Tuesday, June 07, 2016

Taxing Matters: Cleft and Other Matters ...

 He recalled doing the same thing when he was a boy, going over a phrase, a sentence, a paragraph in a book, reading the words over and over again, trying to prise them apart long enough to see into the secret cleft they had just described.  But he never could.  The words closed over as quickly as a woman turning on her bed.
~ The Snow Kimono

 A massive new study links being a workaholic to a myriad of other psychiatric disorders Quartz  Correlation is not causation. They point out that the ADHD might lead to overwork to compensate. And in no case did a majority of workaholics exhibit the “psychiatric disorder”.

This OECD report explores how technology can help address issues of compliance and service delivery

 The Great British role in facilitating global corruption - Lord Collins  

 Devastating report reveals a bribery and fraud crimewave sweeping Britain that is costing City £127bn a year

A new poll conducted in the wake of the international Panama Papers scandal found that an overwhelming majority of Canadians agree that if any Canadian politician were linked to tax evasion they should resign from their position immediately.
The poll of 25 countries around the world, conducted by Ipsos Global, found 87 per cent of Canadians agree that is a politician were proven to have done what is alleged in the Panama Papers they should resign.
Panama Papers: Canadians say there are two sets of rules – one for the rich, one for everyone else

 he once had to hide his wealth onshore

Joshua Blank (NYU) presents The Timing of Tax Transparency, 90 S. Cal. L. Rev. ___ (2017), at the Stockholm Centre for Commercial Law at Stockholm University in Sweden today at an event hosted by Teresa Simon-Almendal, Peter Melz and Roger Persson-Osterman (all of Stockholm University):
Fairness in the administration of the tax law is the subject of intense debate in the United States. As recent headlines reveal, the Internal Revenue Service has been accused of failing to enforce the tax law equitably in its review of tax-exempt status applications by political organizations, the international tax structures of multinational corporations, and the estate tax returns of millionaires, among other areas. Many have argued that greater “tax transparency” would better empower the public to hold the IRS accountable and the IRS to defend itself against accusations of malfeasance. Mandatory public disclosure of taxpayers’ tax return information is often proposed as a way to achieve greater tax transparency. Yet, in addition to concerns regarding exposure of personal and proprietary information, broad public disclosure measures pose potential threats to the taxing authority’s ability to enforce the tax law.

Megan Brackney (Kostelanetz & Fink, New York), Filing Amended and Current Returns in Cases of Past Noncompliance: How Not to Make Matters Worse

Forbes just cut its estimate of Theranos CEO Elizabeth Holmes’s net worth from $4.5 billion to zero Quartz - Her expected net worth is therefore negative, since she is going to face a lot of litigation…

Lucas de Lima Carvalho, The Brazilian Tax Immunity for Music

Alan Cole, The Puzzling Policy of Foreign Tax Credits (Tax Policy Blog). “The essential question for U.S. policymakers is this: is it in the U.S.’s best interests to have the U.S. Treasury treat U.S. revenues and Australian revenues as equal priorities?”

Politico:  The Man Who Could Dash the GOP's Tax Dreams: An Economist for a Little-Known Congressional Office Is Getting Pulled Into the Partisan Fight Over Dynamic Scoring. Things Could Get Ugly., by Brian Faler:
The chairmen of the House and Senate tax-writing committees are preparing what they say will be major tax-reform proposals, and both are looking to an obscure congressional agency to make the numbers work

 Imagine an Economy Without Wall Street Wall Street Journal (Adrien F). Ready your barf bag…

Wealthy Americans Don’t Have to Go to Panama to Hide Their Wealth Foreign Policy in Focus  As we said, thanks to Richard Smith’s knowledge of the terrain, when the story broke.

       Netherlands Is the Tax Haven of Choice for Global Arms Dealers  

The Peter Thiel/Hulk Hogan story has brought the topic of litigation finance into the news, and a recent Alison Frankel column notes an alleged secret $10 million investment in the BP gulf spill case that might possibly have served as overstimulus: “Most of 40,000 seafood workers …turned out to be phantom clients…one, famously, was actually a dog.” [Reuters]

Luzius Cavelti (Altenburger legal + tax) & Christian Jaag (St. Gallen), Why Corporate Taxation Means Source Taxation: A Response to the OECD's Actions Against Base Erosion and Profit Shifting

Following up on last week's postDaniel Hemel (Chicago), Taxation as Compensation (reviewing   Kenneth F. Scheve (Stanford) & David Stasavage (NYU), Taxing the Rich: A History of Fiscal Fairness in the United States and Europe (Princeton University Press, 2016)): According to Scheve and Stasavage . . . , “the story of taxing the rich has more to do with politics” than with fiscal constraints . . . . For Scheve and Stasavage, “politics” specifically means rhetoric: their answer to the “why” question focuses on the types of tax fairness arguments that advocates for redistribution have employed. Scheve and Stasavage direct their attention (and ours) to three particular tax fairness claims. The first is what they call the “equal treatment” argument: “the fairest system involves equal treatment for all”

L.A. County Is Proposing To Tax Millionaires In Order To End Homelessness LAist (Qyrs). Someone needs to send the memo to San Francisco and New York City.
Leandra Lederman (Indiana-Bloomnington) presented Does Enforcement Crowd Out Voluntary Tax Compliance? attOxford University's Saïd Business School and Vienna University of Economics and BusinessGovernments commonly use deterrence methods, such as audits and the imposition of penalties, to foster compliance with tax laws. Although this approach is consistent with economic modeling of tax compliance, some scholars caution that deterrence may backfire, “crowding out” intrinsic motivations to pay taxes and thus reducing compliance. This article analyzes the evidence to date to determine the extent of such an effect. Field studies suggest that deterrence tools, such as audits, generally are highly effective at increasing tax collections but that crowding out may occur in some contexts, with respect to certain subgroups of taxpayers

ATO: Tax office turns off e-tax and replaces it with free, faster system

The New York Times recently published its coverage of the Equilar 200 Highest-Paid CEO Rankings, an analysis of the top paid CEOs at public U.S. companies with at least $1 billion in fiscal year-end market cap. 200 Highest-Paid CEO Rankings

Jim Maule, Heading Out the Door But Coming Right Back In. “It’s official. Today is the first day, since January 2, 1981, that I am not a full-time member of a law school faculty.” Congratulations, Professor (Emeritus)!

Timothy Taylor, US Corporate Stock: The Transition in Who Owns It. “The tradeoffs of raising or lower corporate taxes have shifted.”

Trail of fraudulent overbilling in latest False Claims Act leads back to — well, the NYC government [New York Daily News, U.S. Attorney press release]

INADEQUATELY FUNDED’ HMRC should be the subject of a thorough government review, the president of the ATT has urged  

“Judge of bogus ‘postal court’ files purported judgments, claims only nouns have legal meaning” [ABA Journal] “Sovereign citizen” talk found in various other parts of the English-speaking world, also Germany where some argue Weimar Republic is still in effect [Lowering the Bar; sequel (“Sovereign Citizens Also Bothering Scotland”); our folk law heading]

International Tax Evasion: What Can Be Done?

 France 'to go all the way' to make multinationals pay their taxes  

Bloomberg:  Trump Gets Chance for Tax Cut Moving Trademarks to Delaware, by Lynnley Browning:
As Donald Trump prepared for the Republican primaries, he transferred dozens of his most prized assets, the “Trump” trademarks that adorn everything from hotels to ties to his U.S. golf courses, into a new Delaware-based company — a move that offers him a chance to cut his income-tax bills.

A 2014 email sent by Mossack Fonseca's New Zealand representative lays out exactly how the company uses foreign trusts in this country.
Panama Papers: Mossack Fonseca email shows how it used foreign trusts in NZ: June 2016 AD

Following The Money: Lessons From The Panama Papers, Part 1: Tip Of The Iceberg