Topic
Tax Avoidance
133 published works
Milikowsky Tax Law Blog
Tax Avoidance vs Tax Evasion
What is Tax Avoidance vs Tax Evasion exactly? There are two things you can be sure of. Death & Taxes. No one likes either. The US Tax system was predicated…
Wills, Trusts & Estates Prof Blog
Article on The Possibility for Stateless Dynastic Wealth and the Case of China
Mike P. Gergen recently published an article entitled, The Possibility for Stateless Dynastic Wealth and the Case of China, Wills, Trusts, & Estates Law ejournal (2020). Provided below is the abstract…
India Tax Law
“Heads I win, tails you lose” approach of tax authorities rejected by Kolkata ITAT bench
By Akshara Shukla, CAM Tax Team
In its recent ruling[1], Kolkata bench of Income Tax Appellate Tribunal (“ITAT”) rejected the retrospective application of General Anti-Avoidance Rule (“GAAR”) on a scheme of amalgamation approved by the Punjab…
International Financial Law Prof Blog
Ireland and Apple Win State Aid Case!
Scroll down to paragraph 241-245 for the application of arm's length to the Irish branches, paras 255-309, and then paragraph 322 for the analysis of the application of the TNMM…
Tax
Tax Avoidance or Tax Evasion, What’s the Difference?
Tax Avoidance vs Tax Evasion Tax Avoidance vs Tax Evasion Tax Evasion vs Tax Avoidance: When it comes to taxes and the IRS, sometimes there is a fine-line between planning…
International Financial Law Prof Blog
Eighth Circuit Upholds Determination that Wells Fargo is Liable for Penalties for Engaging in Abusive Tax Shelter Scheme
The Eighth Circuit Court of Appeals issued a precedential opinion on Friday, April 24, 2020, affirming a district court decision that a transaction designed to generate massive foreign tax credits…
International Financial Law Prof Blog
The UK Govt (Parliament and HMRC) Deals With Tax Avoidance Schemes So Differently than the U.S.
In September 2019, the Government commissioned Sir Amyas Morse to lead the independent loan charge review. The loan charge is designed to tackle disguised remuneration tax avoidance schemes. These are…
International Financial Law Prof Blog
HMRC v Hicks: how much diligence must the accountant due regarding the tax scheme?
Factual background (read case here) 12. The underlying facts were not in dispute and can be summarised as follows. It will be seen later in this decision, however, that HMRC…
The CLS Blue Sky Blog
Criminal Penalties on Officers Can Deter Corporate Tax Avoidance
There is a worldwide debate over how to prevent overly aggressive corporate tax avoidance. In 2015, the Australian government doubled civil penalties on large multinational corporations that engage in the…
Tax Talks
Extended tax liabilities for directors in insolvencies linked to tax avoidance
By Philip Gilliland, Stephen Pevsner
Draft legislation included in the Finance Bill 2019-2020 will potentially make directors and certain other individuals closely connected to a company jointly and severally liable for a company’s tax liabilities…