FT Alphaville » Tax

Spot the dodger

Paul Murphy — Tue, 12 Feb 2013 12:51:08 +0000

As part of its worthy attempt to herd the tax authorities of the world towards some form of global coordination on the taxation of multinational companies, the OECD offers us some examples of tax planning structures currently in use.

Skip to page 73 of this document. Can you guess who might be using an “E-commerce structure using a two-tiered structure and transfer of intangibles under a cost-contribution arrangement“?

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The big question that Starbucks raises, ft. Mr Potato Head

Lisa Pollack — Tue, 18 Dec 2012 10:26:23 +0000

International transfer pricing might not win any awards for sexy topic of the year, but it is what's at the heart of the debate around low corporate tax payments by the likes of Starbucks, Google, and Amazon.

To explain why, consider Mr Potato Head...

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Taxman goeth Buddhistheth

Lisa Pollack — Mon, 17 Dec 2012 12:49:56 +0000

Social media strategy is more of an art than a science, as HM Revenue and Customs was busy proving Monday morning as it tried to encourage people to file their taxes online by the end of next month...

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Case studies in low UK taxes: from lattes to water pipes

Lisa Pollack — Mon, 12 Nov 2012 11:32:56 +0000

Corporations appearing to not pay their fair share of tax in the UK is a running theme. Starbucks, Google, Amazon, and now water companies, are all having their turn in the limelight. Let’s have a brief tour around each.

Firstly, sorry to be the bearer of bad news — but it turns out that you aren’t paying enough for your extra hot single-shot caramel skinny latte (as per a Starbucks press release, emphasis ours):

Continue reading: Case studies in low UK taxes: from lattes to water pipes

Counting ghosts

Paul Murphy — Thu, 18 Oct 2012 15:18:13 +0000

And so to HMRC to examine the UK’s “tax gap” — the difference between tax actually collected and the tax that could theoretically be collected. Click to read.

The ‘gap’ in Britain is put at £32bn.

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Presidential optics vs the tax code

Joseph Cotterill — Fri, 21 Sep 2012 18:08:26 +0000

We’re scratching our heads.

The Romneys donated $4,020,772 to charity in 2011, amounting to nearly 30% of their income.

Continue reading: Presidential optics vs the tax code

Dead parrot sketch

Joseph Cotterill — Tue, 28 Aug 2012 12:08:29 +0000

“I’m really sick of this government giving away our taxes to those corrupt Greeks,” said the owner of a pet shop in Amsterdam who asked not to be identified by name because he does not declare all his income to the authorities.

How on Earth did we miss this last week, via Reuters? (H/T Pawelmorski)

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Barclays is one unhappy taxpayer

FT Alphaville — Tue, 29 May 2012 13:05:33 +0000

Just in case you missed it earlier — we thought it worth posting the full letter from Bob Diamond, Barclays chief executive, to Andrew Tyrie MP, Treasury Committee chairman, regarding HMT’s blocking of two tax schemes (one on buybacks of debt). This involved a rare use of retroactive legislation, if you recall.

Anyway, the letter (click image for full doc):

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The defeat of an FTC generator

Lisa Pollack — Fri, 25 May 2012 13:55:47 +0000

The investment that Hewlett-Packard made in an entity called Foppingadreef back in 1996, thinking that it would give rise to significant tax benefits over the next seven years, was not typical of so-called “foreign tax credit generators”.

Barclays’ structured trust advantaged repackaged securities (Stars) are perhaps the most well-known FTC generators and they have allowed multiple US banks to reduce their tax liabilities — though the Internal Revenue Service is challenging this in the courts.

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The anatomy of a transaction

Lisa Pollack — Fri, 25 May 2012 13:45:19 +0000

In our last post, we presented the genesis of a transaction set up by AIG Financial Products in 1996 that stood to reap significant tax benefits by generating an abundance of foreign tax credits (FTCs) as well as a deduction arising from a capital loss.

The Internal Revenue Service fought back when some of the benefits were claimed, and on May 14, 2012 they won in the US Tax Court, leading to the benefits being disallowed. This case, along with another won by the IRS in September last year, allows a rare glimpse into the world of international tax arbitrage.

Continue reading: The anatomy of a transaction