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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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In a report published yesterday, the Organisation for Economic Cooperation & Development (OECD) calls for an overhaul of international tax laws, including controversial transfer pricing rules, in an effort to stamp out corporate tax avoidance. The report addressed concerns from many quarters that global companies have opportunities to “profit shift” from high to low tax […]

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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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