "Treasure Islands,"which explained
how international tax havens --which are also, as the author pointed
out, "secrecy jurisdictions"where many rules don't apply
-- undermine economies around theworld. Not only do they bleed
revenues from cash-strapped governments and enable corruption; they
distort the flow of capital, helping to feed ever-bigger financial
crises.
For the full article, go here.
For the full article, go here.
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Pop (or Is That BEPS?) Goes the Weasel
Christopher E. Berginwrites that addressing base erosion and profit shifting may be the nextweapon in thewar on tax avoidance schemes, and that it comes not a moment too soon.
For the article, go here. (Subscription required.)
For the article, go here. (Subscription required.)
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What You Should Know about the RATE Coalition's Quest for a Lower Corporate Tax Rate
Thisweek, members of Congresswill receive a visit from the tax vice presidents of major corporations that have come together in the so-called Reforming America's Taxes Equitably (RATE) Coalition, a corporate lobbying group pressing lawmakers to reduce the corporate tax rate.
The first thing you should know about the RATE Coalition is that their rhetoric about the U.S. having a high corporate tax is nonsense. The U.S. statutory corporate income tax rate of 35 percent,which RATEwants to reduce, is not as important as the effective corporate tax rate the percentage of profits that corporations actually pay in taxes after accounting for all the loopholes and breaks that lower their tax bills.
For the Citizens for Tax Justice release, go here.
The first thing you should know about the RATE Coalition is that their rhetoric about the U.S. having a high corporate tax is nonsense. The U.S. statutory corporate income tax rate of 35 percent,which RATEwants to reduce, is not as important as the effective corporate tax rate the percentage of profits that corporations actually pay in taxes after accounting for all the loopholes and breaks that lower their tax bills.
For the Citizens for Tax Justice release, go here.
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Business Roundtable Releases Global Competitiveness Tax-Rate Bracket
The Campaign for Home Court Advantage,which compares countrieswith the highest combined national and sub-national corporate tax rates and the largest economies, shows that the "outdated, broken" U.S. corporate tax system causes a competitive disadvantage and should be modernized, according to a March 20 Business Roundtable release.
For the release, go here.
For the release, go here.
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Cut Corporate Tax Loopholes, Multiple Taxation of Dividends, OECD Tells France
France should reduce loopholes for its corporate tax rate, and it should reduce multiple taxation of dividends as part of a thorough simplification of its tax system, according to a report released March 19 by the Organization for Economic Cooperation and Development.
For the article, go here. (Subscription required.)
For the article, go here. (Subscription required.)
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Lawmakers Request Meeting With Treasury to Discuss U.S. Financial Transaction Tax
Rep. Peter A. DeFazio, D-Ore., and Rep. Keith Ellison, D-Minn., have requested a meetingwith Treasury to discuss the merits of a financial transaction tax in the United States, seeking to explain their legislative proposals and demonstrate how the tax can raise substantial revenue and provide a simpleway to reduce excessive risk onwall Street.
For the letter, go here. (Subscription required.)
For the letter, go here. (Subscription required.)
Posted on
BEPS Action Plan Will Provide a Sense of Direction, OECD Tax Director Says
The OECD's coming action plan on base erosion and profit shifting (BEPS)will not include firm measures to implement reform, but itwill provide a valuable sense of direction, Pascal Saint-Amans, director of the OECD's Centre for Tax Policy and Administration, said March 19.
For the article, go here. (Subscription required.)
For the article, go here. (Subscription required.)
Posted on
OECD official discusses BEPS project at TEI meeting
Pascal Saint-Amans, Director of the OECD Centre for Tax Policy and Administration, discussed the OECD's project on base erosion and profit-shifting (BEPS) at the March 19 meeting of the Tax Executives Institute (TEI). Attached is his TEI presentation.
For presentation go here.
For presentation go here.
Posted on
Have U.S. Multinationals Found a New Incentive to Repatriate?
In a letter to the editor of Tax Notes, H. David Rosenbloom comments on a recent rise in U.S. tax receipts from U.S. multinationalswith substantial holdings offshore.
For the letter, go here. (Subscription required.)
For the letter, go here. (Subscription required.)
Posted on
OECD Enables Companies to Avoid $100 Billion in Taxes
Headquartered in a former Rothschild chateau in an affluent Parisian neighborhood, the Organization for Economic Cooperation and Development is best known for earnest conferences on economic and social policy.
With little outside attention, it also plays a pivotal role enabling global corporations such as Google Inc. (GOOG), Hewlett- Packard Co. and Amazon.com Inc. (AMZN) to dodge taxes by shifting profits into offshore subsidiaries, costing the U.S. and Europe more than $100 billion a year.
OECD officials have been digging themselves deeper and deeper into a hole by blindly pursuing a mistaken approach that allows multinationals to avoid taxes, said Sol Picciotto, an emeritus professor of law at Lancaster University in the U.K.
For the article, go here.
With little outside attention, it also plays a pivotal role enabling global corporations such as Google Inc. (GOOG), Hewlett- Packard Co. and Amazon.com Inc. (AMZN) to dodge taxes by shifting profits into offshore subsidiaries, costing the U.S. and Europe more than $100 billion a year.
OECD officials have been digging themselves deeper and deeper into a hole by blindly pursuing a mistaken approach that allows multinationals to avoid taxes, said Sol Picciotto, an emeritus professor of law at Lancaster University in the U.K.
For the article, go here.
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OECD and BIAC on why revisiting tax rules may help build public trust
Tax is not a struggle to the death, say Pascal Saint-Amans, director of the OECD's Centre for Tax Policy and Administration andwill Morris, chair of the OECD's business advisory branch (BIAC) tax committee and global tax policy director for GE.
For the article, go here. (Registration required.)
For the article, go here. (Registration required.)
Posted on
Rough Justice on Foreign Tax Credits
New York lawyers had a virtual trip towashington on March 14,when Senate Finance Committee International Tax Counsel Jefferson VanderWolk visited the International Tax Institute. VanderWolk, for his part, got a taste of New York lawyers' expectations that their policy advicewill be adhered to.
The question at handwas the use of foreign law in U.S. tax law, specifically, reliance on foreign legal conclusions. A brief history: foreign law has been relevant forever, on simple factual issues like did the taxpayer pay a foreign tax. But only in recent years has U.S. law explicitly relied on foreign legal conclusions for U.S. results.
For the article, go here. (Subscription required.)
The question at handwas the use of foreign law in U.S. tax law, specifically, reliance on foreign legal conclusions. A brief history: foreign law has been relevant forever, on simple factual issues like did the taxpayer pay a foreign tax. But only in recent years has U.S. law explicitly relied on foreign legal conclusions for U.S. results.
For the article, go here. (Subscription required.)
Posted on
Lawmakers unified in call to fix international tax system for business Read more: http://www.politico.com/story/2013/03/lawmakers-unified-in-call-to-fix-international-tax-system-for-business-88911.h
Corporate America doing business abroad needs more than a once-in-a-generation repatriation to bring profits home to the United States at low tax rates it needs a better international tax system, a group of bipartisan lawmakers said Friday.
For the article, go here.
For the article, go here.
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