News & Analysis as of

Tax Evasion Corporate Taxes

Whitcomb Selinsky, PC

What Is A Tax Inversion & Can It Save Your Company Money?

Whitcomb Selinsky, PC on

Apple, Inc. made headlines this year when it managed to avoid over $70 million in taxes that the U.S. said the company owed to the federal government. Estimates vary as to the amount of money Apple keeps offshore, but the...more

A&O Shearman

Global Tax Insights: Uncertain tax positions: preparing for further tax disclosure

A&O Shearman on

The UK government is pressing ahead with its proposal to require large businesses to notify their “uncertain tax positions” to HMRC. ...more

Katten Muchin Rosenman LLP

The UK Government and HMRC's Efforts to Clamp Down on Promoters of Tax Avoidance

Tax avoidance is the process of manipulating tax rules to reduce the amount of tax payable and obtaining a financial advantage that was never the intention of the legislation. A typical example of tax avoidance involves the...more

Holland & Knight LLP

Large Corporations and Wealthy Taxpayers Beware: The Taxman is Coming

Holland & Knight LLP on

Internal Revenue Service (IRS) Commissioner Chuck Rettig on April 13, 2021, told a U.S. Senate panel that the tax gap in the U.S. may total $1 trillion per year. In his view, the increase from prior estimates is due, in part,...more

Gerald Nowotny - Law Office of Gerald R....

Taxing Times - April 2021

Male Escort Gets 21 Months In Prison For Tax Case - He lied on his tax returns, resulting in a tax loss to the IRS of $278,325. A male escort who lied to the IRS about his income was sentenced to 21 months in prison and...more

Morgan Lewis

Sovereign Wealth Funds Update: Tax Aspects of Private Fund Investments: Selected US, EU, and UK Considerations in the Current...

Morgan Lewis on

Despite the market disruption caused by the COVID-19 pandemic, sovereign wealth funds continued to make significant capital commitments to private funds during 2020, on a global basis. As the world emerges from the pandemic,...more

Jones Day

Restoration of Crown Preference and Erosion of the English Floating Charge

Jones Day on

With effect from December 1, 2020, Her Majesty's Revenue and Customs ("HMRC") ranks ahead of floating charge holders and unsecured creditors with respect to recovering certain pre-insolvency taxes from an insolvent business...more

McDermott Will & Emery

Despite Appeals Win, Google Agrees To Eur 1B Settlement To Avoid Criminal Prosecution

McDermott Will & Emery on

The Paris Court of Appeal affirmed that Google Ireland does not have a French permanent establishment in a high-profile tax controversy over a double Irish arrangement. But with independent criminal proceedings for tax...more

Robins Kaplan LLP

Financial Daily Dose 11.01.2019 | Top Story: Watching for the GM-strike Impact on the October Jobs Report

Robins Kaplan LLP on

Jobs Report Friday again. Here’s what we’re watching, including the possibility of scary low numbers thanks to the only-recently-resolved GM strike....more

Rosenberg Martin Greenberg LLP

What are some of the monetary penalties and other consequences of failing to properly report my foreign real estate and other...

Depending upon how foreign real estate is owned and/or controlled, a number of different tax reporting regimes may be implicated.  Each of these has its own corresponding penalties and generally applies to United States...more

Hogan Lovells

HMRC introduces Profits Diversion Compliance Facility

Hogan Lovells on

HMRC has announced today the introduction of a new Profits Diversion Compliance Facility, which is aimed at tackling the avoidance of tax by multinationals by diverting profits outside the UK without proper economic...more

Cadwalader, Wickersham & Taft LLP

Autumn Budget 2017 Predictions

The Chancellor of the Exchequer's first Autumn Budget under the new budget timetable, which sees the Autumn Statement replaced with an Autumn Budget (and the Spring Budget replaced with a Spring Statement), will be announced...more

Proskauer Rose LLP

UK Tax Round Up - September 2017

Proskauer Rose LLP on

UK Tax News and Developments - Finance (No 2) Bill 2017 - The second Finance Bill of 2017, known as Finance (No 2) Bill 2017, has now been published. As expected, this contains most of the provisions which were dropped from...more

Foodman CPAs & Advisors

Cumplimiento Fiscal Internacional

Detectar, disuadir y responder al incumplimiento internacional son desafíos clave que enfrentan las autoridades tributarias de todo el mundo. El incumplimiento fiscal internacional es un problema significativo reconocido por...more

Proskauer Rose LLP

UK Tax Round Up - July 2017

Proskauer Rose LLP on

UK Tax News and Developments - Conservative legislative agenda set out in Queen's Speech - Following the UK general election on 8 June 2017, at which the Conservative party won the largest number of seats but lost its...more

Latham & Watkins LLP

Panama Papers prompt new UK tax evasion offences: top 10 concerns for professionals and corporates

Latham & Watkins LLP on

The fallout from the Panama Papers continued with the publication of a further consultation by the UK Government on its proposed corporate tax evasion offence. The offence will introduce criminal liability for organisations...more

Bilzin Sumberg

Proposed IRS and Treasury Regulations Have Broad Implications for Intercompany Debt Structures

Bilzin Sumberg on

On April 4, 2016, the U.S. Treasury Department and the Internal Revenue Service (“IRS”) issued proposed regulations ostensibly aimed at curbing inversions and earnings stripping, by companies located in the U.S. with overseas...more

Alston & Bird

International Tax Advisory: New Temporary Regulations Continue the Fight Against Inversions

Alston & Bird on

On April 4, the Treasury released temporary regulations to attack (and prevent) inversions. Aimed at transactions designed to avoid the purposes of Sections 7874 and 367 and certain post-inversion avoidance transactions, the...more

Lowndes

New Temporary Inversion Regulations

Lowndes on

The IRS once again is targeting inversions, and this time there have been immediate tangible results. The IRS issued temporary regulations on Monday targeting inversion transactions. An inversion occurs where a foreign...more

Cadwalader, Wickersham & Taft LLP

M&A Update: Broad Anti-Inversion Rules Released

On April 4, 2016, Treasury released new rules making it more difficult for some U.S. companies to invert (“Serial Inversion Regulations”), Proposed Regulations limiting the effectiveness of “earnings stripping” techniques...more

Polsinelli

Treasury Notice on Inversions Leaves Basic Inversion Transactions Intact

Polsinelli on

In This Issue: - Deferred Earnings and Profits of CFCs - Code Section 956(e) - Code Section 7701(l) - Code Section 304(b)(5)(B) - Code Section 7874 - Request for Comments -...more

Holland & Knight LLP

U.S. Treasury Tries to Clamp Down on Tax Inversions

Holland & Knight LLP on

Lately, the media has focused on tax inversions, most recently when Burger King announced that it will purchase Tim Hortons, a Canadian company, but what are they?...more

Katten Muchin Rosenman LLP

OECD Publishes Initial Recommendations on BEPS

On September 16, the Organisation of Economic Co-operation and Development (OECD) published a set of recommendations for a coordinated approach to fight tax avoidance by multinational enterprises under the Base Erosion and...more

Skadden, Arps, Slate, Meagher & Flom LLP

"International Taxation – OECD Reboot for the 21st Century"

Introduction - Following on its February 2013 report on Addressing Base Erosion and Profit Shifting (BEPS), the Organisation for Economic Co-operation and Development (OECD) has now released an ambitious action plan...more

Bradley Arant Boult Cummings LLP

Tennessee Department of Revenue Issues Last Call for Intangible Holding Company Voluntary Disclosure

The Tennessee Department of Revenue issued Notice 13-06 in June notifying taxpayers that its acceptance of voluntary disclosure of intangible expense deductions at a preferred settlement rate will be ending later this year....more

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