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United Kingdom – England

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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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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UK lawmakers say Facebook may have broken tax rules

UK lawmakers say Facebook may have broken tax rules

LONDON (Reuters) – Facebook said it would ditch a corporate structure that helps minimise its UK tax bill, prompting lawmakers and campaigners to ask whether the arrangement had ever complied with UK tax rules. Facebook said on Friday it would stop booking sales to major UK clients via an Irish subsidiary and in future report […]

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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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Google to face grilling by UK lawmakers over tax deal

Google to face grilling by UK lawmakers over tax deal

LONDON (Reuters) – A British parliamentary committee will ask Google to testify about a back tax deal under which it will pay 130 million pounds ($185 million) to settle claims covering a 10-year period — an amount the opposition Labour party has described as derisory. Meg Hillier, the Labour party chairwoman of parliament’s Public Accounts […]

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Big insurers get key exemption in proposed British audit rules

Big insurers get key exemption in proposed British audit rules

LONDON (Reuters) – Britain’s biggest insurers will be exempt from having their most important indicator of financial health externally audited under proposals issued by the Bank of England on Friday. New European Union rules will require British-based insurance firms from January to meet a minimum solvency capital requirement, or SCR, to show they have enough funds […]

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Competent Authority Arrangements facilitate U.S.-U.K & Australia FATCA data exchange

Competent Authority Arrangements facilitate U.S.-U.K & Australia FATCA data exchange

IR 2015-108 To facilitate the exchange of Foreign Account Tax Compliance Act (FATCA) data under the intergovernmental agreements (IGAs) with Australia and the U.K., the U.S. Competent Authority has signed Competent Authority Arrangements (CAAs) with the Competent Authority of each country, announced IRS officials on September 24. The CAAs are the first of such arrangements […]

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Newly signed CAAs facilitate FATCA data exchange between U.S.-U.K & Australia

Newly signed CAAs facilitate FATCA data exchange between U.S.-U.K & Australia

IR 2015-108 To facilitate the exchange of Foreign Account Tax Compliance Act (FATCA) data under the intergovernmental agreements (IGAs) with Australia and the U.K., the U.S. Competent Authority has signed Competent Authority Arrangements (CAAs) with the Competent Authority of each country, announced IRS officials on September 24. The CAAs are the first of such arrangements […]

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Coca-Cola bottling deal targets irksome tax hiccup

Coca-Cola bottling deal targets irksome tax hiccup

LONDON (Reuters Breakingviews) – What could be more American than Coca-Cola? A 35 percent corporation tax rate, for starters. That might no longer be a problem for one of the U.S. drinks giant’s biggest bottling groups, if a planned three-way merger, which mixes cost savings with tax-efficient goodness, comes to pass. Coca-Cola Enterprises, which pours, […]

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Payment was dividend, so “withholding tax” rule meant no foreign tax credit

Payment was dividend, so “withholding tax” rule meant no foreign tax credit

Lehman Brothers Holdings, Inc., (DC NY 5/08/2015) 115 AFTR 2d ¶ 2015-731   A district court has ruled that, under the U.S. treaty with the United Kingdom (U.K.), a payment received by a U.S. subsidiary of Lehman Brothers (Lehman) from a U.K. Lehman subsidiary was a dividend. As a result, the Code Sec. 901(k)(1)(A)(ii) “withholding […]

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UK May Follow U.S. Lead If Pursues HSBC Over Tax

UK May Follow U.S. Lead If Pursues HSBC Over Tax

LONDON (Reuters) – British authorities may follow a trail set by their U.S. counterparts in investigating allegations that HSBC’s Swiss private bank helped its customers dodge taxes, lawyers say. Any prosecution against the bank or individuals could hinge on whether HSBC’s Swiss private banking unit sent staff to the UK and advised clients on how […]

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Britain targets multinationals that try to dodge taxes

Britain targets multinationals that try to dodge taxes

LONDON, Dec 3 (Reuters) – Britain plans to introduce a tax to target multinationals such as Google Inc and Amazon Inc accused of using complex accounting schemes to cut their payments on earnings in the country. Governments around the world are trying to overhaul international tax treaties to stop big corporates siphoning off profits into […]

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Bits ‘n Pieces – London mayor is poster boy for expat woes; House approves $42 billion tax break package; Gas tax – time for change?; House approves tax credit for wind energy; Britain and the Google tax

Bits ‘n Pieces – London mayor is poster boy for expat woes; House approves $42 billion tax break package; Gas tax – time for change?; House approves tax credit for wind energy; Britain and the Google tax

* London mayor is poster boy for expat tax woes. By Laura Saunders – The Wall Street Journal. Boris Johnson’s case is a perfect illustration of the dilemmas faced by many of the 7.6 million U.S. citizens living abroad as a result of U.S. authorities’ five-year campaign against secret offshore accounts. Link to The Wall […]

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Boris Should Pay Up But Not Shut Up Over U.S. Tax

Boris Should Pay Up But Not Shut Up Over U.S. Tax

LONDON (Reuters Breakingviews) – Boris Johnson has a point about his U.S. tax bill, but he should still cough up. The London mayor objects to the fact that his dual UK and U.S. citizenship means he has been issued with an American tax bill, and he says he won’t pay. Though many U.S. expats will […]

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Delphi to contest pressure to file U.S. taxes despite UK tax base

Delphi to contest pressure to file U.S. taxes despite UK tax base

(Reuters) – Auto parts supplier Delphi Automotive Plc said it would “vigorously contest” pressure by U.S. tax authorities to file taxes in the United States as a domestic company, when its tax base is in the UK. Delphi, which operates out of Detroit, is one among several American companies locked in a battle with the […]

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Nine Charged in Conspiracy to Steal Millions of Dollars Using “Zeus” Malware

Nine Charged in Conspiracy to Steal Millions of Dollars Using “Zeus” Malware

As reported by the DOJ, nine alleged members of a wide-ranging racketeering enterprise and conspiracy who infected thousands of business computers with malicious software known as “Zeus” have been charged in an indictment unsealed today in Lincoln, Neb. Acting Assistant Attorney General David A. O’Neil of the Justice Department’s Criminal Division, U.S. Attorney Deborah R. […]

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Starbucks to move European base to London, pay more UK tax

Starbucks to move European base to London, pay more UK tax

We previously blogged on this twice – Special Report – How Starbucks avoids UK taxes, and in Starbucks agrees to pay millions in British corporation taxes.  As reported in the news, Starbucks Corp will move its European headquarters to London from the Netherlands this year and pay more tax in the UK as a result, […]

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UK court ruling may prompt more scrutiny of Amazon tax plans

UK court ruling may prompt more scrutiny of Amazon tax plans

LONDON (Reuters) – Amazon’s tax affairs could come under more scrutiny in Britain, tax experts said, after a judge questioned whether it really was organized in the tax efficient way it said it was. The ruling comes as big technology groups, including Amazon, face increasing scrutiny in Britain over their tax practices. A UK judge […]

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Fiat moving tax base to UK to woo U.S. investors-chairman tells paper

Fiat moving tax base to UK to woo U.S. investors-chairman tells paper

MILAN (Reuters) – Fiat wants to establish the tax domicile of the new Fiat Chrysler Automobiles group in the United Kingdom to help woo American investors, the Italian car maker’s chairman told Italian daily La Stampa in an interview published on Thursday. The Turin-based car maker, which this month bought out the minority investor in […]

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The Great British tax giveaway – – mind the gap, . . .

The Great British tax giveaway – – mind the gap, . . .

LONDON (Reuters) – When Neil Withington, the legal director of British American Tobacco (BAT) and the firm’s largest British shareholder, files his next tax return, he will receive a little help from the state. Like every other UK taxpayer, he will be entitled to a tax credit on any dividend payment he receives. He can […]

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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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