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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...

To achieve widely needed tax reform, governments must demonstrate the benefits that tax revenues make possible, according to IMF Managing Director Christine Lagarde and other panelists at the annual meeting of the IMF and World Bank Group in Washington...

by David A. Nickson, Andrew J. Hwang and Elizabeth A. Sweigart * As multinational enterprises continue to expand through acquisition and organic growth, the need for accurate and timely reporting of operational and financial data has never been more...

Today's [April 13, 2014] NYT has an article entitled " Buyers Find Tax Break on Art: Let it Hang Awhile in Oregon ." The artful dodge is accomplished via simple arbitrage between a source, an intermediary, and a residence jurisdiction, so...

by Jeffrey R. Simser and Robert G. Kroeker * Introduction ... The AML regime in any country is apt to be vexing and complex. Canada's is no exception.. Overview of AML Law in Canada Canada is a country of immense size, bordered by the...

In Sun Capital Partners III, LP v. New England Teamsters & Trucking Industry Pension Fund [724 F.3d 129 (1st Cir. 2013)], the First Circuit held that one of two private equity funds (the two funds were Sun Capital Fund III and Sun Capital Fund IV...

by Dale Bond, Elizabeth Sweigart and Alan Fischl * Conventionally, the structuring and pricing of transactions between US taxpayers and their related parties — or transfer pricing — has been considered the realm of large, multinational...

James P. Fuller has an interesting summary of the recently-filed Caterpillar case in his latest U.S. Tax Review [ gated ], in which he laments the competent authority breakdown and argues that the case would have been better off going to treaty-based...

On September 16, 2014, the Organisation for Economic Co-operation and Development (OECD) released its final guidance on transfer pricing documentation and country-by-country (CbC) reporting. Developed as a replacement for the existing Chapter V (Documentation...

by Mary Riley * It is a general maxim that taxpayers want to minimize their tax liability to the greatest extent possible. However, taxpayers who overzealously pursue this aim risk crossing the line separating permissible tax avoidance from impermissible...

By Prof. William H. Byrnes IV and Dr. Robert J. Munro * Editor's Note : The following is an excerpt from the e-book only title Money Laundering, Asset Forfeiture, and Recovery and Compliance - A Global Guide , by William Byrnes and Robert Munro...

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...

By Prof. William H. Byrnes IV and Dr. Robert J. Munro * ...The Joint Statement between the U.S., France, Germany, Italy, Spain and the United Kingdom regarding an intergovernmental approach to improving international tax compliance and implementing...

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 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...