A primer for "deferral" in U.S. international tax discussion

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A primer for "deferral" in U.S. international tax discussion

Post by SonomaCat » Wed May 13, 2009 1:12 pm

I spent yesterday at a software/e-commerce tax seminar hosted by one of the big international tax law firms (B&M, for those who care), and they had a lot of great insights into the proposed tax legislation. Of particular note was the proposed tax changes in the area of international tax and some frustrations with the public's lack of understanding of the topic. One of the presenters played this youtube clip that he thought might be good to pass along, and it is actually pretty decent (it over simplifies things, but I think you almost have to unless a person is really, really intersted in the very technical and dry subject matter).

So ... here it is:

http://www.youtube.com/watch?v=hapfclt6mFY

As a sidenote (Grizlaw, you in particular will understand and probably relate to this), when one of the attorneys started a discussion on the worst-case scenarios and started explaining how companies could invert (with his help and expertise and huge billing rates) their structure to essentially transform a U.S. multi-national a into multi-national based in some other country (historically tax havens like Cayman, but now apparently Switzerland is a more popular destination), a few people got pissed and walked out. It's a topic that conflicts a lot of tax folks. We all have a duty to the shareholders to keep the taxes as low as legally possible, but there is definitely an increasing ethical question being asked when it comes to creating structures specifically to avoid paying taxes ... especially ones that, on the surface (and in the eyes of the public) generally appear to be unpatriotic.



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