Category: Tax Planning

Developing Countries Losing Billions To Corporate Tax Avoidance

BANGKOK, Sept 10 (Bernama) — Developing countries may be losing over US$160 billion annually due to corporate tax avoidance – money that could fund greater policy ambitions to get the global economy out of the doldrums and moving towards a more inclusive and sustainable future. Greater policy ambition in both… – Continue reading

Doubts mount about Valeant Pharmaceuticals’ tax structures

MONTREAL – The disclosure by Valeant Pharmaceuticals International Inc. that it is under audit by the U.S. Internal Revenue Service is raising further doubts among tax specialists about the future of the Quebec-based drug company’s tax strategies. Valeant estimates it has achieved US$2.5-billion in tax and other “corporate structure” savings… – Continue reading

Biggest tax inverters ‘have $21bn offshore’

High quality global journalism requires investment. Please share this article with others using the link below, do not cut & paste the article. See our Ts&Cs and Copyright Policy for more detail. C Three US companies seeking to use controversial takeovers to cut their US tax bills hold at least… – Continue reading

Shifting sands: push for government to crack down on corporate profits

Antony Ting describes it as “like finding treasure”. It was 18 months ago when the powerful US congressional committee blew the lid on Apple’s aggressive corporate tax structure, which allowed it to funnel $US44 billion dollars out of the countrythrough a network of tax haven subsidiaries. Dr Ting, a senior… – Continue reading

PA accord between India and Switzerland to usher in new era of tax cooperation between the nations

(India and Switzerland are…) NEW DELHI: India and Switzerland are finding it difficult to break a deadlock over sharing information on secret bank accounts held in the European nation but both sides are close to finalising the first accord on a bilateral advance pricing agreement that will allow taxpayers to… – Continue reading

CBDT drops Rs 15-cr cap for transfer pricing scrutiny

Audits may now be based on risk of tax evasion The government has dropped the Rs 15-crore threshold for referring transactions between a multinational company and its Indian subsidiary for compulsory scrutiny by the tax department. It might, instead, move towards a risk-based approach to identify international transactions prone to… – Continue reading

Inversions: a Symptom of the Tax Code’s Disease

Stopgap efforts to prevent corporate tax inversions won’t fix the underlying problems With Congress about to return for a final push before the midterm elections in November, one topic on everyone’s lips is so-called corporate inversions. The practice, where a large U.S. company buys a smaller foreign company in order… – Continue reading

Hockey calls on Tax Office to target ‘Australia Tax’

To ensure location-based profits stay on shore. Treasurer Joe Hockey has promised to direct the Tax Office to target multinational businesses who charge Australians more for technology and ship the profits offshore to avoid tax. In a pre-G20 speech this morning, Hockey outlined the ways the Government plans to tighten… – Continue reading

Can A Business Enterprise Ignore Transfer Pricing?

TRANSFER pricing occurs whenever there is a transaction between two business enterprises which are part of the same group of companies or are controlled by a common person. In simple terms we refer to such parties as related parties. The business enterprises can include companies, limited liability partnerships, partnerships, branches,… – Continue reading

Crackdown on Tax Treaty Abuses

Tax authorities throughout the world are cracking down on taxpayers – individuals and corporations – that utilize some aggressive tax planning strategies. While most of these schemes are perfectly legal and merely take advantage of loopholes in theinternational tax system, there is a growing concern that they not only threaten… – Continue reading

The Real Tax Benefits of Inverting to Canada

On August 26, Burger King announced that it entered into an agreement to acquire Tim Hortons, Inc., the Canadian coffee-and-doughnut chain, in a transaction that will be structured as an “inversion” (i.e., Burger King will become a subsidiary of a Canadian parent corporation).  The deal is expected to close in 2014… – Continue reading

Senate Hopeful Defends Role in Irish Firm’s Merger

Years before Burger King sized up a Canadian headquarters in a hunt for lower taxes, Republican U.S. Senate candidate Mike McFadden’s investment firm was involved in a merger that moved an American pharmaceutical company to Ireland and significantly dropped its tax rate. McFadden’s Minnesota-based firm made more than $11 million,… – Continue reading

China’s SAT Investigates Transfer Pricing

In its ongoing efforts to control tax evasion, China’s State Administration of Taxation (SAT) has recently published an instruction (Tax Office General Fa [2014] No 146), calling on national and local tax bureaus to investigate transfer pricing practices of Chinese enterprises. Under scrutiny by the SAT are all transactions involving… – Continue reading

The Biggest Tax Scam Ever

I n July, the American pharmaceutical giant AbbVie, maker of the world’s top-selling drug – the arthritis treatment Humira – reached a blockbuster deal to acquire European rival Shire, best known for the attention-deficit medication Adderall. The merger was cheered by Wall Street, not for what the deal will do… – Continue reading

Broken levy: How U.S. tax law encourages inversions

An innocuously named species of transaction has inspired a political furor this summer. After a number of U.S. companies announced plans to move overseas in so-called inversion deals, Sen. Carl Levin proposed banning them outright. President Barack Obama called the companies unpatriotic. Because of the controversy, Walgreen Co. backed away… – Continue reading

Powerful GOP leaders linked to tax-avoidance

WASHINGTON — Two top Republican lawmakers profited from a corporate tax-avoidance maneuver that the Treasury Department is seeking to curb. While House Speaker John Boehner, Ohio, and Ways and Means Committee Chairman Dave Camp, Mich., have resisted calls for a crackdown on companies adopting overseas addresses to pay lower taxes,… – Continue reading

Burger King-Tim Hortons: Is Canada becoming a corporate tax haven?

Potential inversion deal highlights dropping corporate taxes in Canada, now the lowest among 10 countries, with the U.S. in 5th place. Fast-food giant Burger King faced anger from both Washington and average Americans Monday, a day after it announced that it was in talks to buy Tim Hortons and relocate… – Continue reading

U.S. businesses moving overseas to dodge taxes

NEW YORK — There’s more than one way for a U.S. company to avoid taxes by claiming a foreign address. Consider the business founded in 1916 as General Plate Co., a maker of sensors and controls for everything from Fords and Frigidaires to the spaceship that first carried Americans to… – Continue reading

The Global Crackdown on Profit Shifting

CFOs of multinationals need to prepare by assessing how much their companies engage in profit shifting to cut their taxes. Do you have responsibility, whether direct or dotted line, for the tax function in your company? Does your company have, or plan to have, operations outside the United States? If… – Continue reading

Bosses flee Vietnam, ignoring debts and taxes

VietNamNet Bridge – The bad news about tax evasion and debt repudiation cases by foreign invested companies has darkened Vietnam’s foreign direct investment (FDI) landscape. Tuoi Tre newspaper has reported that Austrian Harald Biebl, director of the HCM City-based Bach Hop Company, operational in Vietnam since 2005, has fled the… – Continue reading

Microsoft Admits Keeping $92 Billion Offshore to Avoid Paying $29 Billion in U.S. Taxes

Microsoft Corp. is currently sitting on almost $29.6 billion it would owe in U.S. taxes if it repatriated the $92.9 billion of earnings it is keeping offshore, according to disclosures in the company’s most recent annual filings with the Securities and Exchange Commission. The amount of money that Microsoft is… – Continue reading

New UK measures to counter avoidance schemes involving transfer of corporate profits

A new section 1305A of the UK Corporation Tax Act 2009 (CTA 2009) has been introduced by the UK Finance Act 2014 that applies to payments made from March 19, 2014 under avoidance schemes involving the transfer of corporate profits within a group. This new measure applies if: two companies… – Continue reading

US has long tried to block tax inversions – with success

US has long tried to block tax inversions – with success – See more at: http://www.independent.ie/business/world/us-has-long-tried-to-block-tax-inversions-with-success-30520958.html#sthash.cT9EIpv4.dpuf US authorities have grappled for more than 30 years with corporate deals known as inversions by which American companies shift their tax 
domiciles abroad to avoid US taxes. Fifty-two substantial deals like this have occurred… – Continue reading

Corporate foreign tax moves have bedeviled U.S. for decades

(Reuters) – The U.S. government has grappled for more than 30 years with corporate deals known as inversions in which U.S. companies shift their tax domiciles abroad to avoid U.S. taxes. Fifty-two substantial deals like this have occurred since 1983, about half of them since the 2008-2009 credit crisis, according… – Continue reading

Global Tax Topical Focus – Corporate Inversions FAQ

To some, US companies switching their tax residency to gain a tax advantage are economic “traitors.” To others, they are victims of a United States tax code that effectively punishes them for investing at home and encourages them to look for opportunities overseas. In this Tax-News Topical Focus, we try… – Continue reading

Investors Should Be Aware Of Cameco’s Dispute With The Taxman

The Canada Revenue Agency is speeding up the frequency of reassessments of Cameco’s tax returns in what may be an attempt to pressure Cameco to settle out of court. Cameco’s cash is being tied up as they are required to remit 50% of each disputed bill. Cameco could ultimately be… – Continue reading

Obama in a stew over corporate tax inversions

Barack Obama, presiding over an unusually dismal post-recession economy, might make matters worse with a distracting crusade against the minor and sensible business practice called “inversion.” Obama gave a 2013 speech regretting that Maytag workers in Illinois lost their jobs when the plant moved to Mexico but rejoicing that more… – Continue reading

American corporations using tax inversion lack patriotism: Letter

Letter-writer Hank Brennan correctly states that tax inversion is a tax avoidance, rather than evasion (“Inversion not a crime,” Reader Forum, Aug. 11). However, like boards of directors off-shoring American corporations as they earlier off-shored American jobs, he is looking at only one stakeholder: stockholders. There are three other stakeholders… – Continue reading