Company changed tax address from U.S. to Ireland this year CEO says 40 percent of cash still located outside U.S. Medtronic Plc’s decision to move its tax address out of the U.S. is already starting to pay dividends. The medical device company used a deal with Covidien Plc this year… – Continue reading
A bill approved by New Jersey’s Assembly would strike back against “corporate inversions,” when a U.S. company buys a smaller company abroad, then changes its address to slash its tax bill. Under the measure approved Thursday, New Jersey would stop offering contracts and development subsidies to these artful tax dodgers… – Continue reading
Leaders from the Group of 20 largest economies (G20) met in Turkey last month to put their final stamp of approval on a major overhaul of the international rules governing corporate taxes. The vote was the icing on a cake that the Organization for Economic Cooperation and Development (OECD) has… – Continue reading
On November 30, 2015, the UK tax authorities at HM Revenue and Customs (HMRC) reached an agreement with Jersey about the interpretation of the company residence tie-breaker provision of the Jersey-UK income tax treaty. After reviewing other income tax treaties that contain similar provisions, HMRC will now take the view… – Continue reading
Lawmakers seek late deal to scale back ‘Cadillac tax’ Lawmakers are making a late push to repeal or scale back Obamacare’s “Cadillac tax” by the end of the year, eying inclusion of changes in a broader tax package, wrote Peter Sullivan of The Hill. But lawmakers in both parties say… – Continue reading
Republicans in both chambers of Congress said international tax reform is necessary to retain companies in the United States following pharmaceutical giant Pfizer’s announcement it is moving its headquarters overseas after its merger with Ireland-based Allergan, citing the country’s high corporate tax rates. During hearings in the House Ways and… – Continue reading
The House and Senate held hearings Tuesday on the Organization for Economic Cooperation and Development’s Base Erosion and Profit Shifting action plan, also known as OECD BEPS, for combating tax avoidance by multinational corporations. A number of the lawmakers expressed a skeptical view of the international tax reforms. “The OECD’s… – Continue reading
While the U.S. is plagued by inertia when it comes to tax policy, the rest of the world hasn’t been standing still. The biggest change of late has been the completion of the Organization for Economic Cooperation and Development’s (OECD) Base Erosion and Profit Shifting Project, or BEPS, a multiyear… – Continue reading
Legislative Activity Tax-Writers Begin to Focus on BEPS, Tax Extenders Still Remain Though international tax reform negotiations may have fallen apart for 2015, tax-writers this week will hold their first hearings to address efforts by the Organisation for Economic Co-operation and Development (OECD) to counter corporate tax avoidance as part… – Continue reading
Tech titans powering the economy shelter money through insane tax-avoidance havens. It’s wrong — and adding up Offshore tax havens enable not only individuals to dodge taxes—they also enable multinational corporations to do so. Often this tax avoidance is done within the letter of the law: multinational groups exploit the… – Continue reading
The Treasury Department and the IRS released Notice 2015-79 (the “2015 Notice”) on November 19th to further limit expatriation transactions and to supplement the anti-inversion guidance issued by them on September 22, 2014 (the “2014 Notice”). The 2015 Notice states that Treasury and the IRS will issue Treasury regulations to… – Continue reading
In response to the announcement that pharmaceutical firms Pfizer and Allergan would merge, Hillary Clinton released a statement that completely missed the real issue behind these inversions – they are a symptom of the greedy, complex, and inefficient U.S. tax code. “Inversion is a symptom, not a disease,” said Grover… – Continue reading
Pharmaceuticals manufacturer Pfizer is set to move its tax address to Ireland following a major merger A Government minister has said that Ireland is not a tax haven, and that companies choose to locate here for ‘lots of reasons’. It comes in the wake of the decision by the pharmaceuticals… – Continue reading
Pfizer $160bn purchase of Allergan will see firm move HQ to Dublin Ireland’s exchequer is in line for an annual boost of up to €620 million following the announcement that Pfizer is buying rival Allergan in a $160 billion (€151 billion) deal. The takeover will see Pfizer move its corporate… – Continue reading
The latest Tax Reform Business Barometer survey, issued by The Tax Council and Ernst & Young, found that tax professionals expect Congress to approve tax reform legislation no earlier than 2017, with most congressional leaders having all but given up hope that tax reform is achievable in the remainder of… – Continue reading
The United States is on the verge of economic collapse. It is being tipped over the edge by its own government with an unquenchable thirst for taxes and incurable addiction to spending. The financial system in the United States and everywhere else in the world is in danger of disintegrating… – Continue reading
Notice 2015-79—released November 19, 2015, by the Treasury Department and IRS—announces their intention to issue regulations relating to inversion transactions and post-inversion restructuring transactions. Notice 2015-79 provides for rules that: Limit the ability of domestic companies to effect an inversion Limit the advantages of certain post-inversion restructuring transactions Clarify certain… – Continue reading
This week, the IRS released Notice 2015-79, which describes intended regulations to cover inversions and related transactions. Colloquially, an inversion refers generally to a transaction in which a domestic corporation is acquired by a foreign corporation. I.R.C. §§ 367 and 7874 operate as the anti-inversion rules; § 367 deals with… – Continue reading
In a further move to reduce the tax benefits of, and therefore the incentives for, corporate inversions, the U.S. tax agency, the Internal Revenue Service (IRS), on Thursday announced additional rules designed to curtail the ability of an inverted company to access foreign subsidiaries’ earnings without paying U.S. tax (Notice… – Continue reading
U.S. Treasury Secretary Jacob Lew today wrote to the leaders of the congressional tax writing committees, and provided an update on the status of Treasury’s administrative actions concerning corporate inversions. In a version of the letter being widely circulated, Secretary Lew wrote that, later this week, Treasury intends to issue… – Continue reading
Markets finished close to unchanged on Tuesday, but these stocks soared. Find out why. After big gains to start the week, the stock market treaded water on Tuesday, with most major benchmarks finishing close to the unchanged level. Yet for Airgas (NYSE:ARG), Nuance Communications (NASDAQ:NUAN), and Syngenta (NYSE:SYT), the day… – Continue reading
WASHINGTON—The U.S. Treasury Department will release new “targeted guidance” this week designed to reduce the tax benefits available to U.S. companies that move their tax addresses overseas. Treasury Secretary Jack Lew informed lawmakers of the coming announcement in a letter on Wednesday, which provided no details on its intentions. The… – Continue reading
The role of corporate taxation has always been a contentious political and economic issue, and with a pending U.S. election it has proven to be a polarizing topic in recent debates. A recent report by WalletHub looked at the 2014 tax rates for S&P 100 companies, and found a wide… – Continue reading
Once again, a possible corporate inversion is making headlines and once again, the Obama administration has proven it does not understand the real reason inversions occur. In response to news that pharmaceutical firms Pfizer and Allergan are in merger discussions, the Obama Treasury department has suggested it would do its… – Continue reading
Pfizer Inc.’s buyout bid for Allergan Plc has financial markets on edge over a possible new move by the U.S. Treasury Department against tax-inversion deals, but the outlook for any such steps was still unclear. For months, Treasury has offered no fresh guidance on the inversion issue, leaving tax experts… – Continue reading
A rout in pharmaceutical and biotech stocks has altered the equation for chief executives thinking about big-ticket mergers and acquisitions. On one hand, target companies are much cheaper than they were: roughly $130 billion has been wiped off the Nasdaq biotech index since Hillary Clinton, the Democratic presidential front-runner, pledged… – Continue reading
Rep. Mark Pocan, D-Wis., has introduced two pieces of legislation to combat corporate tax inversions and tax deferral. The Corporate Fair Share Tax Act and the Putting America First Corporate Act would prevent corporations from using “tax inversions” to reduce a company’s U.S. tax burden and hide profits overseas. Corporate… – Continue reading
Tax-driven “inversion” deals that let companies flee the U.S. tax system by relocating abroad, if only on paper, would be curbed under legislation introduced in Congress, as Pfizer Inc (PFE.N) pursues such a deal with rival Allergan Plc (AGN.N). Wisconsin Democratic Representative Mark Pocan’s bills likely have little chance of… – Continue reading
In a time of fiscal austerity, it is breathtaking to learn that Congress has allowed Fortune 500 companies to avoid an estimated $620 billion in federal taxes on earnings they are holding offshore. While the inaction by lawmakers on this issue may create the impression that there is nothing to… – Continue reading
The recent corporation tax controversy highlighted by US presidential hopefuls Hillary Clinton and Donald Trump is not damaging Ireland’s reputation as a place to do business, said the former chief executive of Apple, John Sculley. According to Mr Sculley, the controversy is simply part of US election fever. Known as… – Continue reading
Pharmaceutical giant Shire, which is headquartered in Ireland for tax purposes, has agreed to buy US rare disease specialist Dyax Corp for about $5.9bn (€5.35bn), and potentially up to $6.5bn, while still pursuing a five- times larger unsolicited bid for biopharma firm Baxalta Inc. The Dyax deal, the latest in… – Continue reading
As the 2016 Presidential campaign heats up with debates and public appearances replete with the candidate’s opinions on the economy, ISIS, and education, among others, few candidates have mentioned the issue of corporate tax reform, especially as it relates to a level playing field between the U.S. and foreign markets,… – Continue reading
Pfizer’s bid for $113bn Dublin-based drug maker Allergan is the biggest merger of the year, anywhere. It’s potentially good news for the Irish exchequer, which may gain a massive new taxpayer, and for businesses here like Arthur Cox, Allergan’s adviser on Irish corporate law. But a deal that may well… – Continue reading
A spate of so-called “tax inversion” deals involving companies based in Ireland appears to be distorting the country’s foreign direct investment (FDI) numbers, The Irish Times reports. An OECD report suggests investment by Irish firms abroad more than doubled to US$75 billion in the first half of 2015. The study… – Continue reading
Pfizer Inc. may be getting closer to breaking up and moving out. The largest U.S. drugmaker and Allergan Plc are considering combining operations, according to the Wall Street Journal. A deal would give Pfizer a way to move to a low-tax legal address abroad and gain valuable specialty drugs like… – Continue reading
The New York billionaire is aiming his financial might at members of Congress who aren’t willing to cut deals on corporate tax policy. Sure, Carl Icahn might make money—lots of money—on his $6 billion stake in Apple Inc. if a political campaign he announced Wednesday to cut taxes on companies’… – Continue reading
Major US investor Carl C. Icahn and the Chief Executive Officer of TechNet, Linda Moore, have both recently written letters to leading lawmakers pointing out that the passage of international tax reform by Congress has become a matter of extreme urgency. In his letter, Icahn announced that “the time has… – Continue reading
Carl Icahn, the iconic activist investor, has shifted, if only for today, his cross-hairs of contempt from the boardrooms of corporate America to the nation’s capital. Icahn sends members of Congress a word of warning Wednesday saw Carl Icahn warn several members of Congress a letter laying out his plans… – Continue reading
A recent Thomson Reuters survey report reveals that European companies are outpacing all others in developing their Base Erosion and Profit Shifting (BEPS) action plans by Dec. 31, 2017 – the deadline set by the Organization for Economic Cooperation and Development (OECD). But most respondents voiced several concerns about BEPS… – Continue reading
With Medtronic being one of Ireland’s largest employers, analysts say there is a new incentive for the medical device maker to prioritize its Dublin headquarters for R&D. In the eyes of developed nations, Ireland has become notorious for baiting multinational firms to its land with the offer of friendly tax… – Continue reading
The chief of the generic drug company discussed her “counterintuitive” strategy for creating U.S. jobs. Mylan is one of a handful of U.S. companies that has recently completed a controversial tax inversion, as the generic drug company moved its official base to the Netherlands earlier this year. While the decision… – Continue reading
The hedge fund trade to gain exposure and then encourage a U.S. corporation to enter into an acquisition transaction with a foreign corporation where it incorporates internationally to lower its tax burden, known as a corporate inversion, might have slowed of late, but the issue is now being addressed at… – Continue reading
The global war on corporate tax avoidance doesn’t look like being so gruesome after all. The OECD reckons that governments are losing out on at least €213bn per year from aggressive tax planning by multinationals, reports the Irish Independent. A new book by a Berkeley University economics professor estimates that… – Continue reading
Supporters of a plan to tax overseas profits to pay for U.S. transportation projects said Wednesday the proposal is the “only possible path forward” for passing a highway bill in the House this month. The sponsors of legislation in the House containing the offshore taxes-for-roads proposal said the plan, known… – Continue reading
Last year at this time, news about “tax inversions” was grabbing headlines – cases where large U.S. multinationals would buy a foreign company in a tax-friendly jurisdiction, and then relocate its headquarters to reap the tax arbitrage benefits. The Obama administration responded to the rash of high-profile inversions with new… – Continue reading
Daily Herald Reports Specialty drug manufacturer Horizon Pharma, which moved its corporate headquarters from Deerfield to Ireland in 2014, announced it is relocating its U.S. headquarters from Deerfield to Lake Forest as part of a company expansion. The Dublin-based company reported it signed a long-term sublease on a 160,000-square-foot building… – Continue reading
Moving overseas to cut tax burden remains a viable option for some firms, though the presidential candidates may have other plans. With the long haul of a presidential election campaign just beginning, companies that leave the U.S. to lower their tax bills are once again political targets. Donald Trump this… – Continue reading
Reading companies’ annual reports to the Securities and Exchange Commission is a reliable cure for insomnia. Every so often, though, there is a significant revelation in the paperwork. Last year, one of the most important revelations came from Microsoft’s filings, which spotlighted how the tax code allows corporations to enjoy… – Continue reading
Valeant is famous for wringing cost savings out of its buyouts, and its tax-advantaged Canadian domicile helps on that front. Now, it’s leveraging another address to pare down Salix’s tax bill by more than $560 million. But how? According to documents seen by The Wall Street Journal, the strategy used… – Continue reading
BY DAVID JESSOP— The Caribbean has just 18 congressional working days from Sunday, September 20 to try to have the U.S. Congress address an act naming 17 Caribbean nations as “tax havens”. If passed without amendment, it could have the effect of reputationally damaging the countries concerned with unpredictable trade,… – Continue reading
