John Stancil

The background for the European Union (EU) assessing a $14.5 billion tax on Apple for its sales in Ireland is a rather complex maze of laws, treaties, and politics. It is not my purpose here to delve into those complexities. I am attempting a simple explanation of the issues involved and why the EU levied the tax, even though Apple and Ireland were both very content with thing the way there were.

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Nassim Kadem reports in today’s Australian Financial Review that recently appointed Commissioner Chris Jordan has mooted a new amnesty for disclosure of hidden offshore assets and income. A Tax Office official has confirmed the proposal and apparently, Treasurer Joe Hockey has indicated support for the idea.

The amnesty would cap the retrospective tax and penalty period to four years, making it relatively attractive for Australian taxpayers wanting to come clean and avoid later criminal prosecution and unlimited back taxes. It would be particularly attractive to second and third generation members of wealthy families who have “inherited” the problem of secret offshore caches. Read More

Moshe Asher: The Tax Authority plans to provide information to relevant countries about foreign residents’ capital in Israel.

“We won’t be a tax haven for foreign residents,” said Israel Tax Authority director general Moshe Asher at the conference of the CPA Association of Jerusalem conference on December 17, 2013.

He said that the Tax Authority planned to provide information to relevant countries about foreign residents’ capital in Israel, and that these countries will reciprocate about the foreign assets of Israelis. Read More

Recently, the OECD ramped up its conflict with tax havens by issuing a report titled, Action Plan on Base Erosion and Profit Sharing. Obviously, the purpose of this report is to provide a set of options that OECD countries can enact to counter the negative impact of tax base erosion, or the shifting of tax revenue away from developed/higher tax countries to lower tax/tax havens. But before I get to the report, a bit of background is necessary to provide some context to the conflict.

First, how did tax havens develop? As I noted in a post I wrote on my economic blog about the Cyprus situation:

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A Practical Guide to Perfecting Your Tax Research Techniques and Achieving Sustainable Tax Return Filing Positions


In order to maximize your accounting firm’s overall efficiency, effectiveness, and productivity in connection to researching and resolving a tax issue and determining the sustainability of the tax return filing position, the appropriate tax research processes must be meticulously designed, implemented, and executed. The subsequent five comprehensive steps will guide you in establishing an all-inclusive tax research effort on behalf of your entire client base while properly ascertaining the likelihood of success Read More

TaxConnections Tax Blog - China and Southeast Asia Transfer Pricing Issues

An effective operational offshore company often used is the leasing company. Leasing has been utilized in the acquisition of assets and there is a split benefit gained through a leasing company. Tax benefits accrue in the way of substantial depreciation deductions reducing taxable income to one party, while the other party may also be entitled to amortization benefits. This is a cross-border effect of the virtues of depreciation. (1)

The leasing company in the United States context is governed by the Foreign Base Company Income category of Foreign Personal Holding Company Income. (See TaxConnections/TaxBlogoshere/September 20, 2013/Foreign Corporations and Subpart F Income-Part III). Foreign Personal Holding Company Income consisting of rental income Read More