Tax Havens And Their Use By United States Taxpayers An Overview
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Author : Richard A. Gordon Publisher : The Minerva Group, Inc. Page : 277 pages File Size : 48,9 Mb Release : 2002-08 Category : Tax exemption ISBN : 9780894991370
Tax Havens and Their Use by United States Taxpayers - An Overview by Richard A. Gordon Pdf
This book was written at the request of the Commissioner of Internal Revenue, The Assistant Attorney General (Tax Division), and the Assistant Secretary of the Treasury (Tax Policy).The purpose of this book was to develop an overview of tax havens and the use of tax havens by United States taxpayers. The study sought to determine the frequency and nature of tax haven transactions, identify specific types of tax haven transactions, obtain a description of the United States and foreign legal and regulatory environment in which tax haven transactions are conducted, describe Internal Revenue Service and Justice Department efforts to deal with tax haven related transactions, and to identify interagency coordination problems.The findings are based on a review of judicial decisions and published literature in the field of international tax planning, research into internal IRS documents concerning taxpayer activities, interviews with IRS personnel, personnel who deal with tax haven issues for other Federal government agencies, and lawyers and certified public accountants who specialize in international taxation. The findings are also based on a statistical analysis of available data concerning international banking, United States direct investment abroad, and foreign investment in the United States. While the findings did not uncover all the methods employed to use tax havens, the belief is that the inquiry was extensive enough to give an understanding of the situation and to enable the IRS to develop options which might be useful in improving the administration of the tax laws as they apply to tax havens
Tax Havens and Their Use by United States Taxpayers by Richard A. Gordon Pdf
Overview of tax havens and the use of tax havens by US taxpayers. The study sought to determine the frequency and nature of tax haven transactions, identify specific types of tax haven transactions, obtain a description of the US and foreign legal and regulatory environment in which tax haven transactions are conducted, describe the IRS and Justice Department efforts to deal with tax haven related transactions, and to identify interagency coordination problems.
Tax Havens and Their Use by United States Taxpayers by Richard A. Gordon Pdf
Excerpt from Tax Havens and Their Use by United States Taxpayers: An Overview; A Report to the Commissioner of Internal Revenue, the Assistant Attorney General (Tax Division) And the Assistant Secretary of the Treasury (Tax Policy) This study was undertaken at the request of the Commissioner of Internal Revenue, the Assistant Attorney General (tax Division), and the Assistant Secretary of the Treasury (tax Policy). The purpose of the study was to develop an overview of tax havens and the use of tax havens by United States taxpayers. The study sought to determine the frequency and nature of tax haven transactions, identify specific types of tax haven transactions, obtain a description of the united States and foreign legal and regulatory environment in which tax haven transactions are conducted, describe Internal Revenue Service and Justice Department efforts to deal with tax haven related transactions, and to identify interagency coordination problems. Our findings are based on a review of judicial decisions and published literature in the field of international tax planning, research into internal irs documents concerning taxpayer activities, interviews with irs personnel, personnel who deal with tax haven issues for other Federal government agencies, and lawyers and certified public accountants who specialize in international taxation. Our findings are also based on a statistical analysis of available data concerning international banking, United States direct investment abroad, and foreign investment in the United States. While we cannot claim that we uncovered all of the methods employed to use tax havens, we believe that our inquiry was extensive enough to give us an understanding of the situation and to enable us to develop options which might be useful in improving the administration of the tax laws as they apply to tax havens. About the Publisher Forgotten Books publishes hundreds of thousands of rare and classic books. Find more at www.forgottenbooks.com This book is a reproduction of an important historical work. Forgotten Books uses state-of-the-art technology to digitally reconstruct the work, preserving the original format whilst repairing imperfections present in the aged copy. In rare cases, an imperfection in the original, such as a blemish or missing page, may be replicated in our edition. We do, however, repair the vast majority of imperfections successfully; any imperfections that remain are intentionally left to preserve the state of such historical works.
Richard A. Gordon,United States Internal Revenue Service
Author : Richard A. Gordon,United States Internal Revenue Service Publisher : Legare Street Press Page : 0 pages File Size : 48,6 Mb Release : 2022-10-27 Category : Business & Economics ISBN : 1017043361
Tax Havens and Their Use by United States Taxpayers: An Overview: a Report to the Commissioner of Internal Revenue, the Assistant Attorney General (Ta by Richard A. Gordon,United States Internal Revenue Service Pdf
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Tax Havens and Their Use by United States Taxpayers by Richard a Gordon,United States Internal Revenue Service Pdf
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This report discusses the State of the Union address, which is a communication between the President and Congress in which the chief executive reports on the current conditions of the United States and provides policy proposals for the upcoming legislative year.
Tax Havens by Congressional Research Congressional Research Service Pdf
Addressing tax evasion and avoidance through use of tax havens has been the subject of a number of proposals in Congress and by the President. Actions by the Organization for Economic Cooperation and Development (OECD) and the G-20 industrialized nations also have addressed this issue. In the 111th Congress, the HIRE Act (P.L. 111-147) included several anti-evasion provisions, and P.L. 111-226 included foreign tax credit provisions directed at perceived abuses by U.S. multinationals. Numerous legislative proposals to address both individual tax evasion and corporate tax avoidance have been advanced. Multinational firms can artificially shift profits from high-tax to low-tax jurisdictions using a variety of techniques, such as shifting debt to high-tax jurisdictions. Because tax on the income of foreign subsidiaries (except for certain passive income) is deferred until income is repatriated (paid to the U.S. parent as a dividend), this income can avoid current U.S. taxes, perhaps indefinitely. The taxation of passive income (called Subpart F income) has been reduced, perhaps significantly, through the use of hybrid entities that are treated differently in different jurisdictions. The use of hybrid entities was greatly expanded by a new regulation (termed check-the-box) introduced in the late 1990s that had unintended consequences for foreign firms. In addition, earnings from income that is taxed often can be shielded by foreign tax credits on other income. On average, very little tax is paid on the foreign source income of U.S. firms. Ample evidence of a significant amount of profit shifting exists, but the revenue cost estimates vary substantially. Evidence also indicates a significant increase in corporate profit shifting over the past several years. Recent estimates suggest losses that may approach, or even exceed, $100 billion per year. Individuals can evade taxes on passive income, such as interest, dividends, and capital gains, by not reporting income earned abroad. In addition, because interest paid to foreign recipients is not taxed, individuals can evade taxes on U.S. source income by setting up shell corporations and trusts in foreign haven countries to channel funds into foreign jurisdictions. There is no general third-party reporting of income as is the case for ordinary passive income earned domestically; the Internal Revenue Service (IRS) relies on qualified intermediaries (QIs). In the past, these institutions certified nationality without revealing the beneficial owners. Estimates of the cost of individual evasion have ranged from $40 billion to $70 billion. The Foreign Account Tax Compliance Act (FATCA; included in the HIRE Act, P.L. 111-147) introduced required information reporting by foreign financial intermediaries and withholding of tax if information is not provided. These provisions became effective only recently, and their consequences are not yet known. Most provisions to address profit shifting by multinational firms would involve changing the tax law: repealing or limiting deferral, limiting the ability of the foreign tax credit to offset income, addressing check-the-box, or even formula apportionment. President Obama's proposals include a proposal to disallow overall deductions and foreign tax credits for deferred income, along with a number of other restrictions. Changes in the law or anti-abuse provisions have also been introduced in broader tax reform proposals. Provisions to address individual evasion include increased information reporting and provisions to increase enforcement, such as shifting the burden of proof to the taxpayer, increased penalties, and increased resources. Individual tax evasion is the main target of the HIRE Act, the proposed Stop Tax Haven Abuse Act, and some other proposals.
Tax Havens and Their Use by United States Taxpayers by Richard A. Gordon Pdf
Overview of tax havens and the use of tax havens by US taxpayers. The study sought to determine the frequency and nature of tax haven transactions, identify specific types of tax haven transactions, obtain a description of the US and foreign legal and regulatory environment in which tax haven transactions are conducted, describe the IRS and Justice Department efforts to deal with tax haven related transactions, and to identify interagency coordination problems.
Tax Evasion and Tax Havens since the Nineteenth Century by Sébastien Guex,Hadrien Buclin Pdf
This collective book offers a panorama of the history of tax evasion, tax avoidance and tax havens from the nineteenth century to the present day, based on the latest research in contemporary history. It aims to show that this phenomenon is at the heart of global capitalism, partly as a response of the ruling classes to the rise of progressive taxation, but for other reasons too: notably the development of a powerful tax evasion and avoidance industry in different countries. The book argues that tax competition between states has stimulated the development of tax havens. It discusses the notion of the ‘tax haven’ and proposes a more rigorous concept - that of the ‘tax predator’. Finally, the book sheds light on the socio-political conflicts that have developed around tax evasion and the way in which states have fought against or tolerated the phenomenon.
This book provides information on an issue of critical importance to tax administration in this country; the practice of sheltering U.S. earned income in foreign jurisdictions as a means of avoiding U.S. taxation. Each year, the United States loses an estimated $100 billion in tax revenues due to offshore tax abuses. Offshore tax havens today hold trillions of dollars in assets provided by citizens of other countries, including the United States. A related issue is the extent to which financial institutions in tax havens may be facilitating international tax evasion. About 50 tax havens operate in the world today with their twin hallmarks being secrecy and tax avoidance. Billions and billions of dollars worth of U.S. assets find their way into these secrecy tax havens, aided by banks, trust companies, accountants, lawyers, and from offshore tax abuses. This book discusses such sources of tax havens, as well as the steps that the IRS has taken to alleviate this problem.
Tax Haven Banks and U.S. Tax Compliance by United States. Congress. Senate. Committee on Homeland Security and Governmental Affairs. Permanent Subcommittee on Investigations Pdf
