Below you'll find a list of all posts that have been categorized as “Uncategorized”
Let’s talk a little more about one of the consequences of Trump Tax Reform that I mentioned in the first part of this series, to wit—a mandatory repatriation tax that is now included in the new Tax Cuts and Jobs Act. Remember, one little change in the new Act—“Section 958(b) is amended by striking paragraph (4)”—causes a bunch of foreign …
It snuck up on us like a fire ant in your underwear. A little-known, little-followed, late added provision of the new U.S. Tax Cuts and Jobs Act that has the unintended consequence of forcing a foreign company to file detailed information with the IRS about all its non-US subsidiaries. The offending provision states simply: “Section 958(b) is amended—by striking paragraph …
Let me start with a prediction: the United States will have a 20% corporate income tax rate in 2018. Exactly how that political “sausage” will be made—and potential opportunities for both US and non-US businesses arising from Tax Reform—is the subject of this series of posts. But lets talk about recent history for a moment. Remember, this all started on …
Did you see the whipping the European Union gave Apple and Amazon?—Apple was told to repay USD $13 billion in “illegal” tax benefits to the Republic of Ireland. Amazon was ordered to repay USD $300 million in back taxes to Luxembourg (https://www.wsj.com/articles/eu-orders-luxembourg-to-recoup-almost-300-million-from-amazon-1507109839). If you read my first two articles under the same title you will recall that Amazon (and other …
You do remember the prediction in my last post don’t you? That Congress will reduce the corporate income tax from 35% to 20% in 2018…? Well when that happens non-US investors should jump for joy. Follow my logic for a moment. It’s fairly non-controversial to say that the short-term benefit of a corporate tax rate cut is enjoyed by shareholders …
If you ever want to see the tax version of a wrestle-mania “beat down” watch the English Parliament’s Committee on Public Accounts administering a properly British wallop upon Amazon’s European director of policy, Mr. Andrew Cecil. It’s a few years old, but demonstrates the tax structures that Amazon and others have used to reduce their global tax bills for years. …
Tax lawyers should take their rightful place among rock stars and astronauts. Google, Apple, Amazon, Pfizer are only some of the mega businesses who think international tax lawyers are more exciting than John Glenn, Beyoncé, Justin Bieber and Drake all in one. Oddly creative in giving their international tax schemes such names as “Double Irish” and “Dutch Sandwich” these unappreciated …
