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Curated by Chris Bale
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Joel Walters and Jim Marshall discuss the evolving role of a Global Tax Director

Joel Walters from PwC US talks to Jim Marshall, Vice President of Global Tax at Pearson PLC, about the changing role of the the senior tax director.

Chris Bale's insight:

This is an interesting conversation. Joel is currently Head of Inbound Tax at PwC US but he was previously Global Head of Tax at Vodafone, based in the UK. 


Jim Marshall's comment that being technically strong is no longer that important for a Head of Tax position is noteworthy.

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Former IRS Commissioner Mark W. Everson announces candidacy for President of the United States (and no this is not a joke)

Former IRS Commissioner Mark W. Everson announces candidacy for President of the United States (and no this is not a joke) | Totally Tax | Scoop.it
Chris Bale's insight:

When I started work at Arthur Andersen, 25 years ago, some of my friends thought that a job in tax would be very restricting in terms of future career choices. 


But just look at Mark Everson. He might be the next President of the USA ! You can click through to his website where he announces his 6 initiatives. At the moment he has only 252 followers on facebook. Let's hope that improves.


Everson’s “Letter to America” lays out six initiatives:


  1. Fundamental tax reform.
  2. Confronting the lawlessness of the Big Banks.
  3. Re-establishing the draft in order to have a shared sense of national service.
  4. Real, balanced reforms to our entitlement programs.
  5. Reinforcing the American tradition of assimilation through comprehensive immigration reform.
  6. Serving only a single term to keep re-election politics out of Presidential decision-making.

On tax reform Everson said,


“We need a tax code that promotes growth and helps Americans provide for their future. Adoption of a consumption tax will remove 150 million Americans from the income tax rolls, freeing them from the burden of dealing with the IRS.”

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London mayor settled IRS tax bill despite initial bravado. Will US embassy in London now settle its motoring fines ?

London mayor settled IRS tax bill despite initial bravado. Will US embassy in London now settle its motoring fines ? | Totally Tax | Scoop.it
The London Mayor has agreed to pay his unsettled capital gains tax bill, which he previously labelled 'absolutely outrageous', ahead of his visit to the US
Chris Bale's insight:

Great story. Cannot help feeling that there is a connection between the IRS extracting this payment from the London Mayor and his hounding of the US embassy in London over unpaid motoring fines. I sense a fight coming...

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3 more UK corporate avoidance schemes are squashed: Biffa Group, Vocalspruce and Fidex

3 more UK corporate avoidance schemes are squashed: Biffa Group, Vocalspruce and Fidex | Totally Tax | Scoop.it

Will the UK tax profession ditch complex tax planning altogether ? HM Revenue and Customs (HMRC) has clocked up another three major legal victories over corporate tax avoidance schemes, protecting over £100 million of tax.

Chris Bale's insight:

HM Revenue and Customs (HMRC) has clocked up another three major legal victories over corporate tax avoidance schemes, protecting over £100 million of tax.


The successes include a Court of Appeal win concerning an avoidance scheme used by a number of large businesses. The lead case was Vocalspruce Limited, and there were 43 follower cases – a combined total of £85.4 million of tax was at stake. A number of other users of the scheme have already settled with HMRC, protecting a further £65.7 million.


The second case is an Upper Tribunal decision in HMRC’s favour in a case involving Fidex Ltd, a subsidiary of the global banking group BNP Paribas – a ruling which protects £17.2 million in tax.


In the third case, a First-Tier Tribunal found for HMRC against an avoidance scheme used by one of the UK’s biggest waste management companies, Biffa Group. Biffa's case, along with two other cases on use of the same scheme, involve around £15 million of tax. More than £16 million had already been settled by other users of the scheme ahead of the litigation.

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Hungary's Tax Chief, Ildiko Vida, is banned from entering the USA on suspicion of corruption

Hungary’s tax chief confirmed she and several colleagues from the National Tax Authority have been banned from entering the U.S. on suspicion of corruption, ending weeks of media speculation.
Chris Bale's insight:

Hungary’s tax chief confirmed she and several colleagues from the National Tax Authority have been banned from entering the U.S. on suspicion of corruption, ending weeks of media speculation.


Denying any wrongdoing, Ildiko Vida said “yes” in response to a question on whether she had been barred entry to the U.S., according to the transcript of an interview published in today’s Magyar Nemzet newspaper.


The U.S. imposed travel bans on six Hungarian officials suspected of corruption, acting on “credible information,” its embassy in Budapest said on Oct. 17. The Orban government has asked the U.S. to share its information, which the U.S. has so far declined to do.

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Tax Jobs | Philippines Tax Revenue Chief, Kim ‘Ice Bucket’ Henares, appointed to UN Committee of Experts on International Cooperation in Tax Matters

Tax Jobs | Philippines Tax Revenue Chief, Kim ‘Ice Bucket’ Henares, appointed to UN Committee of Experts on International Cooperation in Tax Matters | Totally Tax | Scoop.it

The Philippines' Bureau of Internal Revenue chief, Kim Henares, has been appointed by United Nations Secretary General Ban Ki Moon to the UN Committee of...

Chris Bale's insight:

The Philippines’ Bureau of Internal Revenue chief, Kim Henares, has been appointed by United Nations Secretary General Ban Ki Moon to the UN Committee of Experts on International Cooperation in Tax Matters.


Henares is one of 25 tax experts and senior tax administrators from 10 developed and 15 developing countries who have been appointed to the UN committee. The committee is responsible for exploring ways and means of facilitating the conclusion of tax treaties between developed and developing countries and for promoting international tax cooperation among tax authorities.


Please click on the Tax Grotto logo to see the full article and video.

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Glencore unit suspends Zambia copper projects over $200 million tax row

LUSAKA (Reuters) - Glencore-owned Mopani Copper Mines has suspended some of its planned $800 million Zambian copper mining projects after the government withheld $200 million in tax refunds, the company
Chris Bale's insight:

Glencore-owned Mopani Copper Mines has suspended some of its planned $800 million Zambian copper mining projects after the government withheld $200 million in tax refunds, the company said on Wednesday.


Africa's second-largest copper producer is withholding a total of $600 million in VAT refunds owed to mining firms and will only repay the cash when companies produce import certificates from destination countries, the minister of mines said in June.

Zambian Finance Minister Alexander Chikwanda said in August it planned to waive the requirement because it is impractical. The Zambia Revenue Authority says it is still consulting with exporters before implementation.


"I would like to express my concern and distress that the continued withholding of our refunds to the tune of $200 million may force us to slow down progress on these projects," Mopani's chief executive, Danny Callow, said in a statement.

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Former Head of Tax & Treasury at Wm Morrison, Paul Coyle, charged by FCA with insider dealing

The Financial Conduct Authority (formerly known as the FSA) today charged Paul Gerard Coyle (DOB: 20/04/1964), the former Treasurer and Head of Tax at Wm Morrison Supermarket plc (Morrison) with two offences of insider dealing, contrary to Section 52(1) of the Criminal Justice Act 1993.

Chris Bale's insight:

The Financial Conduct Authority (formerly known as the FSA) today charged Paul Gerard Coyle (DOB: 20/04/1964), the former Treasurer and Head of Tax at Wm Morrison Supermarket plc (Morrison) with two offences of insider dealing, contrary to Section 52(1) of the Criminal Justice Act 1993.


The offences relate to trading in Ocado Group plc shares between February and May 2013.


Mr Coyle was suspended from his job in January 2014 in connection with the FCA probe.


Press release here: http://www.fca.org.uk/news/fca-charges-former-treasurer-at-wm-morrison-with-insider-dealing

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French farmers set fire to Brittany tax office as a protest against falling living standards

French farmers set fire to Brittany tax office as a protest against falling living standards | Totally Tax | Scoop.it
Angry French vegetable farmers protesting against falling living standards burn down tax and insurance offices in a Brittany town.
Chris Bale's insight:

French vegetable farmers protesting against falling living standards have set fire to tax and insurance offices in town of Morlaix, in Brittany.


The farmers used tractors and trailers to dump artichokes, cauliflowers and manure in the streets and also smashed windows, police said.


Prime Minister Manuel Valls condemned protesters for preventing firefighters from dealing with the blaze.

The farmers say they cannot cope with falling prices for their products.


A Russian embargo on some Western goods - imposed over the Ukraine crisis - has blocked off one of their main export markets.

About 100 farmers first launched an overnight attack on an insurance office outside Morlaix, which they set light to and completely destroyed, officials said.


They then drove their tractors to the main tax office in the town where they dumped unsold artichokes and cauliflowers, smashed windows and then set the building on fire.

French media said the farmers then blocked a busy main road in Morlaix in both directions.


In a statement, Mr Valls "vigorously" condemned the "looting and destruction by fire" of the buildings.

He said violence was not justified and the perpetrators would be prosecuted.

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Prominent Canadian tax lawyer charged in SNC scandal

Constantine Kyres accused of extortion and obstruction of justice for allegedly plotting to pay for a statement from Riadh Ben Aissa
Chris Bale's insight:

The corporate scandal that has scarred SNC-Lavalin Group Inc. has expanded beyond the company’s Montreal headquarters with the arrest of a prominent tax lawyer who faces criminal charges stemming from an undercover police operation.


Up until the beginning of this year, Constantine Kyres headed the tax group at the Montreal office of Dentons Canada LPP, the multinational law firm that was created when three firms, including Fraser Milner Casgrain, merged in 2013.wfw itax partner london


Click through for the full article in The Globe and Mail


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SMU in partnership with Tax Academy of Singapore launches new Centre for Excellence in Taxation

Chris Bale's insight:

In collaboration with the Tax Academy of Singapore, and with the support of the Inland Revenue Authority of Singapore, the Singapore Management University has launched the SMU-TA Centre for Excellence in Taxation (SMU-TA CET) today.

The SMU-TA CET represents a major new initiative in research addressing international and regional tax issues and taxation policies. It is the first research centre of its kind in Singapore. The aim of the Centre is to produce highly robust research in international and regional tax issues for policy-development and engagement of the international tax community.

SMU President Professor Arnoud De Meyer said, “In its 2010 final report, the Committee to Develop the Accounting Sector (CDAS) envisioned that Singapore should be transformed into a leading global accountancy hub. One of the main recommendations of CDAS was that Singapore should develop a Centre of Excellence in tax. I am extremely happy today that SMU has, with the support of IRAS, entered into a collaboration agreement with the Tax Academy of Singapore to set up this SMU-TA Centre for Excellence in Taxation (SMU-TA CET). I am positive that it will help actualise the vision of CDAS.”

The new Centre will be helmed by SMU Professor of Accounting Sum Yee Loong who has more than 30 years of experience in Singapore and international taxation. Prior to his appointment as SMU Professor, he provided tax advisory services to corporate clients including multi-national companies, financial institutions, international trading companies, manufacturing companies, information technology companies and many international legal firms. His areas of specialisation included corporate structuring & restructuring, restructuring for IPO, mergers & acquisitions and international tax planning.

CEO of the Tax Academy of Singapore, Mrs Eng-Tay Geok Lee said, “The Tax Academy of Singapore has taken a leading role in facilitating the growth of tax expertise. Besides providing the essential building blocks in tax education for the tax professionals, I am heartened that the Tax Academy of Singapore has taken a leap forward by setting up a tax research centre with SMU, a premier university in Singapore, to provide the platform for knowledge exchange and top quality research for tax experts, academics and practitioners from around the world.”

SMU-TA CET will partner members of academia, industry leaders and government officials to produce multidisciplinary research on international taxation, from legal, economic and public policy perspectives. It will receive the support of a soon-to-be established Technical Advisory Panel comprising leading academics and key practitioners, both local and international, with extensive experience and knowledge of global tax trends and issues. The expert advisers will provide technical expertise and guide the SMU-TA CET towards identifying constructive research agenda and producing quality research. 

Centre Director Professor Sum shared that the Centre will first tackle projects on international tax issues that are relevant to Singapore and Asian economies, and look into the impact of the changing global tax landscape on the region’s economic competitiveness. Plans are also in the pipeline for the Centre to develop a post-graduate programme in international tax. 

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R&D Tax market hotting up - boutique firm, HowarthLynch, acquired by Abbey Tax Protection. Who will dominate this market ?

Tax JobsAbbey Tax Protection, the tax fee protection division of the Abbey Protection Group, has acquired Sheffield based HowarthLynch, one of the UK’s providers of
Chris Bale's insight:

The UK R&D market is beginning to get interesting. Today we learnt that one of the boutique firms, HowarthLynch, which was launched only 3 years ago, as been acquired by Abbey Tax. We are also aware of two Law Firms looking to add on R&D tax services to their existing Patent offering.


It is as yet unclear who will dominate this market. On the face of it, very little tax experience is required to build a successful R&D practice, so in theory the market is open to anyone. The margins are not huge for SME clients, so I think the boutiques will service this market and the larger accounting firms will retain their quoted clients. The law firms will probably struggle to make any real in-roads.



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Irish, Dutch and UK law firms now aggressively tarting their tax inversion capabilities to U.S. Corporates

Irish, Dutch and UK law firms now aggressively tarting their tax inversion capabilities to U.S. Corporates | Totally Tax | Scoop.it
NEW YORK (Reuters) - A series of European law firms are aggressively pitching low corporate taxes in their countries to prospective U.S. clients, seeking to tap into the tax inversion frenzy that has seized
Chris Bale's insight:

Article by Reuters. I guess we all knew it must be going on, but interesting to see which law firms are knocking on the doors of US Corporates.


A series of European law firms are aggressively pitching low corporate taxes in their countries to prospective U.S. clients, seeking to tap into the tax inversion frenzy that has seized Corporate America in recent months.


At least eight European law firms are pitching their services to major U.S. law firms and Wall Street banks, hoping that U.S. companies considering an inversion choose Ireland, Britain or the Netherlands for their new tax domicile, according to people with knowledge of the matter.

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HMRC launches major recruitment campaign on eTaxJobs.com to hire 100 experienced tax professionals across the UK.

HMRC launches major recruitment campaign on eTaxJobs.com to hire 100 experienced tax professionals across the UK. | Totally Tax | Scoop.it
Chris Bale's insight:

HMRC today launched a major recruitment campaign to hire 100 experienced tax professionals across the UK. 

- These opportunities are permanent positions and offered on a full-time, part-time or job share basis. 

- The roles can be based in the following locations: Birmingham, Bristol, Cardiff, Edinburgh, Glasgow, Liverpool, London, Manchester, Newcastle, Nottingham, Reading

- The base salary on offer ranges from £47,218 to £61,590 depending on location and experience.

- Benefits include a final salary pension + 25 days holiday 

- These opportunities are open to UK, British Commonwealth and European Economic Area (EEA) Nationals and certain non EEA members

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Superb letter from Gibraltar Chief Minister to Ed Milliband highlights just how hapless the UK Labour leader is.

Superb letter from Gibraltar Chief Minister to Ed Milliband highlights just how hapless the UK Labour leader is. | Totally Tax | Scoop.it
Ed has upset the Gibraltarians by labelling them a tax haven and threatening to blacklist one of Britain's proudest Overseas Territories if they do not comply with his demands. The Chief Minister o...
Chris Bale's insight:

Not only is Ed Milliband factually incorrect in his assertions about British Overseas Territories, he has also stoked up a diplomatic incident between Spain and Gibraltar. Future Prime Minister ? I think not.

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Can you summarise a tax query in 140 characters ? UK Tax Authority expects taxpayers to tweet their questions.

Can you summarise a tax query in 140 characters ? UK Tax Authority expects taxpayers to tweet their questions. | Totally Tax | Scoop.it
HM Revenue and Customs defends asking people to tweet their tax inquiries after revealing an increase in waiting times on its helplines.
Chris Bale's insight:

Tax officials have defended asking people to tweet their inquiries after an MP said the idea was "laughable".


Stephen Hardwick, director of communications for HM Revenue and Customs, said Twitter would be a "supplement" to calling helplines. But Mr Hardwick said people should not tweet any personal data. He apologised for long waiting times on HMRC's phonelines and promised more staff for an expected spike in self-assessment calls this month.


When HMRC suggested using its new @HMRCcustomers Twitter account for some queries, Labour MP Margaret Hodge, who chairs the Commons Public Accounts Committee, said the idea was "laughable". She added: "No customer based service should tolerate such a poor service and both ministers and senior management should simply sort this out."


But Mr Hardwick told BBC Radio 4's Today programme: "We are serious about the use of Twitter as a supplement to going online and using the telephone.


"What we don't want people to do is to give us any personal details.

"It's a very useful social media device to get guidance, to help point people to where they can get information online.

"It's a pilot, it is starting small, but the whole point of social media is you answer a question once and hundreds or thousands of people can see the answer, rather than answering the phone to all of those people asking the same question."



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PwC issues formal statement in response to media reports re Luxembourg that "are based on partial, incomplete information dating back four years or more, which was illegally obtained."

PwC issues formal statement in response to media reports re Luxembourg that "are based on partial, incomplete information dating back four years or more, which was illegally obtained." | Totally Tax | Scoop.it
London, 7 Nov 2014 -- The recent reports in the media on tax advice in Luxembourg co-ordinated by the International Consortium of Investigative Journalists (ICIJ) are based on partial, incomplete info
Chris Bale's insight:

The recent reports in the media on tax advice in Luxembourg co-ordinated by the International Consortium of Investigative Journalists (ICIJ) are based on partial, incomplete information dating back four years or more, which was illegally obtained. 


PwC takes the improper disclosure of any confidential information extremely seriously. As soon as it became aware that documents had been illegally taken from its offices in Luxembourg, PwC undertook a full investigation that quickly led to the individual who we believe took the documents. The matter was immediately reported to the relevant judicial authorities in Luxembourg whose enquiries into the matter are continuing. At the time of the disclosure of the documents, the individual had already left PwC's employment.


Since these documents were taken, PwC Luxembourg has conducted a thorough review of its security systems and processes, and continually enhances the security of its systems to match current best practice.


PwC provides independent professional advice to clients on the issues that are important to them in running their businesses including a wide range of tax issues. This can include advice on the taxation of potential business transactions in a particular country. We also assist our clients with the preparation of tax returns and with discussions with tax authorities. 


All our advice and assistance is given in accordance with applicable local, European and international tax laws and agreements and is guided by the PwC Global Tax Code of Conduct which has been in place since 2005. Our global tax code sets out guidance for our tax professionals around the world on a range of issues, including taking into consideration how any tax decisions will be viewed by wider stakeholders. 


Our client relationships are governed by strict confidentiality; we cannot comment on individual cases.

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Ten things HMRC wants you to know about tax avoidance in the UK

Ten things HMRC wants you to know about tax avoidance in the UK | Totally Tax | Scoop.it
HM Revenue and Customs (HMRC) today issued a list of ‘10 things a tax avoidance scheme promoter won’t always tell you’.
Chris Bale's insight:

Helpful pointers from HMRC...


The 10 things a promoter won’t always tell you:


1. Most schemes don't work. You may be told that avoidance is legal, but if the scheme doesn’t work you'll have made an incorrect tax return which is not in accordance with the law. You are legally obliged to pay tax that is due and you may be charged penalties if you try to avoid it.


2. It could cost you more than you bargained for. Avoidance schemes are complex. They can give rise to unintended additional tax consequences, and the fees you pay the promoter do not count as tax paid. So you could end up paying much more than just the tax you’re trying to avoid.


3. You may have significant legal fees to pay. If the scheme is taken to litigation, you’re likely to have hefty legal fees to pay. Your promoter may ask you to pay into a ‘fighting fund’ up front.


4. You could face criminal conviction. If you deliberately mislead or conceal information from HMRC you could be prosecuted and convicted.


5. You could face publicity as a tax avoider. If you are named in court papers when the case is litigated, or in public registers, you could be reported in the media as a tax dodger.


6. Your scheme is never HMRC approved. Getting an avoidance Scheme Reference Number from HMRC doesn’t mean the department has cleared the scheme. HMRC issues these numbers when a scheme has signs of being designed to avoid tax.


7. You could be marked out as a high-risk taxpayer. Use of a scheme could mark you out as a high-risk taxpayer, which means that all of your tax affairs will be closely scrutinised in future, not just your claim for relief.


8. HMRC is likely to beat your scheme in court. HMRC wins eight out of ten cases where taxpayers and promoters take avoidance schemes to court.


9. The risk is normally all your own. It's unlikely that a promoter will give you a guarantee that a scheme will work. And they probably won’t be around to support you once HMRC starts investigating your tax affairs. Some promoters set up simply to sell the scheme, and then disband.


10. You’ll have to pay the tax up front anyway. You won't get a cash-flow advantage while HMRC investigates a scheme. New legislation means you'll have to pay the disputed tax up front.

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Should Revenue Authorities employ psychologists to deliberately engender guilt and thereby increase tax receipts ?

Should Revenue Authorities employ psychologists to deliberately engender guilt and thereby increase tax receipts ? | Totally Tax | Scoop.it
Danny Alexander, the Chief Secretary to the Treasury, reveals HMRC has subtly altered wording of hundreds of thousands of reminder letters to 'nudge' people into paying up
Chris Bale's insight:

The Chief Secretary to the Treasury revealed that HMRC has subtly altered the wording of hundreds of thousands of letters sent out to the public to encourage people to pay up.


Speaking at the Liberal Democrat party conference, Mr Alexander said: "We are using psychologists and behavioural economists in HMRC to get the money quickly.


"Tax dodgers beware – we know where you live, we know how much you owe, and now we know how you think. Your behaviour is unacceptable, and we are coming for our money."

HMRC said it conducted "large scale" trials involving 100,000 taxpayers to "pinpoint the exact words and concepts" which make people more likely to pay their taxes.


It found that by highlighting the degree to which others are paying their taxes, known as the social norm, people are more likely to pay up.


The change in wording has so far led to an estimated £210 million worth of additional tax revenues each year.

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Bringing the UK tax profession into disrepute: Andrew Meeson and Peter Bradley must repay £5.1 million to HMRC or serve a further 10 years in jail.

Bringing the UK tax profession into disrepute: Andrew Meeson and Peter Bradley must repay £5.1 million to HMRC or serve a further 10 years in jail. | Totally Tax | Scoop.it
A former president of the Association of Taxation Technicians (ATT) and a fellow company director have been jailed for eight and half years each for a £5...
Chris Bale's insight:

 A former president of the Association of Taxation Technicians (ATT) and a fellow company director who were both jailed for a £5 million pension scheme tax fraud have been ordered to pay back a total of £5.1 million.


Andrew Meeson and Peter Bradley must repay the money within six months or serve a further 10 years in jail.


The confiscation follows a financial investigation by HM Revenue and Customs (HMRC) into the assets of the men, who were each sentenced to eight and a half years in jail in March 2013.


Meeson and Bradley, both from Wolverhampton, had conspired to receive £5 million in fraudulent income tax repayments via their company, Tudor Capital Management Limited. The pair claimed that the repayments were due on pension contributions of £25 million made by scheme members, but HMRC investigators found that these contributions did not exist.


Adrian Farley, Assistant Director, Criminal Investigation, HMRC, said:


“Meeson and Bradley committed blatant theft, exploiting their positions of trust and authority. Our priority is to track down tax fraudsters and to confiscate their ill-gotten gains. If they do not pay up, they face a substantial additional prison sentence – and they will still owe the money on release.”


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The Argentinian tax agency is using drones to catch property tax evaders. Will the use of this technology become the norm in tax revenue agencies around the globe ?

The Argentinian tax agency is using drones  to catch property tax evaders. Will the use of this technology become the norm in tax revenue agencies around the globe ? | Totally Tax | Scoop.it
Drones deployed by tax inspectors near Buenos Aires found 200 mansions and 100 swimming pools that hadn't been declared
Chris Bale's insight:

An interesting use of drone technology, as reported in the Daily Telegraph. 


The Argentine tax revenue agency is using drones to catch out wealthy tax evaders who have not declared mansions and swimming pools.


Unmanned aircraft were dispatched over an upper class area of Buenos Aires and discovered 200 homes and 100 pools that had not been detailed on tax returns.


Tax officials said the drones took pictures of luxury houses standing on lots registered as empty.


The evasions found by the drones amounted to missing tax payments of more than $2 million and owners of the properties have been warned they now face large fines.


The unregistered mansions and pools were found in an area about 10 miles south of the city and, according to the tax agency, they appeared to be large and constructed with “premium materials”.


The potential uses of drone technology within the tax world are worrying I think. For example, it is common in the UK for HMRC to stand outside a takeaway Chinese restaurant for 2 nights counting the number of people who enter. From this data an extrapolation is made as to the income and the tax due. Looking ahead, HMRC might position a drone outside every restaurant at regular intervals to more accurately assess customer flow and possible tax evasion through cash transactions.

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Does your Head of Treasury speak to your Head of Transfer Pricing ?

Interesting article from Deloitte. TP is obviously well integrated into most in-house tax functions but I wonder how often the Head of Treasury and Head of TP sit down and talk ?

Chris Bale's insight:

To understand how strategic transfer pricing may relate to cash management, consider a U.S. organization that identifies cash buildup in a subsidiary based in China. While investigating tax-efficient ways to repatriate the cash, executives learn that the subsidiary was regularly using IP that was owned by another subsidiary outside of China.


The organization concludes that part of the reason for the excess cash buildup is the lack of a royalty charge into China. “Once the issue is identified and the transfer pricing problem corrected, it results in a reduction in the rate at which cash builds up going forward,” notes Mr. Yoo. Such an event, he explains, typically leads the organization to reconsider its cash management plans.


Spotting improper allocations is just one reason to consider a strategic approach. “More than a compliance exercise, strategic transfer-pricing also may help identify tax-efficient opportunities,” say Darcy Alamuddin, principal, Deloitte Tax LLP. For example, an organization may have the opportunity to utilize net operating losses in certain countries; deploy excess tax credits; migrate IP to low-tax countries; and clean up so-called de facto cost-sharing.

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Will Jack Lew curb tax inversions on his own?

Will Jack Lew curb tax inversions on his own? | Totally Tax | Scoop.it

The Treasury Department put out the word that Secretary Jack Lew is considering regulatory curbs on corporate tax inversions, a step that may be intended to increase pressure on Congress to act once it returns from its summer recess in September.

Chris Bale's insight:

Great article by Mr Gleckman...


The Treasury Department put out the word that Secretary Jack Lew is considering regulatory curbs on corporate tax inversions, a step that may be intended to increase pressure on Congress to act once it returns from its summer recess in September.


The matter of how much authority Treasury has to limit inversions has generated its own controversy. My colleague Steve Rosenthal and Harvard Law School professor Steve Shay argue that Treasury has broad authority to curb the practice. Others, including USC law professor Ed Kleinbard, are skeptical.


It appears, however, that the Administration may announce a move to limit inversions sometime next month. That could accelerate the pace of deals, as firms and their lawyers rush to beat any curbs. And it surely will increase pressure on Congress to act. Until now, lawmakers have been stuck in the usual partisan mire, unable to respond despite widespread rhetorical concerns from lawmakers of both parties about the practice.


Just by putting out the word that Lew is mulling administrative curbs, Treasury has sent a powerful signal to corporations. If they fear restrictions will be imposed retroactively, it could slow the deal train. But if lawyers don’t take that threat seriously, or write agreements to reflect that contingency, it is more likely to generate a rush to close deals ASAP.




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louise li's curator insight, August 23, 2014 2:36 AM

They should be asking why is this happening and address the cause - being high US corporate tax rates. Lower corporate tax rates assisted the UK.

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Medtronic paid tax lobby group $200,000 to help with Irish tax move via Covidien acquisition

Medtronic paid tax lobby group $200,000 to help with Irish tax move via Covidien acquisition | Totally Tax | Scoop.it
A battle in the US to try to block multinational corporations from shifting their tax base to low-tax countries such as Ireland is heating up.
Chris Bale's insight:

Former US senators Trent Lott and John Breaux have been hired to lobby for companies that want to preserve the option of reducing their corporate tax bills by moving their legal addresses overseas.


Nine US companies that have sought mergers for tax reasons, are considering doing so or are targets of such deals have been pressuring lawmakers since April in regard to legislation to stop the practice, federal disclosure reports show.


They include Medtronic, which is seeking to acquire Dublin-based Covidien. Medtronic paid Breaux-Lott Leadership Group $200,000 (€150,000) in June to try to block legislation from moving forward. Breaux, a Democrat, was once a member of the Senate Finance Committee. Lott, a Republican, is a former Senate majority leader.

US President Barack Obama has ordered officials to find ways to block the deals without congressional action.


To see the full article please click through to the Independent


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Average UK equity partner earnings: Accountants £700k, Lawyers £1.1million

The High Pay Centre has produced a report on Big 4 accounting firms and Magic Circle firms and partner earnings during 2013. 

Chris Bale's insight:

Of the 4,500 equity partners at the firms analysed (2,726 accountants, 1,774 lawyers), average pay in 2013 stood at £700,000 for the accountants and £1,100,000 for lawyers.


Click through to read the report from the High Pay Centre

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