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The Court of Appeal has now confirmed the decision of the Upper Tier Tribunal in Anson –v- HMRC, a case dealing with the issue of whether a Delaware Limited Liability Company was tax transparent or not. Mr Anson was a member of a Delaware LLC which carried on business in the US. Since a Delaware […]

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The courts of most countries have long accepted that taxpayers have the right to arrange their financial affairs in such as manner as to use tax legislation to reduce the amount of tax that is payable by means that are within the law. For centuries the mantra “evasion is illegal but avoidance is not” has been […]

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Tax evasion is the illegal evasion of any type of tax or duty (so it includes smuggling) by individuals, companies, trusts or other corporate entities. Typically evasion occurs when taxpayers deliberately misrepresent the true state of their affairs to the tax authorities to reduce their tax liability and includes dishonest tax reporting, such as declaring less income, profits […]

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Having agreed to a tax deal with the UK recently, Liechtenstein is now co-operatingwith the US Treasury – mainly to avoid legal action against local banks – by agreeing to a so-called “group request” identifying their US clients. Liechtenstein’s traditional secrecy started to unwind after data stolen from LGT (the bank owned by Liechtenstein’s royal family) […]

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Swiss Finance Minister, Eveline Widmer-Schlumpf, claims that the US government is keen to end the long running dispute over wealthy Americans with undeclared Swiss bank accounts before the upcoming US presidential election. Currently eleven Swiss banks are under investigation by the United States accused of aiding US citizens evade their taxes. But the Swiss want the investigations to be […]

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The US Treasury has announced that as part of the crack down on American tax evasion it intends to have signed agreements with five European Union (“EU”) countries by the end of June 2012. The agreements will implement the Foreign Account Tax Compliance Act (“FATCA”) and the spokesman also said that the Treasury hoped to announce agreements […]

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One of the reasons that you won’t often find me commenting on US tax issues is that the US government have a lot of very nasty laws that they are prepared to use on anyone they think might be encouraging their citizens to evade or even just avoid tax – even though tax avoidance is […]

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