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Category Archives: Tax shelters
OECD gives the nod to group information requests – fishy, but not faulty
A recent amendment to the OECD Model Tax Convention gives a boost to the information gathering powers of the tax authorities, especially when it comes to the meaning of “foreseeable relevance” and “fishing expeditions”. The amendment to the commentary to Article 26 of the Convention eases the rules affecting group requests for information under tax treaties. The Article now permits exchange of information only when it is “foreseeably relevant” for the administration of the taxes of the requesting party. This … Continue reading
Posted in Offshore, Tax havens, Tax risks, Tax shelters
Tagged Forseeable relevance, OECD, Tax treaties
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Google, IRS and cross border dealings
There are a few companies that relentlessly hog the headlines. Google is one of them, Apple is another. It is widely believed that magic happens at Google. Apple is where magic is sold. But when a slightest whiff of suspicion appears it doesn’t take long for the corporate glow to disappear. Now it is reported that the IRS has started an audit of Google’s offshore operations. It is thought that Google used “Double Irish” and “Double sandwich” arrangements, see IRS … Continue reading
Posted in Tax administration, Tax shelters, US
Tagged Apple, double irish, double sandwich, Google, sandwich
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Banks, tax shelters and the Wickenby blackhole
The recent tax settlement reached by Deutsche Bank with the Internal Revenue service of US and current inquiries conducted by the ATO are sure signs of tax authorities hardening their position on dealings involving tax havens. In the matter of Deutsche Bank, it is reported that the Bank has agreed to pay half a billion dollars as penalty to the IRS. It is also revealed that the tax shelter dealings were uncovered when a major accounting firm was investigated. The … Continue reading
Posted in Tax administration, Tax shelters
Tagged Deutsche Bank, Tax shelters, Wickenby
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