Category: Puerto Rico

Guam, other US territories in European Union’s dirty-money blacklist again

Guam, American Samoa, Puerto Rico and the U.S. Virgin Islands are included in the European Nation’s updated list of areas that are deemed hot spots for money laundering and terrorism financing. The U.S. Department of Treasury rejected the inclusion of U.S. territories, calling into question the substance of the EU… – Continue reading

Puerto Rico markets its “Tax haven” to attract cryptocurrency investors

Puerto Rico’s Governor, Ricardo Rossello in a move to attract crypto investors and holders to live in its land made an open call to everybody to come and take advantage of the tax haven. Puerto Rico recently got devastated by hurricanes Maria and Irma and is trying to recover slowly… – Continue reading

IRS offers tax relief to hurricane victims in Puerto Rico and Virgin Islands

The Internal Revenue Service released guidance Wednesday to give tax relief to residents of Puerto Rico and the U.S. Virgin Islands who have evacuated the islands or were unable to return because of Hurricanes Irma or Maria. The relief extends the typical 14-day absence period to 117 days (starting Sept…. – Continue reading

How Microsoft moves profits offshore to cut tax bill

SEATTLE — When someone in Seattle buys a copy of Office at a Microsoft Store, that cash doesn’t take the short route to the company’s area headquarters. Instead, after accounting for state taxes, the profit goes to a Microsoft sales subsidiary in Nevada. From there, much of that money begins… – Continue reading

How Microsoft moves profits offshore to cut its tax bill

Cash doesn’t flow directly from buyers’ pockets to Microsoft’s headquarters in Redmond, Wash. Instead, the company operates through three regional sales units, centered in Ireland, Singapore and Puerto Rico. These groups control the rights to profit from Microsoft products around the world. By conducting sales from places with small populations… – Continue reading

“Imposing a tax increase” Transfer Pricing “and basing it on sale is confiscatory”

The Association of Retail Trade (ACDET), which is part of Walmart, defended the decision to the chain filed a lawsuit against the government and the law 72. Considers that the law is unconstitutional and arbitrarily penalize one company. “Since April we warn the people that the measures were being discussed… – Continue reading

Wal-Mart Sues Puerto Rico Over ‘Astonishing’ Tax Increases

   Island’s biggest employer files suit in San Juan federal court    Legal challenge comes as Puerto Rico copes with debt payments The Puerto Rico unit of Wal-Mart Stores Inc. sued the island’s government, seeking to overturn a new tax the retailer calls unfairly high. Enacted in May, Puerto Rico’s… – Continue reading

DAVIS: A refresher on foreign asset reporting requirements

Recently, the Internal Revenue Service announced the exchange of financial account information with certain foreign tax administrations as the next step in efforts to combat offshore tax evasion. This is a significant portion of the IRS’s efforts to enforce FATCA, the Foreign Account Tax Compliance Act, which was enacted in… – Continue reading

Microsoft, IRS spar over long-running probe of its taxes

The Redmond tech company and the Internal Revenue Service tangled in court Friday over the government’s audit of Microsoft’s software sales through offshore subsidiaries. Microsoft and the Internal Revenue Service sparred in court Friday over the agency’s power to investigate taxpayers. Microsoft, seeking a court order to overturn a portion… – Continue reading

Marco Rubio’s Billionaire Backer Likes to Sue Poor Countries and Put Profits in Tax Havens

Paul Singer has a good track record as a money manager. In 1995, he bought $20 million worth of Peruvian debt at a discounted price of $11.4 million, then forced Peru’s government, through lawsuits, to eventually pay nearly five times his initial investment — some $58 million. In 2002 and… – Continue reading

New Report Sounds Alarm on US Corporate Tax Rate

Do your individual clients howl about paying too much federal income tax? Just wait until you get an earful from your business clients. Advertisement A new report from the Tax Foundation, a conservative-leaning think tank located in our nation’s capital, found that the United States has the third-highest marginal corporate… – Continue reading

Puerto Rico must wake up from its tax haven dreams

On October 5, the Organization for Economic Cooperation and Development (OECD) unveiled the consensus plan reached by the Group of 20 and more than 40 other countries regarding its base erosion and profit shifting (BEPS) project. BEPS refers to tax-dodging tactics by multinationals that erode a home country’s tax base… – Continue reading

US Has World’s Third-Highest Corporate Tax Rate

Not only does the United States retain the dubious distinction of having the highest corporate tax rate in the Organisation for Economic Cooperation and Development country grouping, it now has the third-highest rate of corporate tax in the world, according to the Tax Foundation. The non-partisan tax policy think tank… – Continue reading

International Tax Reform May Still Be a Possibility; Treasury Focused on FATCA, PTPs

Tax Reform Still in Ryan’s Sights Despite Boehner’s Departure Last week, following the sudden announcement by House Speaker John Boehner (R-OH) that he would be stepping down from Congress at the end of October, House Ways and Means Committee Chairman Paul Ryan (R-WI) and various other Committee members quickly confirmed… – Continue reading

Transfer pricing audits: flipping the tested party

Introduction Transfer pricing methods and tested parties Troubling trend Tools for taxpayers Introduction In some recent transfer pricing audits the Internal Revenue Service (IRS) has ‘flipped the tested party’ after examining transactions between related US and foreign companies. Typically, this practice results in the attribution of a larger portion of… – Continue reading

Microsoft’s Offshore Profit Pile Surges Past $100 Billion Mark

Microsoft Corp.’s stockpile of offshore profits rose to $108 billion, with a 17 percent increase over the past year as the company continues reaping profits in low-tax foreign jurisdictions. The company crossed the $100 billion mark, making it just the second U.S. corporation — after General Electric Co. — to… – Continue reading

Microsoft, IRS going to court over longtime tax scrutiny

The IRS’ investigation into Microsoft books centers on how the company uses its overseas subsidiaries for tax purposes. The company says the IRS audit has gone on long enough and the federal agency improperly hired an outside law firm to help in the investigation. Microsoft and the federal government have… – Continue reading


Washington, D.C. – As tax day approaches, it’s important to remember that small businesses end up picking up the tab for offshore tax loopholes used by many large multinational corporations. U.S. PIRG joined Senator Bernie Sanders, Bryan McGannon of the American Sustainable Business Council, and Bob McIntyre of Citizens for… – Continue reading

Multinationals should be made to pass “common sense” test on where they get taxed

The Australian Taxation Office should be given the power to ignore multinational transactions that fail to pass the “common sense test” and ensure that technology company profits are taxed where they are earned, the Australia Institute submission to the inquiry into corporate tax avoidance says. The submission takes a swipe… – Continue reading

As Middle Class Flees, Puerto Rico Tries Luring Rich People

Bond trader Ben Eiler swapped life in suburban Georgia for an island in the Caribbean, and he didn’t even have to apply for a visa. The towering 38-year-old native of Arkansas is one of at least 250 people who’ve accepted Puerto Rico’s invitation to well-heeled U.S. citizens to move to… – Continue reading

New tax incentives draw investors to Puerto Rico as middle class continues flight from island

As middle class flees, Puerto Rico tries luring rich people The towering 38-year-old native of Arkansas is one of at least 250 people who’ve accepted Puerto Rico’s invitation to well-heeled U.S. citizens to move to the island and enjoy life without taxes on capital gains, an enticing offer for those… – Continue reading

Puerto Rico Expands Tax Haven Deal For Americans To Its Own Emigrants

Puerto Rico’s Acts 20 & 22, tax incentive laws aimed at luring wealthy American investors to move there and at reviving the Island’s economy, are celebrating their third anniversary this month. While Puerto Rico’s economic situation remains bleak (it currently has more than $73 billion of “junk” status debt, unemployment… – Continue reading

IRS Sues Microsoft in Fight Over Records on Intangibles, Cost Sharing

Dec. 15— The Internal Revenue Service filed a petition in U.S. district court to enforce a summons against Microsoft Corp. to produce “books, records, papers and other data” related to the pricing of intangibles under two cost-sharing arrangements (United States v. Microsoft Corp., W.D. Wash., No. 2:14-mc-00117, petition filed 12/11/14)…. – Continue reading

Global tax war looming and US won’t be backing down

The United States won’t give up its right to tax multinationals, and nations will go to war soon with countries like China on taxing rights, a US tax head says. Grant Thornton’s national managing partner of tax in the United States, Randy Robason, is in Australia this week for a… – Continue reading

Microsoft to pay China $140 million for ‘tax evasion’

(Reuters) – China has levied about $140 million in back taxes from Microsoft Corp in the first major case concerning cross-border tax evasion in the country, as regulators ramp up pressure on U.S. corporations doing business there. According to an article published by China’s Xinhua official news agency on Sunday,… – Continue reading

Puerto Rico – Online reporting, payment of use tax by bonded importers reinstated and effective today

November 18:  A requirement for bonded importers to declare and pay use tax on goods imported into Puerto Rico has been reinstated and is effective today, November 18, 2014. These rules were reinstated by Administrative Determination No. 14-27 (November 6, 2014) as issued by the Puerto Rico Treasury Department. Background… – Continue reading

Europe calls out corporate tax schemes our politicians won’t

You’ll have to forgive Amazon for getting a little flustered when the British Parliament publicly blasted the company for “gaming the system” to dodge paying taxes. Amazon is an American company. They’re used to far more deferential treatment. Responding to how the company paid only $7 million in taxes despite… – Continue reading

Whopper? Microsoft Skirts Billions In Taxes, Google, HP & Apple Have It Their Way Too

With all the talk about inversions and America’s Burger King Going Canadian, it’s easy to ignore even more prevalent tax savings by numerous American companies. Take Microsoft, which admits in its 2014 SEC filing that it avoids $30 billion in U.S. taxes. The trick? Keep about triple that amount, $93… – Continue reading

Microsoft has nearly $93 billion in overseas cash, and it’s reduced its tax bill by almost $30 billion

Microsoft’s stash of cash stored overseas, not subject to US taxes, is growing. In its latest regulatory filing, the software giant said it has now stockpiled $92.9 billion offshore and that this money could have cost the company $29.6 billion in taxes, but didn’t. That compares to $76.4 billion from… – Continue reading

Puerto Rico Pours On Tax Incentives For Investors

Puerto Rico’s tax incentive acts are tailor-made for traders, investors, investment managers and financial institutions. Enacted in 2012, Puerto Rico’s Act 22 allows investors and traders with bona fide residence in Puerto Rico to exclude 100% of all short-term and long-term capital gains from the sale of personal property accrued… – Continue reading