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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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U.S. Senate panel approves eight international tax treaties

U.S. Senate panel approves eight international tax treaties

WASHINGTON (Reuters) – The U.S. Senate Foreign Relations Committee on Tuesday approved eight long-delayed international tax treaties, which had been held up for years because of one Republican senator’s objections, despite support from companies that want consistency in rules for how to do international business. The treaties are with Switzerland, Luxembourg, Hungary, Chile, Spain, Poland […]

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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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Spanish bank gets partial win in STARS tax shelter fight

Spanish bank gets partial win in STARS tax shelter fight

As reported in Reuters – Banco Santander won a partial victory in a $234 million tax refund fight with the U.S. Internal Revenue Service over controversial tax shelters known as STARS when a Massachusetts district court ruled in favor of the Spanish bank. In several cases against banks with hundreds of millions of dollars at […]

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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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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