If Neil Gorsuch becomes the next Supreme Court justice, is that proof bullying works? [Guile is Good]
Tips for surviving work when you’re exhausted. [Corporette]Criminal records and airport security are not a good mix
The Turnbull government is expected to announce some interim measures in the May federal budget aimed at beginning a long journey to claw back up to an estimated $15 billion in lost federal tax revenue and illegitimate welfare payments due to widespread cash economy activity.
The man heading the federal government's "Black Economy Taskforce", Board of Tax chairman Michael Andrew, told Fairfax Media he was shocked by the scale of the problem, with exploitation of vulnerable workers such as students and temporary visa holders rife. Exclusive: Federal budget to tackle illegal cash economy costing up to $15b in lost revenue
StanChart to double minimum wealth for private bank clients Financial Times
Company directors call on AICD to reveal CEO John Brogden's pay
NSW branch of RSL facing fresh claims of fraud, cover-up
By the numbers: Men still run venture capital
White House explores two new tax ideas — a value-added tax and carbon tax — as leading proposal to raise revenue ...
Accountants may have to start making annual reports on their anti-money laundering programs Banks point finger at accountants on money laundering fight
Kay Bell, IRS bringing in more tax money despite budget cuts. “The Internal Revenue Service collected more than $3.3 trillion during the 2016 fiscal year.”
The number of Australians caught up in the global Credit Suisse investigation continues to rise as the Australian Taxation Office confirmed on Monday that it had obtained details of more than 1000 of the bank's accounts linked to local clients.
"Not all of the accounts have a name, some of them are just an address," Deputy Commissioner Michael Cranston told The Australian Financial Review, as the investigation into suspected tax avoidance widens. Revenue and Financial Services Minister Kelly O'Dwyer revealed on Friday that 346 Australians had been identified so far in the leak of Credit Suisse documents, which the Dutch tax authority obtained from a whistleblower last April.
Credit Suisse (CS) Faces Tax Fraud & Money Laundering Probes
- Heather Field (UC-Hastings), Offshoring Tax Ethics: The Panama Papers, Seeking Refuge from Tax, and Tax Lawyer Referral
- Khrista Johnson (Pepperdine), Till Offshore Do Us Part: Uncovering Assets Hidden from Spouses and Tax Authorities
- Cristina Trenta (Örebro University), Migrants and Refugees A EU Perspective on Upholding Human Rights through Taxation and Public Finance
- Allison Christians (McGill), Buying In: Citizenship and Residence by Investment
- Matthew Lister (Pennsylvania), A Tax-Credit Approach to Addressing Brain-Drain
- William Thomas Worster (The Hague), International Law and the Taxation Consequences for Renouncing Citizenship
- Leila Adim (Universitat de Barcelona), Between Benefit and Abuse: Immigrant Investment Programmes
- Montano Cabezas (Georgetown), Migration and Taxation in the Public Imagination
- Henry Ordower (Saint Louis), Taxing Others in the Age of Trump: Foreigners (and the Politically Weak) as Tax Subjects
- Genevieve Tokic (Northern Illinois), Exploring the Intersection of Trade Policy, Immigration, and Tax Law in the Recent Wave of Migration to the United States from Central America
- David Elkins (Netanya College School of Law), The Elusive Definition of Corporate Tax Residence
- Ashrita Prasad Kotha (Jindal Global Law School), The Mauritius Route: The Indian Experience
- Lukas Moravec & Jan Rohan (University of Life Sciences, Prague), Tax Information Exchange Impact on FDI: Tax Havens Czech Case Study
- Diane Ring (Boston College), Transparency and Disclosure Burdens as Business Costs of Border Flexibility
This recent paper "Problems with destination-based corporate taxes and the Ryan blueprint" by Reuven S. Avi-Yonah and Kimberly Clausing has content throughout, but this struck me as the most interesting section:
1. A U.S. pharmaceutical with foreign subsidiaries could develop its intellectual property in the United States (claiming deductions for wages, overhead and R&D), and then sell (i.e., export) the foreign rights to its Irish subsidiary (at the highest price possible). The proceeds would not be taxable. Ireland would allow that subsidiary to amortize its purchase price. This creates tax benefits in each jurisdiction by reason of the different regimes. If the Irish subsidiary manufactures drugs, the profits could be distributed up to the U.S. parent tax-free under a territorial system. If the Irish subsidiary is in danger of becoming profitable for Irish tax purposes, the U.S. parent would just sell it more IP.
Via Staffer of Tim F2. If an Irish parent owns a U.S. subsidiary, the Irish parent can issue debt to fund the purchases of the IP. The U.S. subsidiary then invests the cash to generate more IP (expensing all equipment and deducting all salaries) and sells the IP to its parent.3. If an Irish parent has purchased the U.S. IP rights, it would not want to license the rights to the U.S. subsidiary (income for Irish parent under Irish tax law and no deduction for U.S. subsidiary). So it just contributes the rights to another U.S. subsidiary. Could the U.S. subsidiary amortize the parent’s basis under the Blueprint? When one U.S. subsidiary licenses to another, no net tax would be paid. Any royalties would be taxable to the licensor but deductible for the payor.4. How does the Blueprint work for services? If a U.S. hedge fund manager provides services to an offshore hedge fund, is that considered an export that is tax exempt? What if the U.S. manager develops a trading algorithm and sells it (or licenses) it to an offshore hedge fund? Are the proceeds and royalties exempt? If so, then the hedge fund becomes a giant tax shelter to the manager, because he would not pay 25% on this income–he would pay zero, with no further tax. This is much better than the current carried interest provision, which has attracted bipartisan condemnation because it enables individuals with income of many millions to pay a reduced rate. The Blueprint result is much worse.