Category: Intellectual Property

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

Since 2010, Burger King Has Reduced Its World Wide Tax Rate by 60%

American taxpayers are being robbed by yet another giant corporation that is deserting the USA after using the country’s advantages to build untold wealth. Burger King’s recent decision to pursue a corporate inversion to Canada is the culmination of years of maneuvering to dodge paying its fair share in corporate… – Continue reading

Federal Court hands down software tax decision

The Federal Court has handed down its decision in the case of Task Technology v Commissioner of Taxation in relation to the tax treatment of specific software payments. The case related to payments made by Task to CaseWare International Inc (CWI) for the right to market and distribute CWI software to end users… – Continue reading

‘Vaccine’ tax avoidance scheme loses in court

A cynical tax avoidance scheme which “abused the reliefs” offered for research into life-saving vaccines to claim back £77m, has been rejected at a second tribunal. HMRC said investors in the scheme used a Jersey registered limited partnership which claimed to be involved in creating and exploiting intellectual property from… – 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

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

How U.S. Corporations Skip Out on Their Tax Bill

Microsoft is avoiding paying billions in taxes—and it’s not the only one. a subsidiary of a foreign company, so the firm has not technically engaged in the so-called “inversion” scheme that President Obama and Democrats have lately been criticizing. However, according to a 2012 U.S. Senate investigation, the company has… – 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

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

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

Review of patent tax regimes in EU has Irish support

Ireland can adopt ‘wait-and-see’ approach on tax breaks, says Department of Finance Ireland supports the EU review of all patent box regimes – under which certain member states offer tax breaks for intellectual property – and has decided to take a “wait-and-see approach” on the issue until guidance is provided… – Continue reading

Billionaire Eugene Melnyk: I’m a ‘whistleblower’ on tax allegations against Valeant

MONTREAL • Eugene Melnyk, the billionaire owner of the Ottawa Senators and founder of drug maker Biovail Corp., is waging war against the company that now controls his one-time business. Mr. Melnyk alleges that Valeant Pharmaceuticals International Inc. is masquerading as a Canadian company to make use of this country’s… – Continue reading

How REIT Spinoffs Will Further Erode the Corporate Tax Base

While Congress has been obsessing about tax inversions, it turns out another—potentially more important–tax avoidance technique is getting increased attention from the business community: Spinning off tangible assets into Real Estate Investment Trusts (REITs). If these deals become widespread, they’d be another nail in the coffin of the corporate income… – Continue reading

The difference between a telecoms network and real estate? About $3.2 billion

Tax avoidance, the American way. Little Rock, Arkansas-based telco Windstream has caused a stir by announcing a novel scheme to reduce the amount of federal taxes it has to pay. It intends to spin off certain network assets into a publicly traded real estate investment trust (REIT). In so doing,… – Continue reading

Alter Domus Improves Client On-boarding with Adoption of Thomson Reuters FATCA Solution

lter Domus Improves Client On-boarding with Adoption of Thomson Reuters FATCA Solution Thomson Reuters FATCA solution helps Alter Domus clients comply with regulatory requirements and provides competitive advantage NEW YORK/LUXEMBOURG, July 21, 2014 – Thomson Reuters, the world’s leading source of intelligent information for businesses and professionals, today announced that… – Continue reading

Local brokers, save for a few brave souls, escape Uncle Sam’s tax-reporting embrace

InterAksyon.com means BUSINESS Majority of the local stock brokerages have remained outside the US-mandated reportorial compliance among foreign financial institutions, a worldwide campaign designed to flush out hidden overseas wealth and minimize tax abuse among Americans and green card holders through offshore accounts. A total of 178 Philippine-based financial firms,… – Continue reading

Global tax avoidance ‘is sending wrong message’

GLOBAL firms’ growing ability to avoid company tax by shifting their intellectual property to low-tax countries could undermine Australians’ respect for the tax system, causing greater leakage of revenue, a senior Treasury official warned yesterday. Rob Heferen, head of revenue at the federal Treasury, also said Australia’s massive reliance on… – Continue reading

Your Taxes: Going International

Going offshore means registering any intellectual property (IP) in an offshore company and delegating R&D and marketing to onshore companies. Money doesn’t grow on trees, and taking your business international is no picnic. On June 12, the International Business Structuring Association (IBSA) held a seminar to discuss ways of growing… – Continue reading

Tax Chauvinism: Who Cares Where a Firm is Incorporated?

Following the recent offer by U.S drugmaker Pfizer to acquire British pharmaceutical firm AstraZeneca, congressional Democrats are proposing new limits on the ability of U.S.-based firms to establish foreign residence and thus cut their U.S. corporate tax bill. Even before this latest flap, the Obama Administration proposed curbs on this… – Continue reading

SA startups catch a tax break as Reserve Bank allows for offshore IP transfer

The South African Reserve Bank (SARB) has relaxed regulations for private companies in the country, which now makes it possible to transfer intellectual property (IP) offshore, reports TechCentral. According to ENS Africa IP director Chris Bull, restrictions on intellectual property assets has been one of the key obstacles for local businesses… – Continue reading

Potato boss Paul Rennie ‘can’t recall’ overseas transactions, Federal Court hears

Potato king Paul Rennie has told a court he is unable to explain why he sent millions of dollars to tax havens in transactions revealed by a Project Wickenby investigation. The Federal Court heard Mr Rennie had been raided by federal police, who seized documents related to his Griffith-area potato… – Continue reading

HMRC Increases Amount of Tax Suspected to be Underpaid Through Transfer pricing

Adds £118m to ‘tax under consideration’ from intra-group transfers • HMRC proposes further crackdown on intra-group transfers in Budget HM Revenue & Customs has increased the amount of tax it estimates has been underpaid by the UK’s largest businesses through transfer pricing arrangements by £118 million to more than £1.1 billion, an… – Continue reading

Internet groups face global tax crackdown

A looming global crackdown on aggressive tax avoidance is set to stop internet companies slashing bills by routing profits to havens. Plans to “restore taxation” in the countries where digital companies make their sales and base their headquarters were set out on Monday in the first international response to the… – Continue reading

Companies’ Offshore Profits Keep Piling Up

U.S. corporations added at least $206 billion to their stockpiles of offshore profits last year, parking earnings in low-tax countries until Congress gives them a reason not to. They have accumulated $1.95 trillion outside the U.S., up 11.8 percent from a year earlier, according to securities filings from 307 corporations…. – Continue reading

Developing countries ‘lose taxes to profit shifting’

STUDIES show multinationals shift profits of $365bn a year from developing to developed countries through transfer pricing mechanisms, the South African Revenue Service (SARS) said on Tuesday. Over three years South Africa has seen “hundreds of billions of rand” leaving in royalties, management and service fees and intellectual property payments,… – Continue reading

U.S. companies add offshore profits to avoid taxes

The largest U.S.-based companies added $206 billion to their offshore profit stockpiles last year in order to put earnings in low-tax countries, Bloomberg reported. Multinational companies accumulated $1.95 trillion outside the U.S., which was up 11.8 percent from a year earlier, according to securities filings from 307 corporations reviewed by Bloomberg. Governments… – Continue reading

OECD urges quick action on multinational tax dodges

OECD tax director Pascal Saint-Amans has played down concerns that the United States might resist plans to make multinational companies such as Apple and Starbucks pay more tax, arguing that governments must move quickly to close multibillion-dollar loopholes or risk ordinary citizens ­losing faith in their taxation systems. Mr Saint-Amans… – Continue reading

Apple to IBM hoard $206b abroad to avoid US tax

The largest US-based companies added $206 billion to their stockpiles of offshore profits last year, parking earnings in low-tax countries until Congress gives them a reason not to. The multinational companies have accumulated $1.95 trillion outside the US, up 11.8 per cent from a year earlier, according to securities filings… – Continue reading

Forcing corporations to pay tax on Maine profits stashed offshore is simple way to enforce tax law

Small business owners can feel a little bit like ping-pong balls when elected officials start talking about taxes. I’m a board member of the Maine Small Business Coalition, to which 3,600 Maine small business owners belong. I’m also a registered nurse and owner of a home child care center where… – Continue reading