Category: North America

Disgorgement Remedy Based on Unpaid Taxes From Wylys’ Securities Trading Profits

Sept. 29 — Samuel Wyly and the estate of Charles Wyly must pay a total of $188 million plus prejudgment interest based on taxes they would have paid on profits from offshore trusts (SEC v. Wyly, S.D.N.Y., No. 1:10-cv-05760, 2014 BL 267268, 9/25/14). Judge Shira A. Scheindlin issued an order… – Continue reading

Gideon Spanier: At last, Europe is targeting the tech giants on tax

American technology companies are suddenly living in fear. European governments are finally standing up to the power of these giants that are happy to talk about the benefits their digital products and services bring to society while being accused of not paying their fair share of corporation tax, not doing… – Continue reading

It’s Very Difficult To See How George Osborne’s Google Tax Could Possibly Be Legal

George Osborne, the Chancellor of the Exchequer over here in the UK, has just announced at the Conservative party conference that he’ll be changing the tax laws to make sure that Google GOOGL +0.16% and other tech multinationals (Facebook, Microsoft MSFT -0.17%, possibly Apple AAPL +0.64%, among them) end up… – Continue reading

Tax shelter shake-up hits home

A federal crackdown and a new act make life tougher for lawyers and accountants. Criminal tax attorney Robert Fink views the conviction and sentencing of his client Dr. Michael Canale—on tax fraud charges in New York state federal court in 2012—as representative of everything that’s wrong with the government crackdown… – Continue reading

Crackdown on Apple in Ireland Opens Front in Tax Avoidance War

The European Commission’s crackdown on the deal between Irish tax authorities and Apple Inc. marks an expansion in the growing global war on tax avoidance by multinational companies. Governments that enable it are now a target. Tuesday, the European Commission said the Irish tax authorities failed to conform to international… – Continue reading

EU says Ireland swapped Apple tax deal for jobs

The European Union has accused Ireland of swerving international tax rules by letting Apple shelter profits worth tens of billions of dollars from revenue collectors in return for maintaining jobs. European Competition Commissioner Joaquin Almunia told the Dublin government in a letter published on Tuesday that tax deals agreed in… – Continue reading

United States and Brazil Sign FATCA Intergovernmental Agreement

The United States and Brazil have signed a “Model 1” intergovernmental agreement (“IGA”) with respect to the US Foreign Account Tax Compliance Act (“FATCA”). The Brazilian IGA is intended to simplify FATCA information reporting and reduce compliance burdens for Brazilian financial institutions.

Apple’s foreign tax rate tumbled after 2007 Irish ‘advanced opinion’

The European Commission is expected to announce today that Apple, now one of the world’s biggest listed companies, got special treatment from the Irish authorities, when the American company sought assurances on tax issues in 1991 and 2007 – – from the latter year, Apple’s foreign tax rate tumbled compared… – Continue reading

Another tax-avoidance scheme is getting scrutiny

While it’s said that death and taxes are inevitable, enough money and clever maneuvering can apparently help sidestep the latter. Witness the so-called dividend arbitrage, which is raising concerns from regulators thanks to its ability to allow big banks to create $1 billion per year in revenue, according to The… – Continue reading

Europe to probe Apple further over Irish tax deals

European regulators are set to examine whether Apple violated EU law by striking special tax deals with the Irish government. The European Commission opened an initial investigation into Apple’s tax affairs in June, looking at whether the company’s two percent tax rate in Ireland — far less than the standard 12.5… – Continue reading

New tax-dodge rules prompt AbbVie to seek more Shire financing: sources

(Bloomberg) — AbbVie Inc. is examining plans to raise additional financing to complete its takeover of Shire Plc, after U.S. officials imposed new obstacles to so-called tax inversion deals, people with knowledge of the matter said. AbbVie may seek to borrow as much as $7 billion more than it originally… – Continue reading

Hiding Assets Under Pet Names Looks Willful, Even For Lionel Messi With 400 Goals

There is nothing illegal about tax planning. Yet some things are legal while others are not, and the lines can sometimes get fuzzy. Add to that the fact that some people go to extraordinary lengths to avoid paying taxes, and it can be a recipe for disaster. Increasingly, if you… – Continue reading

Another view: Low tax rates no way to build economy

Canada should not count on building its economy by luring U.S. multinationals over the border with low tax rates in light of an announcement from the U.S. Treasury Department this week. The department outlined new measures to block companies from escaping U.S. taxes by moving earnings outside the country. This… – Continue reading

IRS scam targets financial professionals, too

Now some in the financial services industry, as well as some consumers, are being warned that they could get a call one day from a fake IRS agent seeking bank account information. We’ve heard about the con artists who pretend to be from the Internal Revenue Service and demand immediate… – Continue reading

Trillion Dollar Scandal – the biggest heist you’ve never heard of

The World Bank analysed the world’s biggest corruption scandals over that past two decades. Seventy per cent involved anonymous shell companies Take a guess at how much is lost to developing countries each year through international corruption? $1 billion, maybe $10? Even more? The shocking truth is that $1trn a… – Continue reading

Billionaire Brothers Avoided Taxes by Hiding Stock

Back in the eighties and nineties, the Wyly brothers ran, and owned huge stakes in, a weird bunch of public companies, including some craft stores, some software companies, and a reinsurer. These companies were good and made the Wyly brothers a lot of money. An odd biological fact is that… – Continue reading

Holder legacy as tax-cheat catcher — But not everyone viewed him with rose-colored glasses — GOP to Holder: Good riddance

HOLDER LEGACY AS TAX-CHEAT CATCHER. Attorney General Eric Holder, who on Thursday announced he’s stepping down, made some pretty huge contributions to tax land during his six years on the job. Continuing the work his predecessor started prosecuting Swiss bank UBS, Holder maintained the department’s laser focus on tax evasion, starting… – Continue reading

The Skinny on Corporate Inversions

Corporate financial accounting and taxation are complex subjects. For this reason, many people tune out when issues that involve corporate tax practices rise to the level of public debate. Unfortunately, many legislators shy away from these issues for similar reasons. But while corporate taxation can be mind-bogglingly complex, nontax experts… – Continue reading

Tax avoidance under scrutiny

European Union Tax Commissioner Algirdas Šemeta has welcomed a raft of new measures to combat international tax avoidance, in agreement between the finance ministers of the G20 at a meeting in Cairns, Australia. The ministers have agreed on a several recommendations that were made to address key areas which were… – Continue reading

Lack of fairness with overseas tax evasion: We pay the price

The Government of Canada has been moving ahead with its plans to solve the deficit by cutting services to Canadians and yet, there are billions of dollars in taxable assets illegally hidden by some Canadians in overseas tax havens. Overseas tax evasion is a serious problem requiring assertive action. Eight… – Continue reading

Massimo Cellino’s Leeds reign under renewed threat after tax evasion ruling

 Italian judge rules Cellino guilty of ‘Machiavellian’ tax evasion • Football League rules bar club owners convicted of dishonesty • Cellino’s lawyer says judge’s ruling is ‘full to the brim of errors’ • How an elegant yacht became vital to Leeds United’s future • Cellino: I don’t know why I… – Continue reading

The Obama administration’s tougher rules on offshore corporate inversions had…

Stricter tax inversion rules punish stocks of firms mulling such moves. The Obama administration’s tougher rules on offshore corporate inversions had an immediate effect Tuesday, pushing down the stock prices of companies considering such moves.But the highly technical changes to the tax code di Stricter tax inversion rules punish stocks… – Continue reading

‘I was terrified we’d lose all our money’: banks tell US customers they won’t work with Americans

Thousands of Americans abroad are giving up their citizenship as the implementation of a complex new tax law causes banks to shut down accounts for US expatriates Angry Canadians are rare. But Patricia Moon qualifies. Until 2012, Moon was actually an American – albeit one who had lived in Canada… – Continue reading

Canada Revenue Agency tax dodge informant line receives 1,000 calls

Ottawa’s program that pays for tips to the Canada Revenue Agency about tax cheats has received more than a thousand calls since being set up earlier this year. In January, the federal government enacted the Offshore Tax Informant Program, which encourages citizens to become informants about Canadians trying to hide… – Continue reading

Lack of fairness with overseas tax evasion: Canadians pay the price

The Government of Canada has been moving ahead with its plans to solve the deficit by cutting services to Canadians and yet, there are billions of dollars in taxable assets illegally hidden by some Canadians in overseas tax havens. Overseas tax evasion is a serious problem requiring assertive action not… – Continue reading

Tory crackdown on tax evasion lost in a fog: Goar

After promising to flush out companies that stash their cash in offshore tax havens, the Harper government has lost its enthusiasm for ruffling corporate feathers. By: Carol Goar Star Columnist, Published on Tue Sep 23 2014 There has been scarcely a peep out of Ottawa since last winter’s promise to… – Continue reading

Minecraft, Nokia, Skype: How Microsoft Buys Overseas Companies To Avoid US Taxes

Nokia, Skype and Minecraft-maker Mojang have more in common than just the fact that they are among Microsoft’s biggest acquisition targets in recent years. They are all also based outside the U.S., and that’s no coincidence. As the debate over so-called inversions heats up and critics — from President Obama… – Continue reading

Treasury’s Inversion Rules Create Uncertain Environment For US Multinational Companies

The Obama administration’s new rules intended to stem the tide of inversions, in which U.S. companies reincorporate abroad to dodge taxes at home, won’t be completely effective because they don’t address the high corporate tax rate in the U.S. that compels such behavior, say tax experts and analysts. The rules announced… – Continue reading

Obama Treasury’s Corporate Inversion Regulations Simply Won’t Work

The Treasury Department today came out with a series of arcane new tax regulations in the hopes of stemming corporate inversions. Inversions happen when U.S. companies merge with a foreign company while usually retaining U.S. operations. Their purpose is to avoid punitive U.S. double taxation on income earned overseas. The… – Continue reading

New US Tax Rules Chill ‘Inversion’ Deal-Making

WASHINGTON/NEW YORK, Sept 23, (Agencies): Tough new US rules on corporate “inversions” on Tuesday sent a chill through the market for the tax-avoidance deals, both pending and potential, with share prices falling sharply in nearly a dozen companies on both sides of the Atlantic. As investors sold stocks involved in inversions,… – Continue reading

Brazil, U.S. sign tax pact frozen by spy scandal

Brazil signed a tax information exchange agreement with the United States to prevent tax evasion, the South American country’s finance ministry said on Tuesday, a step long sought by businesses that was held up by a spy scandal last year. The pact opens the door to a tax treaty to avoid the double… – Continue reading

Alibaba’s $21.8 Billion Inversion

Inversions are technically a financial transaction where a corporation from one country, say the United States, merges with a company in a foreign country, say Ireland. Nothing changes in the United States from a business point of view, except that the value and financial sustainability of the corporation goes up significantly. Why… – Continue reading

British Virgin Islands: BVI US And UK FATCA Implementation – Entity Classification And Registration

On 30 June 2014, the British Virgin Islands (“BVI“) government signed a Model 1B (i.e. non-reciprocal) intergovernmental agreement with the United States (the “US IGA“).  The US IGA provides a framework for the implementation of the US Foreign Account Tax Compliance Act (“FATCA“) in the BVI.  The BVI government had,… – Continue reading

Everything That’s Wrong with the US Tax System in One Chart

Last week the Tax Foundation released its annual International Tax Competitiveness Index for 2014. The United States ranked 32 out of 34 OECD countries surveyed. Only Portugal and France got lower competitiveness scores, and not by much. As if that were not bad enough, the competitiveness score is only half… – Continue reading

NZ banks baulking at global FATCA style initiative to combat tax evasion; Lobby group says the later we adopt it the better

All is likely to be revealed on whether New Zealand will be an early adopter of the multilateral follow up to the controversial United States Foreign Account Tax Compliance Act (FATCA) in November, with late adoption something that would please the local banking sector. Either way it’s a question of… – Continue reading

AstraZeneca Shares Tank on US Tax Avoidance Crackdown Pledge

AstraZeneca shares are leading the losers on the FTSE 100 after the US Treasury department revealed that it forging new rules that will make it more difficult for companies to move their bases abroad to avoid tax. The AstraZeneca stock price has tumbled by over 5% to 4348.50p by midday while rival GlaxoSmithKline was hit by 1.25% at… – Continue reading