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Author: Richard A. Gordon Publisher: The Minerva Group, Inc. ISBN: 089499137X Category : Tax exemption Languages : en Pages : 277
Book Description
This book was written at the request of the Commissioner of Internal Revenue, The Assistant Attorney General (Tax Division), and the Assistant Secretary of the Treasury (Tax Policy).The purpose of this book was to develop an overview of tax havens and the use of tax havens by United States taxpayers. The study sought to determine the frequency and nature of tax haven transactions, identify specific types of tax haven transactions, obtain a description of the United States and foreign legal and regulatory environment in which tax haven transactions are conducted, describe Internal Revenue Service and Justice Department efforts to deal with tax haven related transactions, and to identify interagency coordination problems.The findings are based on a review of judicial decisions and published literature in the field of international tax planning, research into internal IRS documents concerning taxpayer activities, interviews with IRS personnel, personnel who deal with tax haven issues for other Federal government agencies, and lawyers and certified public accountants who specialize in international taxation. The findings are also based on a statistical analysis of available data concerning international banking, United States direct investment abroad, and foreign investment in the United States. While the findings did not uncover all the methods employed to use tax havens, the belief is that the inquiry was extensive enough to give an understanding of the situation and to enable the IRS to develop options which might be useful in improving the administration of the tax laws as they apply to tax havens
Author: Richard A. Gordon Publisher: The Minerva Group, Inc. ISBN: 089499137X Category : Tax exemption Languages : en Pages : 277
Book Description
This book was written at the request of the Commissioner of Internal Revenue, The Assistant Attorney General (Tax Division), and the Assistant Secretary of the Treasury (Tax Policy).The purpose of this book was to develop an overview of tax havens and the use of tax havens by United States taxpayers. The study sought to determine the frequency and nature of tax haven transactions, identify specific types of tax haven transactions, obtain a description of the United States and foreign legal and regulatory environment in which tax haven transactions are conducted, describe Internal Revenue Service and Justice Department efforts to deal with tax haven related transactions, and to identify interagency coordination problems.The findings are based on a review of judicial decisions and published literature in the field of international tax planning, research into internal IRS documents concerning taxpayer activities, interviews with IRS personnel, personnel who deal with tax haven issues for other Federal government agencies, and lawyers and certified public accountants who specialize in international taxation. The findings are also based on a statistical analysis of available data concerning international banking, United States direct investment abroad, and foreign investment in the United States. While the findings did not uncover all the methods employed to use tax havens, the belief is that the inquiry was extensive enough to give an understanding of the situation and to enable the IRS to develop options which might be useful in improving the administration of the tax laws as they apply to tax havens
Author: Richard A. Gordon Publisher: ISBN: Category : Government publications Languages : en Pages : 252
Book Description
Overview of tax havens and the use of tax havens by US taxpayers. The study sought to determine the frequency and nature of tax haven transactions, identify specific types of tax haven transactions, obtain a description of the US and foreign legal and regulatory environment in which tax haven transactions are conducted, describe the IRS and Justice Department efforts to deal with tax haven related transactions, and to identify interagency coordination problems.
Author: Congressional Research Congressional Research Service Publisher: Createspace Independent Publishing Platform ISBN: 9781507734483 Category : Languages : en Pages : 0
Book Description
Addressing tax evasion and avoidance through use of tax havens has been the subject of a number of proposals in Congress and by the President. Actions by the Organization for Economic Cooperation and Development (OECD) and the G-20 industrialized nations also have addressed this issue. In the 111th Congress, the HIRE Act (P.L. 111-147) included several anti-evasion provisions, and P.L. 111-226 included foreign tax credit provisions directed at perceived abuses by U.S. multinationals. Numerous legislative proposals to address both individual tax evasion and corporate tax avoidance have been advanced. Multinational firms can artificially shift profits from high-tax to low-tax jurisdictions using a variety of techniques, such as shifting debt to high-tax jurisdictions. Because tax on the income of foreign subsidiaries (except for certain passive income) is deferred until income is repatriated (paid to the U.S. parent as a dividend), this income can avoid current U.S. taxes, perhaps indefinitely. The taxation of passive income (called Subpart F income) has been reduced, perhaps significantly, through the use of hybrid entities that are treated differently in different jurisdictions. The use of hybrid entities was greatly expanded by a new regulation (termed check-the-box) introduced in the late 1990s that had unintended consequences for foreign firms. In addition, earnings from income that is taxed often can be shielded by foreign tax credits on other income. On average, very little tax is paid on the foreign source income of U.S. firms. Ample evidence of a significant amount of profit shifting exists, but the revenue cost estimates vary substantially. Evidence also indicates a significant increase in corporate profit shifting over the past several years. Recent estimates suggest losses that may approach, or even exceed, $100 billion per year. Individuals can evade taxes on passive income, such as interest, dividends, and capital gains, by not reporting income earned abroad. In addition, because interest paid to foreign recipients is not taxed, individuals can evade taxes on U.S. source income by setting up shell corporations and trusts in foreign haven countries to channel funds into foreign jurisdictions. There is no general third-party reporting of income as is the case for ordinary passive income earned domestically; the Internal Revenue Service (IRS) relies on qualified intermediaries (QIs). In the past, these institutions certified nationality without revealing the beneficial owners. Estimates of the cost of individual evasion have ranged from $40 billion to $70 billion. The Foreign Account Tax Compliance Act (FATCA; included in the HIRE Act, P.L. 111-147) introduced required information reporting by foreign financial intermediaries and withholding of tax if information is not provided. These provisions became effective only recently, and their consequences are not yet known. Most provisions to address profit shifting by multinational firms would involve changing the tax law: repealing or limiting deferral, limiting the ability of the foreign tax credit to offset income, addressing check-the-box, or even formula apportionment. President Obama's proposals include a proposal to disallow overall deductions and foreign tax credits for deferred income, along with a number of other restrictions. Changes in the law or anti-abuse provisions have also been introduced in broader tax reform proposals. Provisions to address individual evasion include increased information reporting and provisions to increase enforcement, such as shifting the burden of proof to the taxpayer, increased penalties, and increased resources. Individual tax evasion is the main target of the HIRE Act, the proposed Stop Tax Haven Abuse Act, and some other proposals.
Author: Marshall J. Langer Publisher: ISBN: Category : Tax havens Languages : en Pages : 416
Book Description
This book provides background material concerning why and how to use foreign tax havens. The various chapters discuss why tax havens exist, a survey of havens, tax haven activities, special uses of tax havens, the legal framwork, anti-avoidance measures, major no-tax havens, territorial tax havens, Britain's low-tax Caribbean havens, the Netherlands Antilles and its unique status, Britain's sterling area havens, European holding and domiciliary companies, and choosing the best tax haven.
Author: Jesse Albert Schmitt Publisher: Atlantic Publishing Company ISBN: 160138257X Category : Business & Economics Languages : en Pages : 290
Book Description
An ever increasing number of Americans are convinced that our country is no longer the land of safety or opportunity when it comes to their money and investments. These people recommend transferring your money to offshore tax havens in such countries as Dubai, Hong Kong, Switzerland, Liechtenstein, and Panama. In fact, it has recently been estimated that nearly 60 percent of the world s money is located in offshore accounts. Legal Off Shore Tax Havens will show you how to protect your money and remain legal while doing so. Off shore tax havens are sovereign nations that have laws in place that protect people s financial privacy, assets, and cash. In this new, exhaustively researched book, you will find out how to take advantage of this system. You will learn how the system works, how to develop business opportunities, how to avoid excessive taxation and regulation, how to bank and invest off shore, how to find the tax haven that is right for you, and how to avoid scams. In addition, you will learn about the safest, most private nations, the best off shore banks and tax havens, what is and what is not legal, the best haven for your specific purposes, mistakes to avoid, legal issues, and basic off shore entities. You will also learn how sophisticated tax avoiders use countries such as Ireland, Austria, and the Netherlands to avoid suspicion; how to use residential tax havens, including Argentina and Costa Rica; and how to use Greece, the Phillipines, and Jordan as completely tax-free havens. Legal Off Shore Tax Havens will provide you with the strategies, knowledge, and contacts you need to avoid expensive mistakes and make the most of your offshore pursuits. This book is for those who are weary of paying high taxes and who are suspicious of the government. Whether you are seeking to move your business s money or your own personal finance, this book will provide you with all the necessary information to make a smooth, legal transition. Atlantic Publishing is a small, independent publishing company based in Ocala, Florida. Founded over twenty years ago in the company presidentâe(tm)s garage, Atlantic Publishing has grown to become a renowned resource for non-fiction books. Today, over 450 titles are in print covering subjects such as small business, healthy living, management, finance, careers, and real estate. Atlantic Publishing prides itself on producing award winning, high-quality manuals that give readers up-to-date, pertinent information, real-world examples, and case studies with expert advice. Every book has resources, contact information, and web sites of the products or companies discussed.
Author: Adam Starchild Publisher: Springer Science & Business Media ISBN: 9401744726 Category : Business & Economics Languages : en Pages : 154
Book Description
If you arenot a citizen or resident of the United States (U.S.) and you are contemplating either making or expanding an investment in the U .S., either for yourself as an individual or for a business, you arenot alone. The U.S. is the country of first choice for many foreign investors. This is due to the fact that the U.S. offers foreign investors many advantages, some ofwhich are in short supply in today's world. The primary advantage that the U.S. affords foreign investorsisthat it endorses the economic concept of free enterprise. While it is true that the Federal and state governments have interfered with the private economy to some extent, the prevailing economic philosophy in the U .S. remains laissez faire. History has taught the U.S. that the market place allocates the finite resources of a country betterthan the government, and the advantagesoftbis philosophy have not been overlooked by foreign investors. Another attractive feature of the U .S. as an investment site is its political stability. The present form of constitutional government has presided for over 200 years, and this history provides foreign investors with a measure of security which is absent elsewhere.
Author: Adam Starchild Publisher: Springer ISBN: 1349133426 Category : Business & Economics Languages : en Pages : 158
Book Description
Tax Havens for International Business is a special management report that shows how the establishment of a tax haven operation, in any of many locations worldwide, can save more money than any internal tax-shelter programme. This volume provides a comprehensive, step-by-step plan that simplifies the myriad complexities surrounding the formation and incorporation of branch offices and subsidiary companies within such tax havens as the Bahamas, Bermuda, the Cayman Islands, Greece, Hong Kong, Luxembourg, Malta, The Netherlands, Panama, Puerto Rico, and Switzerland. In addition, it presents detailed information on each tax haven's economic, legal, political, cultural and geographical aspects, which must be considered if such an enterprise is to operate successfully.
Author: Richard A. Gordon
Author: Richard A. Gordon
Author: Richard A. Gordon
Author: Jane Gravelle
Author: Congressional Research Congressional Research Service
Author: Marshall J. Langer
Author: Jesse Albert Schmitt
Author: Marshall Jay Langer
Author: Adam Starchild
Author: Adam Starchild
Author: Adam Starchild