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Germany

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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Lawful permanent resident couldn’t “informally” abandon his status to avoid U.S. tax

Lawful permanent resident couldn’t “informally” abandon his status to avoid U.S. tax

Gerd Topsnik, (2014) 143 TC No. 12 The Tax Court has held that an individual was a lawful permanent resident (LPR) – i.e., a resident alien taxable on his worldwide income – rejecting the individual’ss argument that he had “informally” abandoned his status as an LPR in prior years. Click here for the Opinion of […]

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Burger King has maneuvered to cut U.S. tax bill for years

Burger King has maneuvered to cut U.S. tax bill for years

LONDON (Reuters) – Burger King may have taken a lot of flack in the past week for a deal that should curb its U.S. tax bill but in many ways it is consistent with the burger chain’s aggressive tax-reduction strategies in recent years. Some U.S. lawmakers and other critics attacked the company that is the […]

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German rich and famous in taxman’s crosshairs

German rich and famous in taxman’s crosshairs

German rich and famous in taxman’s crosshairs as reported in the news. Many of Germany’s rich, powerful and famous have hit trouble recently, not because of drugs or sexual escapades, but because the taxman has found out about their Swiss bank accounts. A football legend, a feminist icon and several politicians have issued rueful apologies […]

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Special Report: How Germany’s taxman used stolen data to squeeze Switzerland

Special Report: How Germany’s taxman used stolen data to squeeze Switzerland

Special Report: How Germany’s taxman used stolen data to squeeze Switzerland. (Reuters) – In the digital age, pen and paper are useful tools for intrigue. In 2007, Sina Lapour, an assistant to a private banker at Credit Suisse, hand-copied the names of potential tax evaders listed on two of the firm’s internal computer systems. By […]

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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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Five Foreign Affiliates of Big Four Firms Cited for Flawed Audits

Five Foreign Affiliates of Big Four Firms Cited for Flawed Audits

The PCAOB released inspection reports for 23 accounting firms on October 3, 2013, and found problems at 13 of them. The reports included reviews of work done by Deloitte Touche Tohmatsu in Australia, Ernst & Young Inc. in South Africa, KPMG’s operations in India and the Netherlands, and PricewaterhouseCoopers in Germany and Papua New Guinea. […]

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Special Report – How a German tech giant trims its U.S. tax bill

Special Report – How a German tech giant trims its U.S. tax bill

As reported in the news in Reuters, “Special Report – How a German tech giant trims its U.S. tax bill – In July 2012,” then-U.S. Treasury Secretary Tim Geithner traveled to an island off the German coast to meet Wolfgang Schaeuble, Germany’s finance minister. Schaeuble was on vacation, but Geithner visited to discuss the euro […]

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Former Deutsche Bank Broker Sentenced In Manhattan Federal Court To 42 Months In Prison For Promoting Illegal Tax Shelters That Generated Billions Of Dollars In Fraudulent Tax Losses

Former Deutsche Bank Broker Sentenced In Manhattan Federal Court To 42 Months In Prison For Promoting Illegal Tax Shelters That Generated Billions Of Dollars In Fraudulent Tax Losses

The Department of Justice reported that David Parse, Former Deutsche Bank Broker, Was Sentenced In Manhattan Federal Court To 42 Months In Prison For Promoting Illegal Tax Shelters That Generated Billions Of Dollars In Fraudulent Tax Losses.  Here’s the Press Release. Preet Bharara, the United States Attorney for the Southern District of New York, and […]

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Commerzbank says cooperating on probe of ex-IRS examiner

Commerzbank says cooperating on probe of ex-IRS examiner

As reported in the news, Germany’s Commerzbank said it was cooperating with U.S. prosecutors in a case involving a bank employee charged with conflict-of-interest violations and exposing an Internal Revenue Service whistleblower. “The bank is fully cooperating with the authorities,” a Commerzbank spokeswoman in Germany said by telephone on Friday, declining to answer further questions. […]

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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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Member CA Bar Member Orange County Bar US Tax Court Attorney