The principle focus of the report is for the shifting of otherwise taxable U.S. income overseas, particularly by large corporations. While that is a phenomenon in the secret offshore bank area, the report is principally concerned with transfer pricing and other opportunities to shift, of the type recently investigated by the Senate Permanent Subcommittee on Investigations, which I previously report on. See U.S. Senate Committee Investigation of Crackdown on Offshore Tax Evasion (Federal Tax Crimes Blog 2/20/14), here.
From the press release:
- General Electric paid a federal effective tax rate of negative 11.1 percent between 2008 and 2012 despite being profitable all of those years. The company received net tax payments from the government. GE maintains18 subsidiaries in tax haven in 2013 and parked $110 billion offshore. One of the company’s most lucrative loopholes just got renewed by the Senate Finance Committee. GE alone hired 48 lobbyists to push to renew the “active financing exception.”
- Microsoft avoided $4.5 billion in federal income taxes over a three year period by using sophisticated accounting tricks to artificially shift its income to tax-friendly Puerto Rico. Microsoft maintains five tax haven subsidiaries and keeps $76.4 billion, on which it would otherwise owe $24.4 billion in additional U.S. taxes.
- Pfizer paid no U.S. income taxes between 2010 and 2012 because the company reported losses in the U.S. during those years, despite making 40 percent of its sales in the U.S. and earning $43 billion worldwide. The company operates 128 subsidiaries in tax havens and has $69 billion parked offshore which remains untaxed by the U.S., according to its own SEC filing.
I believe we tend to think that the Criminal Defense attorney Houston.
ReplyDeletefor example, are defending the most wicked of criminals. That's what TV shows
would have us believe. They can defend the innocent as well though.
Hello Jack,
ReplyDeleteLooking at public information it seems that your list is probably correct.
Other websites especially did not list the tiny "Neue Privat Bank" as
Category 1 but the speaker of the bank confirmed that they were contacted by
the US authorities and are in negotiations.
The following links summarize the bank's choices where the second one seems to
be most up-to-date. A lot of the foreign banks in Switzerland are missing in
the lists as they did not make public statements about their choice but their
association speaker confirmed that most of them participate in the Program.
http://www.nzz.ch/wirtschaft/wirtschafts-und-finanzportal/die-schweizer-banken-geben-nach-1.18207257
http://www.ustaxprogram.com/banks/
http://www.financecorner.ch/liste-des-banques-suisses-participant-au-programme-us/
http://sites01.20min.ch/steuerstreitusa/grad/