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Tag Archive for Multinationals

“Corporations Are People Too ….. My Friend.” – Tax Law

Giving a speech on tax reform whilst stumping for president in what is now seemingly a woebegone era of politics, Mitt Romney quipped this now seemingly famous sound bite personifying the greed of purported capitalism. According to US tax law, unfortunately he is right. Corporations are ‘treated’ like people.

Since this is how we live, when it comes to writing tax laws it seems a reasonable expectation that corporations behave as moral agents of society just like the rest of us. After all, they have their own decision structures and choices to make between rightness and wrongness, goodness and badness that are justified with reasons just like us. Read more

Big Businesses Lobby For 3.5% Offshore Repatriation Tax

Ron Marini

According to various news reports, U.S. multinationals are “pushing” the U.S. government to further reduce the tax rate on offshore profits. Major U.S. multinationals are pushing the Trump administration to deepen the tax break it has already tentatively proposed on $2.6 trillion in corporate profits being held offshore by more than 500 U.S. companies.

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IRS Crack Down On Foreign Tax Credits For U.S. Multinationals

Ronald Marini

The U.S. Department of the Treasury revealed on September 15, 2016 that it is drafting rules to curb U.S. Multinationals from obtaining U.S. foreign tax credits as a result of foreign government’s audits resulting in foreign tax adjustments for U.S. Multinationals.

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Corporate Tax Professionals Surprised By Stunning “Spans & Layers” Report By Bain & Company

After thirty years consulting to tax executives of multinationals, I have been fortunate to witness trends emerging behind the scenes long before corporate tax professionals ever see them. Stunning new trends will take corporate tax organizations by surprise in 2015 and beyond. Having built many trusted relationships consulting with tax executives over three decades, my goal is to protect tax professionals now and in the future from these trends with an awareness of what is happening behind the scenes and how to position yourselves in an ever changing market. These days, I find myself in an interesting position having founded two organizations focused on helping tax professionals make better connections with the people searching to find them. Corporate tax professionals I know well, having placed thousands of tax experts over a span of thirty years into corporate tax Read more

Australian Tax Office Is Probing 86 Multinationals

Pat McGrath of Australia’s national broadcaster ABC News reports that “About 100 Tax Office staff have begun a four year investigation into the tax affairs of big companies global companies operating in Australia.” (sic)

In an interview with Pat McGrath, Mark Konza (ATO Deputy Commissioner) said: “At the moment – and I should say this process is ongoing, so other cases will be identified over time – these 86 cases where we felt that the structuring events that had taken place seem to have a very bad effect on a company’s Australian tax position…”. Deputy Commissioner Konza continued, “We will issue assessments on companies that we think weren’t applying the law correctly. If they’re involved in profit shifting, they’ll get an assessment; they’ll get penalties as well.” Read more

India Tax Planning – Multinationals Should Act Before May 31, 2013

Multinationals with operations in India have only until May 31, 2013 to act before a newly proposed provision in India’s Finance Bill will affect their tax planning.

Private companies operating in India typically resort to a buyback of its shares instead of payment of the dividends to avoid a dividend distribution tax, particularly where the capital gains arising to the shareholders are either not chargeable to tax or are taxable at a lower rate.

The Union Budget 2013 includes a provision that, effective June 1, 2013, an additional tax — at a rate of 20% (plus applicable surcharge and cess levy) — would be imposed on any amount distributed by an Indian company with respect to the buy-back of unlisted shares.

In other words, this tax would be imposed on the distributed income of the Indian company. This income would not be Read more

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