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Tax Avoidance

123 published works

  1. European Union and Italian International Tax Law Blog

    Italian Supreme Court Held That Burden of Proof in Tax Avoidance Cases is Upon Taxpayers

    By Marco Rossi

    Italian Supreme Court in judgment n. 8487 of April 8, 2009 placed upon taxpayers the burden to prove the existence of valid economic reasons to avoid the application of anti…

  2. European Union and Italian International Tax Law Blog

    Special Audits and Rulings for “Big Taxpayers”

    By Marco Rossi

    Big taxpayers are subject to automatic audit

  3. European Union and Italian International Tax Law Blog

    Italy’s Tax Administration Clarifies New Tax Avoidance Ruling Procedure

    By Marco Rossi

    Italy's tax administration clarified new tax avoidance ruling procedure. The ruling must be issued within 120 days from taxpayer's application. Failure to issue the ruling within 180 days from taxpayer's…

  4. Securities Law Prof Blog

    UBS Settles SEC Charges It Facilitated Clients’ Tax Avoidance

    By Securites Lawprof

    The SEC filed an enforcement action against UBS AG, charging the firm with acting as an unregistered broker-dealer and investment adviser.  According to its complaint, UBS's conduct facilitated the ability…

  5. European Union and Italian International Tax Law Blog

    Burden of Proof of Tax Avoidance on Tax Administration, Italian Supreme Court Says

    By Marco Rossi

    The Tax Section of the Italian Supreme Court in its judgment n. 1465 of January 21, 2009 held that the tax administration bears the burden to prove that a transaction…

  6. European Union and Italian International Tax Law Blog

    Italian Supreme Court Applies General Anti-Avoidance Principle

    By Marco Rossi

    With two very important decisions issued on December 23, 2008 and concerning a dividend washing and dividend stripping transaction, the Italian Supreme Court for the first time applied a general…

  7. Legal Profession Blog

    No Misconduct Found

    By Michael Frisch

    In a disciplinary case where the accused had "represented entities that invested and participated in a tax avoidance enterprise created by Walter J. Hoyt, III," the Supreme Court of Oregon…

  8. Wills, Trusts & Estates Prof Blog

    IRS cautions about trust arrangements presented as welfare benefits

    By Gerry W. Beyer

    The Internal Revenue Service has recently issued two Notices and a Revenue Ruling, urging taxpayers to exercise caution with regard to certain trust arrangements sold to small businesses as welfare…

  9. The Right Coast

    Irish tax authorities can’t find what they’re looking for Tom Smith

    By Thomas A. Smith

    U2's Bono is fighting for more aid to Africa, but U2 is moving its business domicile to the Netherlands to avoid high Irish taxation.  Back when I was a firm…

  10. Wills, Trusts & Estates Prof Blog

    Patent Your Favorite Tax-Saving Technique?

    By Gerry W. Beyer

    There is a growing trend for lawyers to patent tax-saving techniques which they have developed.Here are some excerpts from Jeremy Kahn, Taxes: Patent that loophole, Fortune, Aug. 30, 2006:In recent…