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    Article Summarizing the Swiss Bank Developments and Process

    I offer here a new article which I think readers might find quite helpful. Walter H. Boss and William M. Sharp, Sr., The Swiss-U.S. 'Turnover' Ground Rules: A Technical Update , 64 Tax Notes International 423 (11/7/2011), here . Key points which...

    Dismissing Weak Claims

    Sexual harassment week continues. Last post I addressed What is Sexual Harassment? The gist was that successful sexual harassment claims are harder to establish than some people think. Today's post comes at it from the other angle: getting rid of...

    The Flat Tax is a VAT . . . in 90 Seconds

    Republicans despise the value-added tax. But the flat tax they admire so much is nothing more than a value-added tax split into two parts. A value-added tax is a tax collected from business. The tax base is the difference between business receipts minus...

    Article in Continuing Negotiations with the Swiss Government / Banks

    Lynnley Browning has a new article on this continuing saga, Exclusive: Swiss offer U.S. tax deal for all Swiss banks (Reuters 10/3/11), here . The thrust of the article is that the Swiss want an all inclusive deal covering the 11 prominently mentioned...

    I Thought the ‘Dodgers’ Were a Baseball Team?

    There's a report that's getting a lot of attention this morning that concludes that many large U.S. corporations paid little or no corporate income taxes between 2008 and 2010 even though they raked in millions of dollars. The report, prepared...

    Down With Stadium Financing

    The Minnesota Vikings would like the people of Minnesota to pay for a new stadium. Specifically, the team wanted the legislature to okay a local option sales tax to finance the stadium. But the Minnesota legislature has said no (although most legislators...

    To Hell With Tax Reform -- For Now

    I hate to drag you away from your fascination with Herman Cain's 999 plan and Rick Perry's flat tax, but if we are going to make real progress, we can't fixate on every overhyped, half-baked tax slogan that comes along. Sooner or later we...

    TIGTA Report on IRS Offshore Accounts Initiative Administration

    TIGTA has a new report on the IRS's administration of the offshore account initiatives. The full report, titled The 2009 Offshore Voluntary Disclosure Initiative Increased Taxpayer Compliance, But Some Improvements are Needed (TIGTA Report 2011-30...

    Camp's 'Territorial' Proposal . . . In Three Paragraphs

    The proposal would eventually eliminate U.S. tax on foreign source income from active business. But the exemption would be limited to 95 percent of foreign profits. (The five percent "haircut" that the Japanese have but the British don't...

    Fair's Fair

    Who would have thought this year's World Series would turn out to be as good as it is? My Yankee fan wife announced the season was over within minutes of the Bronx Bombers' elimination. I, a Phillies fan, agreed wholeheartedly. "Wait 'til...

    Article on OVDI and Beyond

    Scott Michel and Mark Matthews have written a thought-provoking article on the status of the IRS offshore financial account. See Scott D. Michel, OVDI is Over -- What's Next for Voluntary Disclosures ?, 133 Tax Notes 369 (Oct. 17, 2011), here . (The...

    Life Without Stimulus

    Republicans constantly remind us that the Obama stimulus--the American Recovery and Reinvestment Act of 2009--did not work. They voted against it. In the United Kingdom the government is led by Conservative Prime Minister David Cameron. His government...

    The Foreign Fund’s FATCA Dilemma – A New White Paper

    I've been posting some of the FATCA white papers prepared by Navigant's FATCA task force on this blog. Continuing this practice, I just received the latest one from my colleague Rich Kando at Navigant's Disputes and Investigation Practice...

    Why Experts Really Don't Like 9-9-9

    Most mainstream public finance experts have been critical of Herman Cain's 9-9-9 plan. They have called the plan crazy and nuts and evil. I was shocked at the unanimity of the opposition. But I know why they hate it. First, Cain is a guy who sold...

    Is Class Warfare Justified?

    These data are from a recent edition of the prestigious Journal of Economic Literature . The first data column corresponds to what we hear on the news all the time: the growth of the overall economy. The information in the last three columns, however...

    Tax Breaks to Take Advantage of Now

    "Plan for what we know, not for what we think might happen" Mitchell A. Drossman, national director of wealth planning strategies at U.S. Trust, advised in a recent New Your Times piece " Take Advantage of Tax Breaks Now, Experts Say "...

    TIGTA Report on the State of IRS CI

    In August, TIGTA released its report titled Trends in Criminal Investigation's Enforcement Activities Showed Improvements for Fiscal Year 2010, With Gains in Most Performance Indicators (Ref: 2011-30-068 7/25/11), here . I have finally found time...

    Cain's 9-9-9 in 90 Seconds

    Cain gets rid of the entire current system-income, corporate, payroll, and estate taxes. In its place he would institute three new taxes. His "9% business flat tax" is simply a value-added tax dressed up to look like a corporate tax. His "9...

    That Shining Guillotine on the Hill

    Obviously lobbyists in Washington live in a bubble. I say that because if I were a lobbyist in Washington working for, say, Google or Pfizer I would be reminding my client about the French Revolution, rather than running around the Capitol frantically...

    SALT To Taste: Still Alive and Kickin': "Cost of Performance" Sourcing for Sales

    By Marshal T. Kline and Kellie A. Lanford Many states continue to follow the Uniform Division of Income for Tax Purposes Act ("UDITPA") provisions that establish a "cost of performance" sourcing rule for sales of non-tangible property...

    GAO Report On Exchange of Information Between U.S. and Its Treaty Partners

    GAO recently issued a report, titled IRS's Information Exchanges with Other Countries Could Be Improved through Better Performance Information (GAO-11-730 September 2011), here , describing the U.S. treaty system for sharing information between treaty...

    Carried Interest Proposal Blocked in the Senate Yet Again

    Recently I mentioned on this blog that the Carried Interest legislation is resurfacing again courtesy of Obama's efforts and the American Jobs Act of 2011. In my post I reasoned that, well, this time the effort may have some legs considering the economic...

    Are Capital Gains Double Taxed?

    The very rich get most of their income from capital gains. Republicans have tried to sidestep this fact, but you can see it for yourself in the chart below. So any discussion of efforts to increase progressivity -- such as President Obama's so-called...

    Herman Cain's 999 Plan: Stepping Stone to a VAT?

    GOP presidential candidate Herman Cain is promoting fundamental tax reform. Bravo! Somebody needs to do it. Like most ideas designed to appeal to Joe-the-Plumber types, Cain's proposal is charmingly simple yet fundamentally flawed. It's called...

    State Tax Alerts - This Week's Stories Worth a Second Look

    By Rusty Little In case you missed them, the following is a summary of a few key state tax developments, news articles, and observations during the past week: Groupon and Living Social are two popular Internet companies offering online discount vouchers...