Denial of Treaty Benefits and Limitation of Benefits One of the hallmarks of international tax planning is the ability to obtain a tax ruling from a foreign revenue services that the taxpayer is a qualified resident for income tax treaty purposes. Such a ruling permits a taxpayer to proceed with certainty in establishing operations. It […]
Increase of offshore account penalties The IRS recently warned that the agency has collected $8 billion in taxes and fines collected from offshore bank account penalties which were a result of not conforming to the Foreign Account Tax Compliance Act. According to a report by Forbes contributor and tax lawyer Robert Wood, the IRS has begun to […]
According to a Forbes report last week, Walmart has $76 billion in foreign tax havens. The report claimed that the world’s largest retail chain has 78 subsidiaries in 15 overseas tax havens where the company has no store locations. Walmart’s hidden assets The report claimed that Walmart is effectively avoiding U.S. corporate taxes on overseas […]
Microsoft is being audited by the IRS and they demand leaders testify The IRS is suing a number of former and current executives of Microsoft in a bid to force them to testify in an investigation into the company’s corporate tax practices. According to The Seattle Times, at issue is whether the company is following […]
