Business Better Podcast Episode: Tax Audits, Investigations, and Global Enforcement - A Conversation with IRS Special Agent Jonathan Schnatz
UK corporate offence of failure to prevent tax evasion
The Panama Papers - What the Fallout Means for U.S. Companies and Professionals
Foreign Bank Account Reporting and Employment Tax Enforcement: Ronn Owens interviews Steve Moskowitz
The Panama Papers & The Tempo of International Corruption Cases
Lauryn Hill's Tax Evasion a 'Battle for Survival': Lawyer
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
The UK government is pressing ahead with its proposal to require large businesses to notify their “uncertain tax positions” to HMRC. ...more
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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