In November 2012, a startled TV audience watched coverage of the House of Commons Select Committee questioning Google’s chief executive about why his business, with ostensibly billions of pounds in sales generated in the UK, accounted for UK corporation tax in an amount equivalent to the price of a single… – Continue reading
In November 2012, a startled TV audience watched coverage of the House of Commons Select Committee questioning Google’s chief executive about why his business, with ostensibly billions of pounds in sales generated in the UK, accounted for UK corporation tax in an amount equivalent to the price of a single… – Continue reading
Each year U.S. multinational corporations avoid an astounding $90 billion in corporate income taxes by booking their profits on paper through international tax havens. At a time of growing inequality and budget austerity, it is outrageous that we allow the world’s richest companies to get away with not paying their… – Continue reading
Senate Finance Committee Chairman Orrin Hatch reiterated his view that the only solution to corporate tax inversions is United States tax reform, during remarks at a conference hosted by the Brookings Institution on January 23. Hatch has long been skeptical of short-term measures – legislative or non-legislative – to deter… – Continue reading
Democratic lawmakers Tuesday pushed legislation to stop U.S. companies from reincorporating overseas to reduce their tax bills, saying a wave of so-called inversions last year has nearly doubled the revenue the federal government will lose from those moves over the next decade. The bill would make it tougher for U.S…. – Continue reading
Outlook: The OECD’s work on corporate tax avoidance has proceeded at a faster rate than many expected According to Oxfam, on current trends the richest 1 per cent of the world’s population will have a greater share of its wealth than the remaining 99 per cent within two years. The… – Continue reading
(Bloomberg) -– So how did the previously obscure term tax inversions become part of Washington parlance, fodder for the next presidential campaign and the issue that helped derail a U.S. Treasury nominee? Thank, or blame, depending on your perspective, cutting-edge tax lawyers, populist Democrats, a banana seller, a drugmaker, a… – Continue reading
Shareholders typically don’t object to tax inversion deals Nathan points out that — with some exceptions — shareholders are rarely opposed to tax inversion deals.They, not unreasonably, want the firms they invest in to be as profitable as possible, so they typically feel that corporate structures designed to avoid taxes… – Continue reading
A pair of Democratic lawmakers in the House and Senate have re-introduced legislation aimed at preventing the abuse of offshore tax havens by multinational companies. Rep. Lloyd Doggett, D-Texas, a senior member of the tax-writing House Ways and Means Committee, and Sen. Sheldon Whitehouse, D-R.I., a member of the Senate… – Continue reading
SPECIAL REPORT: IS AMERICA LOSING IT’S CORPORATE SECTOR? Corporate inversions have been the dominant tax issue over the last year and have forced a serious evaluation of the U.S. corporate tax system. While there is widespread agreement that the U.S. corporate tax code is out of step with our global… – Continue reading
From Premier International Tax Library With the publication in September of Notice 2014-52, the IRS has made it extremely difficult for any foreign corporation that is not primarily engaged in an active business to acquire a U.S. business in exchange for its stock without risking being transformed into a U.S…. – Continue reading
The 4,029-page tax code is so complex both parties want to revise it. On business tax reform, they share surprising common ground, raising the potential for partial tax reform to be enacted this year. As the 114th Congress convenes this week, it has a golden opportunity to rid itself of… – Continue reading
Medtronic Inc. took one step closer to becoming an Irish company when shareholders voted in favor of acquiring Dublin-based medical supply maker Covidien Ltd. Covidien shareholders similarly voted on the deal early today and also approved it. The acquisition now goes before the Irish High Court, which may take several… – Continue reading
Critics said the deal would allow Medtronic avoid taxes while providing preferential treatment to executives. The promise of 1,000 new Minnesota jobs was not enough to convince the state’s pension board to support a $48 billion corporate transaction that will move Medtronic’s legal headquarters overseas. A four-member subcommittee of the… – Continue reading
Fiat Chrysler Automobiles publicly denied a media report saying it was thinking about moving the tax residence of its Ferrari luxury sports car division outside Italy. “These rumors have no grounds,” FCA said in a company statement. “There is no intention to move the tax residence of Ferrari SpA outside… – Continue reading
In August, President Barack Obama pledged to use the powers of his office to discourage the corporate tax-avoidance technique known as inversion, in which U.S. companies claim foreign tax addresses. Four months earlier, according to a previously unreported legal document, his Department of Homeland Security did just the opposite. It… – Continue reading
Burger King Chief Executive Officer Daniel Schwartz swears that the company’s plan to renounce its U.S. “citizenship” and become a Canadian corporation “is really not about taxes.” But a new report by my group, Americans for Tax Fairness, finds that it really is about taxes after all. The report reveals… – Continue reading
Five Senate Democrats urged the IRS to put harsher rules into place to stop the offshore tax deals known as inversions. The five Democrats said the recently finalized deal between Burger King and the Canadian doughnut chain Tim Hortons – perhaps the most prominent in the recent wave of cross-border… – Continue reading
There has been a recent surge in anti-tax inversion legislation discouraging companies attempting to shift corporate subsidiaries or headquarters to low-tax or tax-free countries. The issue was subjected to a great deal of publicity in April 2014 during the failed hostile takeover by Pfizer (NYSE:PFE) for AstraZeneca (NYSE:AZN) when Pfizer… – Continue reading
The FACT (Financial Accountability and Corporate Transparency) Coalition today submitted comments to the Treasury Department praising their previous actions to limit inversions while also calling for additional measures. The proposals come as a part of the open comment period for Notice 2014-52, Rules Regarding Inversions and Related Transactions, originally issued… – Continue reading
Something strange happened in 2014 — Americans became very interested in corporate tax policy. It started in the spring, when U.S.-based pharmaceutical giant Pfizer, which produces blockbuster drugs like Lipitor and Viagra, floated a possible merger with its British-based rival AstraZeneca. Normally a merger of that size would make a… – Continue reading
The surge in U.S. companies avoiding taxes by taking a foreign address has been condemned by President Barack Obama and stirred a policy debate in Congress. What’s often overlooked is that these “inversions” are typically a final step in a hopscotch of multinational tax dodging. Many companies invert after years… – Continue reading
Rome (dpa) – The head of Italy‘s tax office, Rossella Orlandi, on Monday criticized automaker Fiat‘s decision to move its tax residence to Britain after completing a merger with US peer Chrysler. “I would … like to stress that we need some sense of national pride. In Germany tax rates… – Continue reading
MONTREAL – The problem is not that Bombardier Inc. played a complex shell game since at least 2010 by refinancing and redirecting US$500 million of its financing activities to Luxembourg, a notorious tax haven. It’s that it does so legally — and is hurting its home country despite being one… – Continue reading
Findings from Americans for Tax Fairness directly contradict Burger King’s earlier insistence that the merger would create ‘no tax benefit’ Burger King acquires Tim Hortons and calls Obama’s bluff on tax Burger King stands to avoid paying hundreds of millions of dollars in US taxes if it completes its pending… – Continue reading
Jeb Bush, a front-runner to become the Republican Party’s next presidential nominee, has used Britain to set up a private equity fund that could possibly allow it to avoid paying tax in America. The potentially damaging revelation was uncovered by the financial news wire Bloomberg and could pose a serious… – Continue reading
Four years after entering a punishing €67bn bailout, the Irish economy is booming again. Gross domestic product expanded at an annual rate of 5.5 per cent between January and June. The European Commission expects Ireland to be the fastest-growing country in the eurozone in 2014. Yet a chorus of economists… – Continue reading
The Joint Committee on Taxation has increased, from USD19.5bn to more than USD33.5bn, its estimate of tax revenue that could be saved over a ten-year period from legislation to restrict corporate inversions introduced by Democrat lawmakers in the United States House of Representatives in May this year. A recent letter… – Continue reading
While the dust is still settling from the mid-term elections and the pundits are trying to figure out what it all means, the American people have made their collective voices heard and delivered a message that they do not like the country’s direction. Exit polling data from Election Day showed… – Continue reading
Legislation seeking to stop U.S. corporations from moving their legal address abroad to avoid paying U.S. tax rates would raise significantly more revenue than originally thought, according to the official congressional scorekeeper. The Joint Committee on Taxation now says that Democratic legislation to curb inversions would raise $33.6 billion over… – Continue reading
The medical device manufacturer Medtronic has launched a USD17bn bond to finance part of its USD43bn corporate inversion acquisition of Ireland-based Covidien, in replacement of the cash held by its foreign subsidiaries that it was prevented from using following the United States Department of Treasury’s announcement of anti-inversion measures in… – Continue reading
Pascal Soriot has said that controversial inversion tax deals, branded ‘unpatriotic’ by President Obama, are still taking place despite attempts to curb the practice AstraZeneca’s chief has said inversion deals used by US companies to escape high taxes at home are not over despite a major clampdown on the practice…. – Continue reading
Hal Hicks cleared his throat and addressed a roomful of peers in a midtown Manhattan auditorium. The topic: the tax-avoidance technique called inversion, in which a U.S. company claims a foreign legal address. Waving his hands back and forth as if tracing a pendulum’s swing, Hicks explained how four government… – Continue reading
Despite the Obama administration’s ongoing efforts to crackdown on American companies moving overseas to avoid U.S. taxes, the Treasury Department is still awarding millions of dollars in federal contracts to these companies. Tyco International for example, moved their firm from the U.S. to Bermuda in 1997 and currently operates out… – Continue reading
WASHINGTON–U. S. authorities on Wednesday approved Medtronic Inc.’s$43 billion merger with fellow medical device maker Covidien PLC after requiring the spinoff of a drug-coated catheter business. The Federal Trade Commission required Minneapolis-based Medtronic to sell off Ireland-based Covidien’s catheter business before completing the acquisition. That $30 million sale, to Colorado-based… – Continue reading
A deal between Stryker Corp. (SYK) and Smith & Nephew Plc (SN/) makes as much sense now as it did six months ago. It just might be tougher to pull off. Stryker is considering structuring the takeover as a tax inversion, allowing the Kalamazoo, Michigan-based company to move its legal… – Continue reading
Companies based in the United States now have over $2.1 trillion stashed overseas shielded from U.S. taxes. That’s a sixfold increase in 12 years, NBC News reported citing research provided by Capital Economics. Generally, the U.S. tax policy allows companies based in the country to defer any tax obligation on… – Continue reading
Companies can be more competitive in the U.S. if they’re based outside the country, said the chief executive officer of a company that is moving its tax address outside the U.S. Heather Bresch, the CEO of Mylan Inc., described her company’s proposed tax inversion as a shield against a takeover… – Continue reading
NEW YORK — Shifting the address of his Liberty Global Inc. from Colorado to London last year didn’t just put billionaire John C. Malone in a position to reduce his company’s tax bill. He also took precautions to avoid the capital-gains hit that the so-called inversion would trigger for him… – Continue reading
Property purchases in Ireland help Liberty Global chairman John Malone avoid tax Billionaire Irish American businessman John Malone, who owns a number of prestigous properties in Ireland, didn’t just reduce his company’s tax bill when he shifted the address of UPC parent Liberty Global from Colarado to London last year…. – Continue reading
New York • Shifting the address of his Liberty Global Inc. from Colorado to London last year didn’t just put billionaire John C. Malone in a position to reduce his company’s tax bill. He also took precautions to avoid the capital-gains hit that the so-called inversion would trigger for him… – Continue reading
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Foreign profits sit on sidelines as companies seek tax reform. WASHINGTON — They are all companies that call Minnesota home: Medtronic, 3M, St. Jude Medical, General Mills and Ecolab. But they also all hold 90 percent or more of their cash outside the United States. Amid a growing national political… – Continue reading
Medical device companies Wright Medical Group Inc. and Tornier NV have agreed to merge in an all stock USD3.3bn transaction that will involve the transfer of Wright’s tax domicile from the US to the Netherlands. Wright’s deal with Tornier is one of the few corporate tax inversions that have been… – Continue reading
U.S. tax law creates perverse incentives for American companies to hold cash offshore, and the U.S. Treasury recently announced proposals to deter the practice. The proposals have triggered an outcry that ranges from criticisms that the Obama administration has overstepped its authority, on one side, to criticisms that the proposals… – Continue reading
New U.S. tax rules applicable to Covidien acquisition make deal less attractive, Moody’s said. Two Wall Street rating firms expect to downgrade Medtronic Inc.’s debt because the company will have to borrow $13.5 billion more than it expected to buy health care supplier Covidien and move the combined company to… – Continue reading
US banana producer and distributor Chiquita has decided to terminate its proposed inversion with its rival Fyffes, in a deal which would have involved moving its tax residence to Ireland, and will instead be acquired. Chiquita’s decision comes after the announcement of non-legislative measures by the US Treasury Department on… – Continue reading
Canada’s Competition Bureau says that Burger King’s plan to buy Tim Hortons does not pose a competitive threat to the fast food industry. The antitrust watchdog issued a No Action Letter (NAL) Tuesday, confirming that it reviewed the proposed transaction and concluded that it will not, at this time, “challenge… – Continue reading
Wright Medical Group Inc. (WMGI), a U.S. maker of bone implants, will merge with Tornier NV, creating a new company valued at $3.3 billion in the latest proposed tax inversion since tighter rules were announced last month. The legal address for the new company, to be called Wright Medical Group… – Continue reading
(Bloomberg) — The U.S. attempt to stop companies from leaving the country for tax reasons won’t stop Pfizer Inc., which is still considering a deal to move America’s biggest drugmaker abroad, said Chief Executive Officer Ian Read. “I see no reason why we wouldn’t be able to do an inversion,”… – Continue reading
