Puerto Rico has amended its income tax rules to allow taxpayers to fully deduct intercompany expenses if taxpayers file a transfer pricing study with their income tax return, due April 15, 2020, if not extended. ... - Continue reading
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’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
The GOP’s consolidated tax bill, unveiled Friday, could be bad news for Puerto Rico. That’s because Puerto Rico is sometimes considered a foreign country for tax purposes. The designation means corporations doing business on the island could face a minimum 10 percent tax on profits abroad, as well as a… – Continue reading
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
A loophole may make it a good place for foreigners to keep cash. Some 65,000 Puerto Ricans left their bankrupt U.S. island commonwealth last year. A group of private bankers are moving the other way. They’re increasingly opening offshore banks known as International Financial Entities, which were created by a… – Continue reading
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
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
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
Ramos Vega asked to accept pay 2% of sales per year as a reasonable contribution Representative Luis Vega Ramos called Walmart today the company to desist from his claim against the Government of Puerto Rico by the tax increase purchases subsidiary on the island does to its parent company. The… – Continue reading
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
The multinational has to file a legal complaint against the Secretary of the Treasury by the changes in its tax structure resulted Law 72 The Walmart Puerto Rico, Inc. corporation filed today in federal court in San Juan a legal action against the Finance Minister Juan Zaragoza, which challenges Law… – Continue reading
Under the judge’s order, Microsoft must hand over more documents and make some former and current executives available for interviews in a long-running tax audit of the company’s books. Microsoft must comply with Internal Revenue Service requests for documents and interviews with current and former executives as part of a… – Continue reading
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
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
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
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
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
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
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
The original online payment platform, PayPal, has decided to leave the populous island of Puerto Rico next month. The commonwealth has imposed a 2 percent take on any money transmission, forcing Paypal’s hand. So what does this mean for those who need to send money from Puerto Rico? Puerto Rico… – Continue reading
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
Due to a little-noticed provision in the new highway appropriations bill signed into law on July 31 – the Surface Transportation and Veterans Health Care Choice Improvement Act of 2015 – the deadline for filing an FBAR (Report of Financial Bank and Financial Accounts) has been moved up from June… – Continue reading
On Monday, Puerto Rico defaulted on its debt for the first time in history, repaying only $628,000 of a $58 million portion of the total $73 billion it owes. The White House said on Tuesday that it had no plans to bailout the small island nation, which is an unincorporated… – Continue reading
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
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
Microsoft Corp. and the IRS are back in court, this time fighting about the U.S. tax agency’s interest in hiring David Boies, the lawyer who beat Microsoft in an antitrust case in 2000. The software company filed a federal lawsuit May 29 in Seattle, marking the latest legal flurry over… – 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
The Internal Revenue Service (IRS) has reminded American citizens and resident aliens, including those with dual citizenship, who have lived or worked abroad during all or part of 2014 that they may have a US tax liability and a filing requirement in 2015. The agency pointed out that a filing… – Continue reading
Puerto Rico’s governor has signed a law that requires service providers to accept at least two different types of payment in a push to crack down on tax evaders. The law applies to anyone requiring a license or legal authorization to provide services. It is common for doctors, lawyers and… – Continue reading
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
SAN JUAN, Puerto Rico – With recession biting into profits at their chain of burger restaurants and surf shops, two brothers responded in a way Puerto Rico authorities say is common: by shortchanging the government. Javier and Oscar Juelle failed to turn over $1.27 million in sales taxes they collected… – Continue reading
Microsoft and the Internal Revenue Service (IRS) have agreed to end their battle over documents used in transfer pricing audits of the tech company. On February 24, the Internal Revenue Service (IRS) and Microsoft reached an agreement which resulted in the dismissal of the Freedom of Information Act (FOIA) lawsuit… – Continue reading
Some of your well-to-do clients may be thinking of moving to the “51st state.” Puerto Rico is quickly becoming a tax haven for U.S. citizens fed up with paying higher taxes on the mainland. If you qualify, the tax rate on much of your investment income – including certain capital… – Continue reading
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
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’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
The tech industry is ramping up its lobbying efforts on tax reform, seeking to make sure it doesn’t end up the loser if Washington can finally find a consensus on rewriting U.S. tax laws. The Tax Innovation Equality Coalition, or TIE, a group that counts both technology and pharmaceutical titans… – Continue reading
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
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
(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
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
Alex Lemond is among a new wave of New Yorkers trading in their Manhattan condominiums for beachside villas in Puerto Rico. The former hedge fund honcho moved to San Juan from New York last year, and his company, the Encanto Group, is investing hundreds of millions of dollars in developing… – Continue reading
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
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’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
Back in 2012, the Puerto Rican government signed a law that created a nice tax haven of U.S. citizens. Tax attorney Rob Wood comments on the Puerto Rican option, which was also the subject of his Forbes article “Hate Taxes? Move To Tax-Free Puerto Rico, Stay American, Avoid IRS.” Wood… – Continue reading
A lot of Americans are moving out of the homeland, getting rid of their American citizenship and with it a whole lot of tax. The American system of Worldwide tax and FATCA levied on the citizens is one of the driving forces for this shift. The IRS collects taxes from… – Continue reading
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
