In a crackdown on offshore accounts, the Internal Revenue Service has placed more focus on the disclosure of foreign accounts. In addition, the Foreign Account Tax Compliance Act went into effect in July and requires foreign financial institutions provide the agency information on U.S. taxpayer clients. A recently unsealed indictment […]
Burger King Worldwide Inc. is in talks to buy Canadian coffee-and-doughnut chain Tim Hortons Inc. in a move that would relocate the hamburger seller’s headquarters to Canada. The two are planning to create a new company. Should the deal be successful, the new entity will be the third-largest quick-service restaurant […]
Treasury Department officials are preparing an arsenal of administrative weapons for Secretary Jacob Lew to use in the government’s battle to prevent U.S. companies from reincorporating overseas in an effort to avoid paying federal taxes, otherwise known as tax inversion. Inversion, while complex, became popular because of its ability to […]
Most banks have some type of customer loyalty points program where you earn a certain number of points based on dollars charged each month. In some cases, the bank may offer a certain number of points for opening an account. When you convert the points into a new television or […]
While the U.S. maintains the highest corporate tax rate at 35 percent, a paper published earlier this month by University of Southern California law professor Edward Kleinbard, suggests many companies use a system of elaborate tax loopholes to avoid paying anywhere near that amount. Kleinbard’s work gained national recognition after […]
By Brown, PC of Brown, PC posted in Legislation on Tuesday, September 2, 2014. Samsung Electronics Co. is sitting on $60B in cash, that’s 58% larger than Apple’s cash pile, and the Korean tax man has sent a message to the country’s biggest company: “Use it or lose it.” The […]
As part of a recent settlement between Bank of America and the U.S. Department of Justice, almost seven billion dollars will be available to provide relief for homeowners struggling with “underwater” mortgages. Forgiveness of substantial mortgage debt could however lead to large tax bills in April just as these homeowners […]
Senate Democrats moved to discourage the use of inversion by outlining a proposal that would restrict the practice of earnings stripping, where U.S. companies borrow money from overseas parents and deduct the interest expense on U.S. taxes. The plan, outlined by Sen. Chuck Schumer (D., N.Y.), makes it clear that […]
Most of Wall Street was excited to hear Kinder Morgan Inc.’s $44 billion plan to consolidate its pipeline companies, however, some investors in the company’s master limited partnership may be left with huge, unexpected tax bills. Houston-based Kinder Morgan announced Sunday it would acquire three affiliated companies. Two of the […]
Lately, we have been following the corporate maneuvers designed to reduce U.S. corporate tax burdens. Unlike the recent Kinder Morgan move that will only affect some investors, inversion deals will bring broader unwelcome tax surprises for legacy investors. Medtronic’s acquisition of Covidien provides an example of how an inversion deal […]