~ Bishop Joseph Butler, who died around this date in 1752
Aldi Australia signs tax transparency code
In Awad v. Commissioner, T.C. Memo 2017-108, here, a whistleblower case,
the following is the key time line:
There are some significant, scantily explained, time lapses in the foregoing,
but they are not relevant to the outcome because the examining agents involved in LB&I and SB/SE all attested that the Form 211 information did not contribute to the ultimate outcome -- the acceptance of the TH Estate and TW's voluntary disclosure. After all, for collection, the information does have to contribute to collected proceeds to permit a WB award.
The thing that is curious to me is that there were no procedures to flag the matter when the WBO first assigned it to LB&I so that, after that date, the taxpayers could not qualify for voluntary disclosure. It is true that the procedure assumes disqualification only after the IRS has flagged the taxpayer for audit. (I have had one client thus disqualified even though the IRS had never notified him of the audit.) I understand that LB&I had not yet decided to audit, but it seems to me that there should be some way to disqualify once WBO decides the information has sufficient gravitas to refer to Examination, at least while it is in that status. Just my view.
Globalisation Work: Better Lives for All, I have a piece in Inside Story, headlined: The OECD joins the backlash against unfettered globalisation looking at a recent report they’ve issued. The subheading is
Sydney's primary school overcrowding to hit high schools
SSCL is a joint venture between the Cabinet Office and French outsourcer Sopra Steria, intended to shift departments' back office servers and ERP systems into privately owned shared services centres Oh the irony: Government Digital Services can't pay staff because of tech problems
The federal government is giving lucrative contracts to suppliers who avoid paying their share of taxes by using tax havens. This includes individuals and organizations named in the Panama Papers. Those findings, and recommended changes to the current rules, are contained in a report by Canadians for Tax Fairness and the labour organization Unite Here.
Why are Tax Haven Users Getting Govt Contracts? Canadians for Tax Fairness
Aldi Australia signs tax transparency code
Queanbeyan cleaner Kelvin Mark Skeers convicted for ripping off ATO
A Queanbeyan man has been sentenced to three years in prison after he defrauded the tax office of more than a quarter of a million dollars
ATO tax fraud: Superannuation funds of eight 'syndicate members' seized
US Gov’t Wants Rights To ‘Dumb And Dumber’ Sequel, Due To International Corruption Case
“The US Justice Department is seeking to acquire the rights to films, including the comedy sequel Dumb and Dumber To, as part of an effort to recover $540m in assets it says were stolen from Malaysia’s troubled wealth fund.”
Tax Court Denies Claim in Offshore Account Case with Very Unusual Facts Because the Information Did Not Produce Collected Proceeds
In Awad v. Commissioner, T.C. Memo 2017-108, here, a whistleblower case,
the following is the key time line:
Date
|
Event
|
11/18/2008
|
Awad files WB claim (Form 211) identifying husband and wife (TH and TW, respectively) and their three adult children as owners of undisclosed foreign bank account.
|
2/?/2009
|
WBO assigns to LB&I
|
LB&I Agent reviews returns and decides to accept as filed based on insufficient information
| |
8/?/2009
|
TH dies.
|
1/?/2010
|
TW and children file "voluntary disclosures pertaining to a previously undisclosed account at the same foreign bank" Awad had disclosed.to WBO
|
??/??/2010
|
SB/SE opens exam incident to voluntary disclosure
|
7/?/2010
|
LB&I returns the case to WBO (although a year after LB&I made decision not to pursue)
|
9/?/2010
|
WBO discovers SB/SE exam and forwards information to SB/SE for possible use in examination
|
??/??/2010
|
SB/SE Agent interviews Awad by telephone; Awad provides additional information
|
??/??/2010
|
SB/SE advises WBO that the information did not assist in the audit
|
8/??/2011
|
IRS enters closing agreement on the voluntary disclosure requiring tax, penalties (including MOP) in excess of $2M for TW and estate
|
9/??/2013
|
WBO learns of estate tax exam for TPH and refers information to SB/SE Estate and Gift Tax
|
1/28/2014
|
WBO denies award.
|
but they are not relevant to the outcome because the examining agents involved in LB&I and SB/SE all attested that the Form 211 information did not contribute to the ultimate outcome -- the acceptance of the TH Estate and TW's voluntary disclosure. After all, for collection, the information does have to contribute to collected proceeds to permit a WB award.
The thing that is curious to me is that there were no procedures to flag the matter when the WBO first assigned it to LB&I so that, after that date, the taxpayers could not qualify for voluntary disclosure. It is true that the procedure assumes disqualification only after the IRS has flagged the taxpayer for audit. (I have had one client thus disqualified even though the IRS had never notified him of the audit.) I understand that LB&I had not yet decided to audit, but it seems to me that there should be some way to disqualify once WBO decides the information has sufficient gravitas to refer to Examination, at least while it is in that status. Just my view.
OECD vs Globalisation:
Not quite, but the OECD has finally recognised that globalisation isn’t currently working to deliver improved living standards for everyone, a fact implicit in the title of its latest report MakingGlobalisation Work: Better Lives for All, I have a piece in Inside Story, headlined: The OECD joins the backlash against unfettered globalisation looking at a recent report they’ve issued. The subheading is
But can an organisation that has promoted a globalised world economy take on the massively powerful finance sector?
(Hint: Probably not)
"Too soon we grow old, too late we grow smart..."
"Too soon we grow old, too late we grow smart..."
John Quiggin OECD vs Globalisation
Sydney's primary school overcrowding to hit high schools
Exclusive The UK's Government Digital Service – the Whitehall body responsible for transforming government IT – is having problems paying staff because of, er, technical issues.
In an internal email sent within GDS, and seen by The Register, the body said: "We are aware of a number of pay related issues currently within GDS."
Last month GDS switched over to a new payroll system, handled by the Cabinet Office's Shared Services Connected Limited company. SSCL is a joint venture between the Cabinet Office and French outsourcer Sopra Steria, intended to shift departments' back office servers and ERP systems into privately owned shared services centres Oh the irony: Government Digital Services can't pay staff because of tech problems
Tax transparency and the end of transfer pricing: A few quick thoughts on where things stand in the battle for fair taxation of multinationals – by TJN’s Chief Executive @alexcobham
Transparency on beneficial ownership is essential for good governance and reforms Open Government Partnership
Swiss banks lobby for get-out clause as end of bank secrecy nears Reuters
See our report “The end of bank secrecy”? Bridging the gap to effective automatic information exchange, see also our recent blog: Switzerland and information exchange: tweak, tweak and something will always remain
See our report “The end of bank secrecy”? Bridging the gap to effective automatic information exchange, see also our recent blog: Switzerland and information exchange: tweak, tweak and something will always remain
A fire in the world’s laundromat Open Democracy
Malta / Money Laundering: Fair and thorough investigation urgently needed Sven Giegold
Malta / Money Laundering: Fair and thorough investigation urgently needed Sven Giegold
India – First Panama Papers seizure: Top Delhi jeweller’s deposits The Indian Express
Tanzania: Chronicle of Suspected Plunder and Corruption in Energy and Minerals Ministry: An Inside Story Business News
‘Recent press reports said Tanzania lost a staggering Tsh. 7.2trn/- ( about $2.13billion) in 2016 as a result of some extraordinary tax holiday and loopholes in the mining sector.’
‘Recent press reports said Tanzania lost a staggering Tsh. 7.2trn/- ( about $2.13billion) in 2016 as a result of some extraordinary tax holiday and loopholes in the mining sector.’
Bangladesh: E-commerce would promote illicit flow of information & asset by MNCs from LDCsNewsflash 24bd
Why are Tax Haven Users Getting Govt Contracts? Canadians for Tax Fairness
Hundreds of mining, oil and gas companies reveal payments to governments for the first time, in Canada and around the world Publish What You Pay Canada
Why Kenya’s super-rich stay invisible Business Daily
Foreign investors snapping up London homes suitable for first-time buyers The Guardian
‘… and being held in off-shore tax havens’
‘… and being held in off-shore tax havens’