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Foreign Income

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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EU rules Starbucks, Fiat tax deals illegal, rocking system

EU rules Starbucks, Fiat tax deals illegal, rocking system

BRUSSELS (Reuters) – The European Commission ruled on Wednesday that Starbucks Corp and Fiat Chrysler Automobiles NV benefited from illegal tax deals with the Dutch and Luxembourg authorities, dealing a heavy blow to profit-shielding arrangements used by many multinationals. Antitrust commissioner Margrethe Vestager said all firms must pay a “fair share” and ordered the Netherlands […]

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Big U.S. firms hold $2.1 trillion overseas to avoid taxes

Big U.S. firms hold $2.1 trillion overseas to avoid taxes

WASHINGTON (Reuters) – The 500 largest American companies hold more than $2.1 trillion in accumulated profits offshore to avoid U.S. taxes and would collectively owe an estimated $620 billion in U.S. taxes if they repatriated the funds, according to a study released on Tuesday. The study, by two left-leaning non-profit groups, found that nearly three-quarters […]

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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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U.S. manufacturer subject to multiple agency investigations over Swiss tax strategy

U.S. manufacturer subject to multiple agency investigations over Swiss tax strategy

In a form filed with the Securities and Exchange Commission (SEC), Caterpillar Inc., which last year was the subject of a Senate hearing on multinationals shifting profits out of the U.S., revealed that numerous investigations by the Justice Department, IRS, and SEC were ongoing with respect to its tax strategies and overall business structure.According to […]

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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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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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SOI Bulletin reports more high-income returns & growth in U.S. taxpayers’ foreign income

SOI Bulletin reports more high-income returns & growth in U.S. taxpayers’ foreign income

IR 2014-69 Click here for the text of Spring 2014 Statistics of Income Bulletin. IRS has released the Spring 2014 issue of the Statistics of Income (SOI) Bulletin, which contains four detailed articles on tax matters pertaining to the 2011 tax year. The Spring 2014 SOI provides analysis on, among other things, the increase in […]

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IRS issues long-awaited Instructions for FATCA form for entities, Form W-8BEN-E

IRS issues long-awaited Instructions for FATCA form for entities, Form W-8BEN-E

IRS has released the long-awaited Instructions to Form W-8BEN-E (June 2014), Certificate of Status of Beneficial Owner for United States Tax Withholding and Reporting (Entities). This form is used exclusively by entities to document their status both as a payee under chapter 4 and a beneficial owner under chapter 3 of the Code, and to […]

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IRS issues Instructions for Form 8966, FATCA Report

IRS issues Instructions for Form 8966, FATCA Report

IRS has released Instructions for Form 8966, FATCA Report, which is used to report information with respect to certain U.S. accounts, substantial U.S. owners of passive non-financial foreign entities (NFFEs), U.S. accounts held by owner-documented foreign financial institutions (FFIs), and certain other accounts based on the filer’s chapter 4 status. For calendar years 2015 and […]

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Credit Suisse nears $2.5 billion deal to end U.S. Tax-Evasion Probe

Credit Suisse nears $2.5 billion deal to end U.S. Tax-Evasion Probe

(Reuters) – Credit Suisse Group AG is expected to plead guilty and pay more than $2.5 billion to U.S. authorities to resolve charges that the Swiss bank helped Americans evade U.S. taxes, people familiar with the discussions said on Thursday. Under the terms being discussed, about $2 billion would go to federal authorities, mainly the […]

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Foreign banks get transition period on U.S. tax evasion law

Foreign banks get transition period on U.S. tax evasion law

(Reuters) – The U.S. Treasury Department said on Friday that the Internal Revenue Service (IRS) this year and next will take into account “good faith efforts” by foreign banks to comply with a new U.S. anti-tax evasion law set to take effect on July 1. The Foreign Account Tax Compliance Act (FATCA), approved in 2010, […]

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IRS Tax Tip 2014-43: Tips for U.S. Taxpayers with Foreign Income

IRS Tax Tip 2014-43:  Tips for U.S. Taxpayers with Foreign Income

Did you live or work abroad or receive income from foreign sources in 2013? If you are a U.S. citizen or resident, you must report income from all sources within and outside of the U.S. The rules for filing income tax returns are generally the same whether you’re living in the U.S. or abroad. Here […]

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Prada owners under investigation for tax avoidance – sources

Prada owners under investigation for tax avoidance – sources

Prada owners under investigation for tax avoidance – sources, as reported in the news in Reuters. MILAN (Reuters) – Italian fashion designer Miuccia Prada and her husband, Prada chief executive and fellow shareholder Patrizio Bertelli, are under investigation as part of a tax avoidance probe by Milan prosecutors, three investigative sources told Reuters on Friday. […]

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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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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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2014: IRS Voluntary Disclosure – Option #2 – Participate “Somewhat” But Not Completely: Options for Taxpayers Contemplating the Program

2014:  IRS Voluntary Disclosure – Option #2 – Participate “Somewhat” But Not Completely:  Options for Taxpayers Contemplating the Program

NOTE: JUNE 18, 2014 – – The IRS came out with NEW and REVISED Rules and Procedures for the Offshore Voluntary Disclosure Program and the Streamlined Compliance Filing Procedures. Here are the links to two articles which are MUST reads: 1. 2014 – New IRS Offshore Voluntary Disclosure Program (OVDP), Amnesty, and Streamlined Compliance Filing […]

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2014: Last chance to enter into IRS “amnesty” program, Offshore Voluntary Disclosure Program?

2014: Last chance to enter into IRS “amnesty” program, Offshore Voluntary Disclosure Program?

NOTE: JUNE 18, 2014 – – The IRS came out with NEW and REVISED Rules and Procedures for the Offshore Voluntary Disclosure Program and the Streamlined Compliance Filing Procedures. Here are the links to two articles which are MUST reads: 1. 2014 – New IRS Offshore Voluntary Disclosure Program (OVDP), Amnesty, and Streamlined Compliance Filing […]

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Foreign Recipients of US Income Study, 2011 Tax Year

Foreign Recipients of US Income Study, 2011 Tax Year

Two tables presenting data for Tax Year 2011 from Form 1042-S, Foreign Person’s U.S. Source Income Subject to Withholding, are now available here. The tables include statistics for the number of returns, total income, tax withheld, income subject to withholding, income exempt from withholding, and income by category. Data are available by selected countries and […]

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Cayman Islands, Costa Rica sign tax pacts with U.S

Cayman Islands, Costa Rica sign tax pacts with U.S

WASHINGTON (Reuters) – The United States has signed agreements with the Cayman Islands and Costa Rica to help those countries’ banks comply with an anti-tax evasion law starting next year, the Treasury Department said on Friday. The deals are part of the U.S. effort to enforce the Foreign Account Tax Compliance Act (FATCA), enacted in […]

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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