Crackdown on Tax Treaty Abuses

Tax authorities throughout the world are cracking down on taxpayers – individuals and corporations – that utilize some aggressive tax planning strategies. While most of these schemes are perfectly legal and merely take advantage of loopholes in the international tax system, there is a growing concern that they not only...

Corporate Inversion – Assertive Tax Planning & Political Concerns

Our recent article published, The Corporate Inversion: From Obscure Strategy to Hot Trend addresses why many businesses and longstanding American icons have made the move towards corporate inversion, a tax reduction method of re-incorporating a company in another country if a significant portion of the company's income is derived from...

The Corporate Inversion: From Obscure Strategy to Hot Trend

Capitalist ideals of “free enterprise” and “competition” make great debate topics, but when compared to the business-friendly tax codes of other nations the United States Tax Code cannot compete. With the highest corporate income tax rate in the developed world, many businesses and longstanding American icons have made the move...

Tax Inversions: Tax Savings Strategies for Corporations and What Political Calls for Tax Reform Mean

Corporate inversion is defined as an international corporation reincorporating in a different country, changing from a U.S. corporation to an offshore jurisdiction that is usually a tax haven and therefore potentially reducing tax liability. U.S. Corporations have availed themselves to the policy and have reaped the rewards of lower tax...

Pursing a Claim for the Refund of a Penalty Paid Through an Offshore Voluntary Disclosure Program

Other Posts in this Series A History of the IRS’s Targeted Offshore Voluntary Disclosure Programs The IRS's Position Regarding Disclosures Made Outside a Targeted Voluntary Disclosure Program Part Four: Examining the Limitations a Closing Agreement Places on Tax Litigation OVDP Penalty Refund - Setting Aside the Closing Agreement on the...