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Foreign Countries

Companies put $221 billion into low-tax jurisdictions in 2015 – U.N.

Companies put $221 billion into low-tax jurisdictions in 2015 – U.N.

GENEVA (Reuters) – Companies put $221 billion into countries with low tax last year, chiefly Luxembourg and the Netherlands, while $72 billion of investment went into two British tax havens – the British Virgin Islands and Cayman Islands, the U.N. said on Tuesday. However, they took billions out of Luxembourg and the Netherlands in the final […]

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Court clarifies definition of term used in foreign document request rules

Court clarifies definition of term used in foreign document request rules

LaRue, (DC OR 4/13/2016) 117 AFTR 2d ¶ 2016-624 A district court has concluded that the term “foreign-based documents,” which is used in the rules that govern IRS’s ability to obtain documents under the foreign document request rules, means documents held outside the U.S. and copies of those documents that are held in the U.S. […]

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Accountants, journalist face tax leaks trial in Luxembourg

Accountants, journalist face tax leaks trial in Luxembourg

LUXEMBOURG (Reuters) – Two former employees of accountancy giant PwC go on trial in Luxembourg on Tuesday along with a French journalist, accused of leaking details of corporate tax deals that have fuelled global demands for reform. The case, coming 18 months after revelations dubbed LuxLeaks sparked accusations the Grand Duchy conspired with multinational companies to deprive […]

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Employers in Two States & Virgin Islands Could Pay Higher FUTA Rates in 2016

Employers in Two States & Virgin Islands Could Pay Higher FUTA Rates in 2016

California, Ohio, and the Virgin Islands have outstanding federal unemployment loan balances as of Mar. 28, 2016. Employers in these jurisdictions will pay 2016 federal unemployment tax (FUTA) at a higher rate than employers in other areas if the loans are not repaid by Nov. 10, 2016. Background. Employers pay FUTA tax at a rate of 6.0% […]

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IMF, World Bank, UN, OECD form new group to stop tax erosion

IMF, World Bank, UN, OECD form new group to stop tax erosion

WASHINGTON (Reuters) – The International Monetary Fund and the World Bank said on Tuesday they are joining forces with other international organizations to cooperate on tax issues and develop new tools and standards to halt tax base erosion and evasion. The new grouping, which will also include the United Nations and the Organization for Economic […]

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District Court strikes down Puerto Rico’s corporate AMT aimed at Wal-Mart PR

District Court strikes down Puerto Rico’s corporate AMT aimed at Wal-Mart PR

Wal-Mart Puerto Rico, Inc. v. Zaragoza-Gomez, (DC PR 3/28/2016) Civil No. 3:15-CV-03018 (JAF). A U.S. district court has held that certain parts of Puerto Rico’s corporate alternative minimum tax (AMT) regime are unconstitutional and has granted Walmart’s Puerto Rico corporation an injunction to stop its collection. The court characterized the cash-strapped legislature’s increase in the maximum […]

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Editor in Panama Papers says published in the public interest

Editor in Panama Papers says published in the public interest

BERLIN (Reuters) – The editor of the German newspaper that broke the Panama Papers story said on Mondayhe did not know exactly where his team’s source got the information but defended his decision to publish on the basis of the public interest. Wolfgang Krach, co-editor-in-chief of the Sueddeutsche Zeitung, said a source who introduced themselves as […]

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In 1950s Panama diner, glum offshore lawyers count cost of leak

In 1950s Panama diner, glum offshore lawyers count cost of leak

PANAMA CITY (Reuters) – Aghast at the biggest offshore scandal in memory, lawyers, businessmen and politicians flock to one of their favorite haunts, a diner opened in the 1950s nestled between Panama City’s financial and historic quarters, to swap notes. Given the reports from the “Panama Papers” jolting colleagues at shell company specialist Mossack Fonseca, […]

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IRS adds three countries to list of countries with which it exchanges certain tax data

IRS adds three countries to list of countries with which it exchanges certain tax data

Rev Proc 2016-18, 2016-16 IRB In a Revenue Procedure, IRS has updated the list of countries with which Treasury and IRS have determined that it is appropriate to have an automatic exchange relationship under Reg. § 1.6049-8(a) and Reg. § 1.6049-4(b)(5), which require the reporting of certain deposit interest aggregating $10 or more paid to […]

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U.S. Supreme Court wrestles with Puerto Rico restructuring case

U.S. Supreme Court wrestles with Puerto Rico restructuring case

Liberal justices on Tuesday signaled support for Puerto Rico as the U.S. Supreme Court considered whether to revive a law that could let the U.S. territory cut billions of dollars owed in debt at some public agencies, a key test in the island’s efforts to weather a huge fiscal crisis. It was unclear how the court will […]

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Residency and presence tests for 2015 foreign income/housing exclusions waived for Burundi

Residency and presence tests for 2015 foreign income/housing exclusions waived for Burundi

Rev Proc 2016-21, 2016-14 IRB In a Revenue Procedure, IRS has waived the residency and presence tests that apply for purposes of the Code Sec. 911 foreign earned income and foreign housing cost exclusions with respect to certain U.S. individuals in Burundi due to adverse conditions in that country beginning on May 14, 2015. Background. Code […]

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5 Ways to Sample Americana in Havana

5 Ways to Sample Americana in Havana

As reported in the LA Times, and as originally reported in the NY Times: How to sample Americana in Havana. Every American dashing to Cuba these days seems to share a goal: to see the island “before we ruin it.” But Havana, the city that awaits a historic visit by President Obama and his family next week, owes […]

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36 Hours in Havana

36 Hours in Havana

As reported in the NY Times, 36 Hours in Havana. Havana is no longer frozen in time, at least not completely. With Cuba’s guarded openness to private enterprise grabbing hold, classic American cars and salsa singers now share the cityscape with new and inventive offerings in food, culture, night life and hospitality. No other city […]

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Innovation boxes and their potential role in international tax reform

Innovation boxes and their potential role in international tax reform

“Encouraging Innovation and the Role of Tax Policy,” Remarks by Jason Furman, Chairman, Council of Economic Advisers. “An Innovation Box Would be a Bad Innovation for American Tax Policy,” Treasury Notes post by Mark Mazur, Assistant Secretary of Tax Policy. So-called “innovation boxes” — essentially, preferential tax regimes for income derived from intellectual property (IP) […]

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Diplo and Major Lazer Bring Their Brand of Music to Cuba

Diplo and Major Lazer Bring Their Brand of Music to Cuba

As reported in the NY Times, Diplo and Major Lazer bring their brand of music to Cuba. HAVANA — “I know you’ve been waiting a long time for a party like this,” the D.J. and producer Diplo called out to a sea of pulsating young Cubans here on Sunday evening, during a free concert by […]

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U.S. Justice Dept reviewing Panama documents

U.S. Justice Dept reviewing Panama documents

WASHINGTON (Reuters) – The U.S. Justice Department is reviewing the leaked documents from a Panamanian law firm that reveal the offshore financial arrangements of global politicians and public figures, a department spokesman said on Monday. The department is determining whether the documents point to evidence of corruption and other violations of U.S. law. “The U.S. […]

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Another First for Cuba: A Concert by the Rolling Stones

Another First for Cuba: A Concert by the Rolling Stones

As reported in the NY Times:  Another first for Cuba: a concert by the Rolling Stones. HAVANA — Five decades after his music was banned in this Communist country, Mick Jagger stood — and sang, jumped and performed his signature dance moves — before hundreds of thousands of adoring fans Friday night in Cuba and […]

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U.S. companies line up to do business in Cuba

U.S. companies line up to do business in Cuba

As reported in the news of the LA Times, in Cuba, a business gold rush builds. Chris Rosander was touring a mango grove in Cuba last year with a group of U.S. agriculture leaders when he had a revelation: “Why don’t we import mangoes from Cuba?” Sun-Maid Growers, the California dried fruit company where he […]

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U.S. charges consultant to Iran’s UN mission-hearing

U.S. charges consultant to Iran’s UN mission-hearing

NEW YORK (Reuters) – U.S. prosecutors on Wednesday unveiled criminal charges at a Brooklyn, New York, court hearing against a consultant to the Iranian mission to the United Nations. Ahmad Sheikhzadeh, 60, is accused of charges related to sanctions violations, money laundering and tax matters, his lawyer, Steve Zissou, said at the hearing. Sheikhzadeh had pleaded not […]

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UK sugary drink tax could be sweet for food ingredient suppliers

UK sugary drink tax could be sweet for food ingredient suppliers

LONDON (Reuters) – The British government’s planned levy on sugary soft drinks means more business for suppliers of specialty ingredients that boost sweetness without adding calories and can mask aftertastes or add texture. The surprise levy announced on Wednesday would go into effect in two years. That gives manufacturers including Coca-Cola or PepsiCo and their UK partners such […]

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Meet Paul Raymond

Meet Paul Raymond

Mr. Raymond is a sought after speaker in tax controversy law by many attorney, accountant, and business groups and at the request of the Internal Revenue Service, has presented programs at the IRS Nationwide Tax Forum, attended by tax professionals throughout the United States.

Additionally, he continues to be an active member in the Section of Taxation, American Bar Association, where he was the Past Chair of the Employment Taxes Committee.

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Member CA Bar Member Orange County Bar US Tax Court Attorney