The international business community has witnessed an increase
in US tax enforcement activity arising from individual
whistleblower claims filed with the US Internal Revenue Service.
One such instance recently came to light in press reports about a
former employee of LGT bank in Liechtenstein who sold information
to the IRS and other tax authorities purporting to reveal the names
of hundreds of taxpayers with previously undisclosed assets. While
the issue of the disclosures made of LGT account holders has been
public for some weeks, the new information is that this individual
is represented by a US lawyer and is seeking a reward under an
enhanced IRS whistleblower program that will pay substantial
amounts, potentially millions, to informants who provide
information that leads to the collection of US tax, penalties and
other amounts.
The Liechtenstein matter is not an isolated event....
Specific Questions relating to this article should be addressed directly to the author.
For many years there has been a debate as to whether a company can incur a cost in relation to the acquisition of an asset or the incurral of operating expenditure, where it pays the supplier by issuing its own shares.
The ATO Compliance Program for 2010-11 released earlier this month identifies a focus on globally mobile executives and other highly paid individuals. This focus, in the context of recent significant legislative changes in the areas of foreign employment income and employee share schemes, creates significant risks for those individuals identified and their employers. Now is the time to undertake a compliance review and get the house in order before the ATO comes knocking at your door!
The Supreme Court of Pennsylvania held that a license to use canned software is a license to use tangible personal property and is therefore taxable for Sales and Use Tax purposes.
The European Commission has decided to refer Finland to the European Court of Justice because of failure to comply with a Reasoned Opinion on its legislation which discriminates against foreign pension funds.
The Danish tax system comprises of direct and indirect taxes. Direct taxes include income tax and property tax, while the principal indirect taxes are value added tax (VAT), customs, green taxes and excise duties.
The importance of economic relations between the countries has increased with the ever-growing mobility of capital in the globalised world. In the current conditions, where international investments significantly rise, companies wish to maximize their profits.
On March 18, 2010, a majority of the Illinois Supreme Court held that a religiously affiliated Illinois hospital was not entitled to an exemption from property tax because it failed to establish that it was a charitable institution.
In May, the House of Representatives passed legislation (Section 413 of H.R. 4213) that would subject non-wage earnings of certain S corporation shareholders to the self-employment tax for the first time.
