2011 Offshore Voluntary Disclosure Initiative Frequently Asked Questions and Answers. The following scenarios are provided to illustrate the effect of a taxpayer opting out of the civil settlement structure.
Opting out of the civil settlement structure does not affect the status of a taxpayer’s voluntary disclosure under Criminal Investigation’s Voluntary Disclosure Practice, so long as the taxpayer is fully cooperative in the examination process, by providing all requested foreign records and submitting to interviews, as requested, and as long as no new issues are uncovered that were previously not disclosed. The facts of each example were chosen to illustrate particular issues and do not represent a full analysis of a taxpayer’s particular situation. Consequently, they may not be relied upon in dealing with any taxpayer’s actual case. For all of the following examples, assume a 35% tax rate on all unreported income.
Example 4 - Large Unreported Gain The Offshore Penalty under 2011 OVDI will be $2,500,000 (i.e., 25% of $10 million). IRS Readies Enforcement Against at Least One Overseas Bank. The Internal Revenue Service is planning an imminent enforcement action against one or more non- U.S. banks, a top agency official said.
“The IRS plans to move against one or more banks in the next month or so,” Steven Miller, deputy commissioner for services and enforcement, said at a conference in Washington on June 7. In recent years, the IRS and the Justice Department have stepped up enforcement to combat offshore tax evasion. UBS AG (UBSN), Switzerland’s largest bank by assets, was charged in February 2009 with helping U.S. citizens evade taxes. The bank avoided prosecution by paying $780 million, admitting that it fostered tax evasion, and agreeing to give data to the IRS on more than 250 accounts. UBS later handed over data on an additional 4,400 accounts to resolve an IRS lawsuit. In February, four Europe-based bankers at Credit Suisse Group AG (CS) were indicted in federal court in Alexandria, Virginia, accused of conspiring to help U.S. clients evade taxes.
Action Against HSBC. Google Bermuda: here's how the world's most powerful tech company is avoiding taxes to the tune of $1 billion per year. The Tax Haven That's Saving Google Billions. The heart of Google's (GOOG) international operations is a silvery glass office building in central Dublin, a block from the city's Grand Canal.
In 2009 the office, which houses roughly 2,000 Google employees, was credited with 88 percent of the search juggernaut's $12.5 billion in sales outside the U.S. Most of the profits, however, went to the tax haven of Bermuda. To reduce its overseas tax bill, Google uses a complicated legal structure that has saved it $3.1 billion since 2007 and boosted last year's overall earnings by 26 percent. While many multinationals use similar structures, Google has managed to lower its overseas tax rate more than its peers in the technology sector.
Its rate since 2007 has been 2.4 percent. G.E.’s Strategies Let It Avoid Taxes Altogether. Drew Angerer/The New York Times <strong>A PRESIDENT’S BUSINESS LIAISON</strong>In January, President Obama named Jeffrey R.
Immelt, General Electric’s chief executive, to head the President’s Council on Jobs and Competitiveness. “He understands what it takes for America to compete in the global economy,” Mr. Obama said. A Wealth of Exceptions Articles in this series will examine efforts by businesses to lower their taxes and the debate over how to improve the tax system. SPECIAL INVESTIGATION: 1,000 tax haven subsidiaries of the top 20 companies. By Lawrie Holmes and Alex HawkesUPDATED: 22:10 GMT, 22 January 2011 When Barclays boss Bob Diamond confirmed that the bank had about 300 subsidiaries in tax havens there were gasps of dismay at a Treasury Select Committee hearing earlier this month.
Few at the highly charged meeting would have believed such a vast network of offshore companies existed, potentially allowing the bank and its clients to avoid huge sums in tax. They would still be in the dark had MP Chuka Umunna not put the figure to Diamond in the first place. But a Financial Mail investigation can reveal that Barclays' Byzantine structure is far from unusual.
In fact it is more the tip of the iceberg as far as Britain's biggest companies are concerned. Tucked away: Many of BP's companies are based in Bermuda. The Double Irish - How Companies Bypass the US High Income-Tax Rate. Lowtax.net - Offshore, Tax, Law, Business, E-commerce Information Resource. Tax havens under pressure: Whiter than white.