Monthly Archives: February 2018

The tax laws generally provide that a taxpayer seeking to change its annual accounting period and use a new taxable year needs to get the approval of the IRS.

In general, the newly enacted section 965 of the tax code that was included in the Tax Cuts and Jobs Act imposes a transition tax on untaxed foreign earnings of foreign subsidiaries of U.S. companies by deeming those earnings to be repatriated.

Foreign earnings held in the form of cash and cash equivalents are taxed at a 15.5 percent rate, and the remaining earnings are taxed at an 8 percent rate. The transition tax generally may be paid in installments over an eight-year period.

The new revenue procedure was issued to prevent the avoidance of the purposes of section 965 through changes in the taxable years of certain foreign corporations, such as controlled foreign corporations that are effectively subsidiaries of U.S. corporations.  

Rev. Proc 2018-17 will be published in IRB 2018-09 on Feb. 26, 2018. 

On November 17, 2017 we posted How Will The IRS Know? - The Paradise Papers Exposes US Clients of Asiaciti Trust! where we discussed that Appleby, an Offshore Law Firm/Corporate Agent's Recent Data Breach is yet Another Example of How the IRS Can Discover your Unreported Foreign Account and how the Super-rich clients of offshore law firm Appleby are bracing themselves for the exposure of their financial secrets, after the firm admitted data had been stolen in a cyber attack last year.

 

Now the International Consortium of Investigative Journalists (ICIJ) has issued the Paradise Papers which is a global investigation into the Asiaciti files.

 

According to ICIJ a total of More Than 85,000 ENTITIES and

More than 110,000 Officers from the Paradise Papers will be added to the Offshore Leaks Database on

Wednesday, February 14, 2018. 

 

With this release information on more than 290,000 companies related to the Paradise Papers will be available in the database, more than from any of our previous leaks.

The new data comes from three corporate registries: the Cook Islands, Samoa – a member of the Commonwealth of Nations and one of two jurisdictions that make up the Samoan Islands – and Malta. It is valid until the end of 2016. All of the jurisdictions rank high on the Tax Justice Network’s secrecy index, either on secrecy only or on secrecy weighted by their share of the offshore market.

Hidden in the Malta records was also the head of Sweden’s largest business lobby. Leif Östling, chairman of the Confederation of Swedish Enterprise and the former head of the truckmaker Scania, who with his wife owned a Maltese company called Hertsoe Ltd. that held about $3.6 million worth of stock via subsidiaries in Luxembourg, ICIJ partner SVT (Swedish public television) reported. He resigned following the revelations.

Malta was also the tax haven of choice of pop stars Shakira and Bono. The U2 lead singer was a Guardian. Yet, the Lithuanian company agreed to pay back 53,000 euros ($65,000) as well as a fine, following an investigation into its tax affairs prompted by the Paradise Papers. Bono later announced he had instructed his advisers to end his investment in the company.
minority shareholder of a Malta-based entity that bought a shopping center in a small town in Lithuania. The company was later transferred to Guernsey, a jurisdiction that doesn’t charge tax on corporate profits. After Lithuanian authorities announced a probe into the company’s business, Bono said that he welcomed the audit and that he has “been assured by those running the company that it is fully tax-compliant,” according to the

As for the Colombian singer Shakira, she was actually using the tiny island of Malta to transfer more than $30 million of music rights, according to Spanish paper El Confidencial. Shakira was listed as the sole shareholder of the Maltese company which, her lawyers told reporters, “fulfills all legal requirements.” The singer is currently under investigation in Spain for tax evasion.

 

Contact the Tax Lawyers at 

Marini & Associates, P.A.  

 

 

for a FREE Tax Consultation

at: www.TaxAid.com or www.OVDPLaw.com or

Toll Free at 888-8TaxAid (888) 882-9243