Comments for CCH Tax Chat

Comment on FATCA – Expanded affiliated group under IGA by Dr Terry Dwyer

Dr Terry Dwyer — Fri, 15 Mar 2013 00:04:18 +0000

Australia should refuse to co-operate with FATCA. As a source country it is not in our national interest. A resource-rich, capital importing, country has every reason and the means to become seriously tax-competitive. Australia should be taxing land values and resource rents and cutting personal and corporate tax rates. A reduction to 15% could be reasonably easily financed, along with abolition of CGT and taxation of foreign source income. Australia could out-compete Singapore and Hong Kong. We should be seeking to get population and capital from the USA and Europe as taxpayers flee decaying welfare states. We should not emulate US or UK decline nor assist them in stopping capital flight to us.

As with the US “Free Tade” agreement and the WTO agreements on intellectual property, Australia is so far too stupid to understand its own latent economic power or its long term interests.

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Comment on Taxes never felt better- Warren Buffet has the dough to match by hedge fund trading x

hedge fund trading x — Wed, 27 Feb 2013 06:42:10 +0000

I have observed that over the course of creating a relationship with
real estate managers, you’ll be able to get them to understand that, in most real estate deal, a commission is paid. Eventually, FSBO sellers do not “save” the payment. Rather, they struggle to earn the commission simply by doing a agent’s
job. In this, they invest their money as well as time to perform, as best they can, the tasks of an real estate agent.
Those responsibilities include uncovering the home via marketing, presenting the
home to buyers, constructing a sense of buyer urgency in order to induce
an offer, booking home inspections, dealing with qualification
check ups with the financial institution, supervising maintenance, and assisting the closing.

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Comment on Hedge effectiveness – banishing “bright line” testing by Dana Caffrey

Dana Caffrey — Thu, 29 Nov 2012 11:25:12 +0000

Thanks for this very good article. I’m really quite confused about hedge accounting and how it affects taxation. Now, it gave me an idea of how it really works, how the two are linked to each other. Hope to read more educational articles like this.

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Comment on FATCA – will it keep personal information private? by Marvin Van Horn

Marvin Van Horn — Fri, 03 Aug 2012 05:58:44 +0000

You may not be aware of two recent developments in the States as U.S. legislators wake up to this monster they have created.

First, is a push back by Congress against the IRS reciprocity tool they are trying to impose unilaterally on U.S. Banks to make them report foreign interest to the IRS so they can trade it for the IGAs (Intergovernment agreements) that they just recently announced.

This was reported here…. http://bit.ly/OrYTSm

The reason they are now responding, is there is starting to be the natural Capital flight in Florida banks as reported in the Miami Herald. http://hrld.us/R8Az8g FATCA is the fallout back on U.S. banks. Comments there explain it more, if you are not aware of the relationship.

Secondly, 4 U.S. Senators have recently written Geithner basically grilling him about what Treasury is doing. We have a Bureaucracy running wild and setting policy, and the Senators are just waking up to what they created. As you may not know, they don’t read the bills that they vote for, or only later realize the unintended Consequences of their actions. http://www.repealfatca.com/downloads/letter.pdf

I hope Wayne Swan can take some lessons from Canada’s Flaherty who isn’t just rolling over to the ridiculous and extra-territorial demands of the Yanks!

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Comment on Budget 2012: Survey results by Qiana Aguado

Qiana Aguado — Wed, 11 Jul 2012 22:42:37 +0000

Since when did dreaming about change receive such a narrow definition as counterfactual thinking? Surely all creative thinking and change management deals with some element of change? Does such an academic approach really help us take action towards or make for a better world?

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Comment on Arm’s length price in transfer pricing – a Canadian view by Becky Stremlow

Becky Stremlow — Mon, 25 Jun 2012 12:41:07 +0000

The easiest way is to look at the viewing angles, if they are above 178 degrees, the panel is most likely a S-PVA type.

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Comment on Strange case of Vodafone- Goose that lays no more by CCH Tax Chat » Blog Archive » Transfer pricing – ravages of retrospective legislation

Tue, 12 Jun 2012 00:39:24 +0000

[...] the Bill’s retrospectivity, a similar resentment is brewing in India. Following the decision in Vodafone the Government announced tightening the anti-avoidance and transfer pricing rules. Reports are [...]

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Comment on “Defriending” at Facebook, co-founder says good bye by Damian

Damian — Fri, 25 May 2012 22:28:13 +0000

Eduardo Saverin might not be too keen to leave the US anytime soon. Can you imagine the ‘special attention’ US customs would lavish upon him after learning how much potential tax revenue he took with him to Singapore?

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Comment on Budget 2012: Handicapping the speech by Nick

Nick — Tue, 08 May 2012 16:32:59 +0000

3 out of 5 isn’t bad.

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Comment on Tax break is no load of bull by Anton

Anton — Fri, 20 Apr 2012 00:25:52 +0000

What if this happens in Australia? Off the boats and onto to the pastures. Spare the knife and spoil the cattle. Unseen methane comes packed with carbon? But wait, deduction is available for carbon sink forests. That’s double whammy for the Revenue.

Enter Part IVA or should we wait for the coming reform of the anti-avoidance provisions? What’s the counterfactual here? Pack them off on a one way ride to tables of no return. Sure, tax benefit is hard to deny.

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