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Will Developed Countries Learn to Tax?

In 1963, Nicholas Kaldor published a paper in Foreign Affairs about the ongoing fiscal problems of poor countries, entitled " Will Underdeveloped Countries Learn to Tax? " It turns out Kaldor should have aimed this advice at his own country, as the rich world, confident in its fiscal advice...

Tax Considerations for Taxpayers Applying the Economic Substance Doctrine

The Background In 2010, Congress codified the economic substance doctrine, but left numerous unanswered questions for taxpayers on how to apply the doctrine. Along with codifying the economic substance doctrine, Congress also enacted strict liability penalties [ IRC § 6662(b)(6) (20 percent strict...

Corporate Tax Transparency

The activist-led movement to increase multinational tax disclosure is proving to be a full-employment program for natural resource industry lobbyists. The money and energy available for fighting against transparency seems limitless. We have seen the effects of this in the US, where Dodd-Frank's section...

Repatriation Tax Holidays and IRC Section 965

By Mary Riley * The debate over corporate tax reform has largely centered on lowering the corporate tax rate and, more radically, transitioning from a worldwide to a territorial system of international taxation. [Donald J. Marples and Jane G. Gravelle, CONG. RESEARCH SERVE, R40178, TAX CUTS ON REPATRIATION...

Taxing Financial Pollution

European finance ministers ("finance minister" is equivalent to our Treasury Secretary) voted on January 22 to move forward with a plan to tax trades of stock, bonds, and other financial instruments. As a result a financial transactions tax will likely become law in eleven countries--including...

Taxing Financial Pollution

European finance ministers ("finance minister" is equivalent to our Treasury Secretary) voted on January 22 to move forward with a plan to tax trades of stock, bonds, and other financial instruments. As a result a financial transactions tax will likely become law in eleven countries--including...

Managing the Competent Authority Process for U.S.-Based Multinational Enterprises

by Barry Shott, Richard Barrett and Elizabeth Sweigart * Under pressure to close revenue gaps and to address perceived aggressive tax positions related to the pricing of cross-border transactions, both the U.S. and foreign tax authorities are imposing very large tax adjustments upon multinational enterprises...

A Moral Obligation to Aggressively Lobby

In the United Kingdom a great debate is taking place about aggressive tax avoidance. On one side, David Cameron, the Conservative prime minister, says it is immoral . On the other side, most executives say they have a duty to their shareholders, and most practitioners say they have a duty to their clients...

'Legal Enemies of the State'!

How does that old Wall Street saying go? Bulls make money; Bears make money; Pigs get slaughtered. Bulls in this context are easily defined, and so are Bears. Money can be measured. But it seems to me that piggy behavior is in the eyes of the beholder. In Tax Notes this week I wrote about abusive transfer...

How Should the U.S. Stop Profit Shifting

... In the current debate about international tax reform... [t]here are several proposals now being floated (including one in the President's budget ( Treasury "General Explanation" of FY 2013 Budget, p. 88 ) and Options A and C of Ways and Means Committee Chair Dave Camp's Discussion...

How Important Is Deferral to Multinationals?

by Jeremy Scott The U.S. tax system allows multinationals to effectively indefinitely defer taxes on profits earned by active foreign affiliates until that money is repatriated to the United States. Deferral as a cornerstone of tax policy dates from a compromise during the Kennedy administration and...

SCOTUS OKs U.K. Windfall Tax for Credit: The PPL Case

The PPL decision was released yesterday [May 20, 2013] and taxprof posted initial thoughts from Reuven Avi Yonah and myself. I'm not convinced as Prof. Avi-Yonah is that the decision is correct, but I am interested in a few of the interpretive advances presented in the case. My comments: The Supreme...

View all the federal, state and international tax news headlines for October 10th from TaxAnalysts® on LexisNexis Tax Center

View all the federal tax news headlines for October 10th from TaxAnalysts® on LexisNexis Tax Center View all the state tax news headlines for October 10th from TaxAnalysts® on LexisNexis Tax Center View all the international tax news headlines for October 10th from TaxAnalysts® on LexisNexis...

Strengthening Procedures Against Tax Evasion

by Henry Christensen III * The events involving Union Bank of Switzerland ("UBS") have resulted in federal criminal prosecutions, a deferred prosecution agreement between the U.S. Department of Justice and UBS and a separate global settlement between the U.S. Department of Justice, the Swiss...

FATCA Compliance Programs

By Prof. William H. Byrnes and Dr. Robert J. Munro * Editor's Note: The following is an excerpt from Chapter 2 of the 2014 edition of LexisNexis Guide to LexisNexis® Guide to FATCA Compliance by William Byrnes and Robert Munro, published February 2014. Chapter 2 contributors: Jeffrey Locke...

View all the federal, state and international tax news headlines for April 3rd from TaxAnalysts® on LexisNexis Tax Center

View all the federal tax news headlines for April 3rd from TaxAnalysts® on LexisNexis Tax Center View all the state tax news headlines for April 3rd from TaxAnalysts® on LexisNexis Tax Center View all the international tax news headlines for April 3rd from TaxAnalysts® on LexisNexis...

NYU Summer Institute in Taxation

Dates: July 14-25, 2014 Location: The Westin New York at Times Square New York, NY Join today's leading national and international tax authorities during a series of in-depth sessions on state and local taxation, partnerships, consolidated returns, trusts and estates, federal wealth tax, and...

View all the federal, state, and international tax news headlines for October 8th from TaxAnalysts® on LexisNexis Tax Center

View all the federal tax news headlines for October 8th from TaxAnalysts® on LexisNexis Tax Center View all the state tax news headlines for October 8th from TaxAnalysts® on LexisNexis Tax Center View all the international tax news headlines for October 8th from TaxAnalysts® on LexisNexis...

EU to Investigate Amazon Tax Ruling for State Aid Breach

The European Commission on October 7 formally launched an investigation into whether Amazon's Luxembourg subsidiary received a favorable transfer-pricing-related tax ruling that violates EU state aid rules. According to a commission release, the investigation focuses on a tax ruling granted by the...

Filing Compliance Procedures Challenge U.S. Taxpayers Residing Overseas

Generally, [the 2012 Offshore Voluntary Disclosure Program] OVDP is designed for those delinquent U.S. taxpayers who have been holding financial assets overseas, have not been disclosing such assets to the U.S. government, have not been reporting the income produced from such assets, and...