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France

31 countries sign international agreement on country-by-country reporting, but not U.S.

31 countries sign international agreement on country-by-country reporting, but not U.S.

OECD press release (Jan. 27, 2015). On January 27, finance ministers and top officials from 31 countries — which didn’t include the U.S. — signed the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports (the Agreement), according to an OECD press release. This is the first signing ceremony for the Agreement to facilitate […]

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JPMorgan probed over role in French tax evasion case

JPMorgan probed over role in French tax evasion case

PARIS (Reuters) – U.S. bank JPMorgan Chase has been placed under formal investigation in France as part of a probe into alleged tax evasion by senior managers at investment firm Wendel, a court official said on Wednesday. A Paris-based spokesman for JPMorgan declined to comment on the move, part of a wider investigation in which […]

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Tax Court decides French social security taxes don’t qualify for foreign tax credit

Tax Court decides French social security taxes don’t qualify for foreign tax credit

In Eschel v. Commissioner, 142 T.C. No. 11 (2014), the Tax Court has held that U.S. citizens weren’t allowed a foreign tax credit under Code Sec. 901 for social security taxes paid to France while the taxpayers were working there for a non-American employer. The Court found that Sec. 317(b)(4) of the Social Security Amendments […]

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French Leader Would Reward Companies That Hire More People

French Leader Would Reward Companies That Hire More People

French Leader Would Reward Companies That Hire More People, as reported in the news. PARIS — President François Hollande, seeking to reduce France’s punishingly high unemployment rate, has called for a “responsibility pact” with businesses that would reward companies that hire more people with lower taxes and greater flexibility. “There is but one objective, one […]

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France will not tolerate tax avoidance

France will not tolerate tax avoidance

France will not tolerate tax avoidance, says Francois Hollande. French president Francois Hollande says that “everyone must be in the same competitive situation” as reported in the news. President Francois Hollande insisted France would not continue to tolerate the tax optimisation strategies used by multinational internet giants like Google. “This is not acceptable and that […]

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France cleared to impose controversial ‘millionaire tax’

France cleared to impose controversial ‘millionaire tax’

PARIS (Reuters) – France’s Constitutional Council gave the green light on Sunday to the government’s controversial ‘millionaire tax’, to be levied on companies that pay salaries of more than 1 million euros a year. The measure, introduced in line with a pledge by President Francois Hollande to make the rich do more to pull France […]

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UK Bribery Digest – Edition 2

UK Bribery Digest – Edition 2

Editor’s Note: I previously blogged on Ernst and Young Bribery Digest, finding some interesting cases. Here is Edition 2 of the UK Bribery Digest, along with some snippets. Deferred Prosecution Agreements (DPAs) The introduction of DPAs in the UK took a further step in October 2012 with the publication by the Ministry of Justice of […]

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U.S. Treasury signs pact with France for anti-tax evasion law

U.S. Treasury signs pact with France for anti-tax evasion law

WASHINGTON (Reuters) – The United States has signed an anti-tax evasion agreement with France, the 10th country to join a U.S. global dragnet that goes into effect next July, the U.S. Treasury said on Thursday. The Foreign Account Tax Compliance Act (FATCA), enacted in 2010, will from then require financial institutions abroad to disclose Americans’ […]

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Bankers’ lawsuit jeopardizes U.S. tax dodger crackdown

Bankers’ lawsuit jeopardizes U.S. tax dodger crackdown

WASHINGTON/NEW YORK (Reuters) – A court challenge by Texas and Florida bankers threatens to undermine a broad U.S. government crackdown on offshore tax avoidance and jeopardize a web of carefully crafted international agreements, tax lawyers said recently. The Texas Bankers Association and the Florida Bankers Association, both industry groups, have filed a lawsuit attempting to […]

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Special Report – How big techs stay offline on tax per OECD – the key is tax residency or permanent establishment

Special Report – How big techs stay offline on tax per OECD – the key is tax residency or permanent establishment

As reported in the news in Reuters, big business was having none of it. In January 2013, a lobby group which represents the largest corporations in the world wrote a letter to the body that drafts the rules on taxing multinationals. The letter focused on a small change to an obscure document, but one that […]

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Taxes on some wealthy French top 100 pct of income: paper

Taxes on some wealthy French top 100 pct of income: paper

As reported in the news, more than 8,000 French households’ tax bills topped 100 percent of their income last year, the business newspaper Les Echos reported, citing Finance Ministry data. The newspaper said that the exceptionally high level of taxation was due to a one-off levy last year on 2011 incomes for households with assets […]

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France, Germany tax evasion inquiries target Swiss banks UBS and Credit Suisse and their clients

France, Germany tax evasion inquiries target Swiss banks UBS and Credit Suisse and their clients

Editor’s Note:  what caught my eye is the following article from the LA Times regarding French and German authorities raiding the offices and homes of Credit Suisse and UBS bank officials and their wealthy customers as part of an investigation.  We previously blogged that Swiss Bankers are Afraid to Leave Switzerland – IRS and Department […]

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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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