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The Organization for Economic Co-operation and Development (OECD)

Treasury releases 2015 proposed revisions to U.S. Model Tax Convention

Treasury releases 2015 proposed revisions to U.S. Model Tax Convention

Treasury has released proposed updates to the U.S. Model Income Tax Convention (U.S. Model Treaty) in an effort to protect the U.S. tax base from base erosion and profits shifting (BEPS). The proposed updates address “exempt permanent establishments,” payment by “expatriated entities,” so-called “special tax regimes” that provide very low tax rates in certain countries, […]

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CRS reports on corporate tax base erosion and profit shifting

CRS reports on corporate tax base erosion and profit shifting

A recently released Congressional Research Service (CRS) Report finds that the magnitude of profit shifting—i.e., using tax planning strategies to avoid, delay, or reduce U.S. tax on income earned overseas—may be significant.It notes that American corporations are reported to be engaged in profit shifting with increasing frequency, including some of the most well known companies: […]

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OECD provides global standard for automatic exchange of financial account information

OECD provides global standard for automatic exchange of financial account information

OECD: Standard for Automatic Exchange of Financial Account Information The Organization for Economic Cooperation and Development (OECD) has released a global standard for automatic exchange of financial account information, including a Common Reporting and Due Diligence Standard (CRS) and a Model Competent Authority Agreement (CAA). The OECD said that the common standard is intended to […]

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OECD proposes changes to model tax convention to address treaty abuses

OECD proposes changes to model tax convention to address treaty abuses

Click here for the Organization for Economic Cooperation and Development’s Public Discussion Draft Titled “BEPS Action 6: Preventing the Granting of Treaty Benefits in Inappropriate Circumstances.” [Link Omitted] The Organization for Economic Cooperation and Development (OECD) has released a discussion draft following up on its action plan, published over the summer, to address base erosion […]

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OECD proposes global automatic exchange of tax information to boost compliance

OECD proposes global automatic exchange of tax information to boost compliance

Along with its Action Plan on Base Erosion and Profit Shifting, the Organization for Economic Cooperation and Development (OECD) called upon G20 finance ministers to support next steps in a clampdown on both company and individual tax avoidance. It presented them with a proposal to increase international tax cooperation and transparency through the automatic exchange […]

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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