Tax notes international

Share to Twitter Share to Linkedin Elodie Lamer and Nana Ama Sarfo of Tax Notes discuss the tax implications of golden visas and passports, which allow affluent foreigners to receive residency or citizenship in exchange for a minimum level of investment. This transcript has been edited for length and clarity. David D. Stewart: Welcome to the podcast. I'm David Stewart, editor in chief of Tax Notes Today International . This week: good as gold. The idea of immigration often conjures up black and white images of huddled masses on ships in New York Harbor. People seeking new opportunities to make their fortune. But what happens for people who've already made their fortune and don't have time to wait in line for the normal process? And what about the growing class of remote workers who don't need to be physically anywhere? This week, we're talking about golden passports with Tax Notes reporter Elodie Lamer and Tax Notes … [Read more...] about First-Class Tax Opportunities: Golden Visas And Passports

Share to Twitter Share to Linkedin Every U.S. Tax Court opinion in an IRC section 482 case dutifully recites some variation of the necessary incantation: The IRS has broad discretion in applying section 482 , and its determinations must be upheld unless the taxpayer can establish that the IRS abused its discretion by making adjustments that are “arbitrary, capricious, or unreasonable.” However, a substantive discussion of how that vague formulation should be applied in transfer pricing cases is much harder to find, and the Tax Court’s decades of manifest refusal to defer to the IRS’s section 482 interpretations compounds the mystery and confusion. Before the Tax Court issued its opinion in Coca-Cola Co. v. Commissioner , 155 T.C. 145 (2020), the most substantive guidance on the matter arguably came from a 1935 case that predates section 482 and the Tax Court itself. In Asiatic Petroleum Co. v. Commissioner , 31 B.T.A. 1152, 1157 (1935), aff’d … [Read more...] about Reviewing Standard Of Review After Tax Court’s Coca-Cola Opinion

Share to Twitter Share to Linkedin As we enter the middle of Tax Season 2021, I'm hearing a lot of people asking the following questions about their mortgage interest, "Can I still deduct my home equity line of credit ? Should I refinance to make it tax-deductible again? How do I know if I can deduct the home equity line of credit (HELOC) interest?" Below, we will answer your questions and more. Home Equity Lines of Credit (HELOC) Basics This mortgage tax break continues to confuse many homeowners when filing taxes. Adding to the confusion are the mortgage tax deduction changes in the Tax Cuts and Jobs Act (TCJA) of 2017 . I have been vocal over the years about how bad these changes are for most of my home-owning clients. For many homeowners, there are quite a few cases where the interest on a HELOC can be deductible, but there are also many times HELOC interest will not be tax-deductible. For those with valuable real estate holdings, just a … [Read more...] about Can I Still Get A Tax Deduction For My HELOC Mortgage?

Philip Morris International Inc. agreed to buy smokeless tobacco company Swedish Match AB in a $16 billion transaction to hasten its push beyond cigarettes. The maker of Marlboros offered 106 kronor a share ($10.56) for the smaller business, it said in a statement. Wednesday, a premium of nearly 40% to Swedish Match’s closing price on Monday. The board of directors at the Stockholm-based company said shareholders should accept the offer. The agreement with Swedish Match, whose vision statement is “a world without cigarettes,” ranks as one of the largest transatlantic deals this year and thrusts Philip Morris into the highly competitive field of oral nicotine products, many of which are very different from the chewing tobacco of the past. It also opens up the large and growing U.S. smoking alternatives market to the company, at a time when it’s looking at ways to exit Russia after its invasion of Ukraine. The tobacco giant has been at the forefront of the industry’s push to … [Read more...] about Philip Morris International to buy smokeless-tobacco maker Swedish Match

Share to Twitter Share to Linkedin Tax audits are down. By a lot. Internal Revenue Service audit rates of individual taxpayers’ returns have dropped for all income levels from tax years 2010 to 2019, according to a new Government Accountability Office report. On average, individual tax returns were audited over three times more often for tax year 2010 (0.9 percent) than for tax year 2019 (0.25 percent). Audit rates for taxpayers with incomes between $200,000 and $500,000 saw the biggest drop (a 92% drop), from 2.3% in 2010 to 0.2% in 2019. For the highest income taxpayers, those with income of $10 million or more, the audit rate dropped from 21.2% in 2019 to just 3.9% in 2019 (an 81% drop). Here’s a look at how much audit rates are declining: Table 3 in the report, Trends of IRS Audit Rates and Results for Individual Taxpayers by Income , has more detailed numbers. The drop in audits is good news for tax cheats and bad news for the rest of … [Read more...] about IRS Tax Return Audit Rates Plummet

Walmart Inc said on Thursday it would give nearly half its U.S. employees free Samsung phones by the end of the year. Walmart reported stronger sales for its fiscal first quarter, but its profit took a beating as the nation's largest retailer grappled with surging inflation on food and fuel and higher costs from a snarled global supply chain. The company also on Tuesday cut its full-year earnings forecast, sending shares down more than 8% in morning trading. Walmart Inc., based in Bentonville, Arkansas, is among the first major retailers to report quarterly results and is considered a major barometer of spending given its size and the breadth of its customer base. Like many big box retailers, Walmart benefited in the early days of the pandemic as shoppers splurged on food and other necessities, particularly online. But shoppers are resuming to pre-pandemic behaviors like pulling back their spending online and going back to the physical stores. And supply chain clogs and … [Read more...] about Walmart Q1 profit dragged down as inflation takes a bite

On December 3, Rohit Kulkarni (name changed on request), a 38-year-old New Delhi-based marketing executive, got a text message. The message read: “Dear Rohit, Congratulations!! Your PAN <his actual 10-digit PAN unmasked> is eligible for a pre-approved personal loan of Rs 5 lakh from NAVI. Apply now (followed by a link).” At first, Kulkarni thought it was spam—someone trying to sell something. No surprises there; he was used to such unsolicited messages. Then, Kulkarni saw something unusual in the message: his permanent account number (PAN). And it wasn’t even masked. “How can the company send an SMS so blatantly to random individuals with the full PAN card details in it and unmasked?” a stunned Kulkarni asked, noting that even the income tax department sends messages with PAN details masked. Several others too complained on Twitter of being approached by Navi in a similar fashion, getting text messages with their unmasked PAN details. So now Navi has my pan … [Read more...] about Navi spams users with loan offers containing PAN data, faces social media backlash

Share to Twitter Share to Linkedin The pandemic has exposed inequality of those who lack broadband, connected devices and digital skills to work, learn, and receive healthcare online. Policy research has emerged to study why broadband infrastructure and adoption shortfalls remain in a multi-trillion market. The short answer is a lack of business models. More largely, broadband policy has been slow to evolve, and the largest and richest internet platforms have lobbied to insulate themselves from financial obligations for universal access. Admittedly the notions of universal access differ across time and country and can be addressed in different ways. Presently the costs of connectivity are borne by end users and broadband providers, and yet, a class of companies profit disproportionately from the internet but do not contribute to the cost recovery of middle and last mile networks. Notably tech companies like Google, Facebook, Microsoft, Amazon, Apple, and … [Read more...] about The Growing Global Movement For Fair Cost Recovery On Broadband Networks

The market breadth was in favour of bears as four-and-half shares declined for every share rising on the NSE. The Nifty50 on May 11 failed to hold on to the early rebound and traded lower for a major part of the session amid volatility, continuing the downtrend for the fourth consecutive session. Auto, technology, and FMCG stocks were under pressure. The index smartly defended the psychological 16,000 mark and recouped more than 170 points from the day's low to form a bearish candle which resembles the Hammer kind of pattern on the daily charts. The Hammer is a bullish reversal pattern formed after a decline. It consists of no upper shadow, a small body, and a long lower shadow. The long lower shadow signifies the stock bounced back after testing its support, where demand is located. Experts say generally such pattern formation is an indication of some kind of pullback rally but only if the coming session closes on a strongly positive note. The volatility index climbed … [Read more...] about Technical View | Nifty forms Hammer pattern, pullback trade likely

Bloomberg Inflation is often viewed as an economic phenomenon, with mostly economic effects. Policy makers today worry about what inflation will do to the housing market; they express concern about government borrowing costs. They might note changes in individual economic behavior: a shopper pinching pennies at the grocery store. Politicians will worry about being voted out of office if they are blamed for its economic impact. But inflation is associated with more than just economics and electability. It is also linked to political instability. The historical record contains many cases where inflation went hand in hand with major political realignments, coups and even bloody revolutions. This history is worth keeping in mind as countries throughout the world grapple with spiraling prices. That inflation could fuel political instability — or vice versa — may seem self-evident, but teasing out a causal relationship is easier said than done. It’s a classic chicken-and-the-egg … [Read more...] about Which Comes First: Inflation or Political Instability?: Stephen Mihm