BMC Software loses $13 million to IRS after repatriating $717.2 million

“In a decision that could have implications for other companies in similar disputes with the IRS, the Tax Court said BMC owes taxes on a portion of its foreign profits brought into the United States under the 2004 tax break. In 2004, President George W. Bush signed into law a repatriation holiday that allowed multinational U.S. businesses to bring foreign profits into the United States at a 5.25 percent tax rate, rather than the then current 35 percent rate.  In 2005, BMC repatriated $717.2 million.  Analog Devices Inc, a Massachusetts-based circuit-maker, has a similar dispute over $26 million pending with the IRS.”

http://finance.yahoo.com/news/bmc-software-loses-13-million-215243449.html

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More Africans leaping Spanish border fence to enter Europe

“Growing numbers of Africans are taking a daunting test to enter to Europe: leaping a towering, triple-layer security fence and trying to race across before rapid-deployment police guards can catch them.  A vast security operation has failed to deter the would-be migrants attempting to reach the Spanish territories of Ceuta and Melilla, cities that lie on the northern coast of Morocco and offer the only land border between Africa and Europe.   Surveillance cameras watch over the three layers of fencing, which is lit up along its entire length to help spot migrants.  On the other side stands Mount Gurugu where hundreds of African migrants lie in wait for the right moment to make a dash for European soil.”

http://www.rawstory.com/rs/2013/10/22/more-africans-are-leaping-security-fence-to-enter-europe-through-spanish-border/

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U.S. tax law has some expatriates waiving the American flag

“Proponents of the law, including President Obama, praise it as an important tool to help ferret out wealthy tax cheats in America and abroad suspected of hiding millions or even billions of dollars in offshore accounts.  But it has also wreaked havoc on many upstanding Americans who have settled overseas for reasons of love, work or adventure, and who now say they are having trouble buying a home, paying for their kids’ education or planning for a comfortable retirement. Because of FATCA, some overseas banks are refusing to take on American customers, declaring themselves unwilling or financially unable to report information to the IRS, the tax agency of a foreign nation.”

http://www.latimes.com/world/la-fg-us-citizens-abroad-20131014,0,7445958,full.story

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FATCA: Making the world support US Homelanders

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“I am proud to be a large corporation operating all over the world and having subsidiaries worldwide. I have really worked hard over several decades to establish myself with a global footprint and my products serves the need of old and young irrespective of nationalities and ethnicities and people from every background and every facets of life. Uncle Sam calls me a global giant with a local approach.  Uncle SAM re-named me as a NFEE (Non-Financial Foreign Institution) for FATCA purposes which is applicable 1 July 2014 onwards. He told that it’s not only the non US financial institutions but non US NFEE as well who may be subject to FATCA compliance.”

http://isaacbrocksociety.ca/2013/10/09/fatca-making-the-world-support-us-homelanders/

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New Corporate Tax Shelter: A Merger Abroad

“From New York to Silicon Valley, more and more large American corporations are reducing their tax bill by buying a foreign company and effectively renouncing their United States citizenship. Reincorporating in low-tax havens like Bermuda, the Cayman Islands or Ireland — known as ‘inversions’ — has been going on for decades. But as regulation has made the process more onerous over the years, companies can no longer simply open a new office abroad or move to a country where they already do substantial business. Instead, most inversions today are achieved through multibillion-dollar cross-border mergers and acquisitions.”

http://dealbook.nytimes.com/2013/10/08/to-cut-corporate-taxes-a-merger-abroad-and-a-new-home/

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Foreign investors: Why US bank may close your account

“El Paso’s international trade traffic in 2011 was greater than the trade traffic passing through San Diego, Calif. and Nogales, Ariz. combined.  With such cross-border economic activity it is only natural for foreign businesses to maintain U.S. bank accounts in El Paso. Unfortunately, many of these commercial accounts are being closed by U.S. banks. Why is this happening? The answer can be traced back to the bank formerly known as the Hong Kong Shanghai Banking Corporation and its violations of the 2001 Patriot Act – transgressions that a U.S. Senate subcommittee investigated and resulted in the assessment of a $1.9-billion penalty to HSBC in July.”

http://www.elpasoinc.com/columns/article_897770d4-2ea6-11e3-bcfd-0019bb30f31a.html

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Eighth Amendment circumvented through plea bargaining

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“Pius Kampfen, a retired Swiss banker living in California, became a US citizen in 2006, has agreed to pay a penalty of 1.5 million on a high account balance of $2,930,785.  Tax owing to the US was minimal ($4,945 according to the government’s reckoning).  The penalty is thus 300x the damage to the government in uncollected taxes.  Jack Townsend comments,  ‘With the indicated tax loss, and the reference to the tax loss table for setting the base offense level, the sentence seems to be not out of line with other sentences.  But, I wonder why the Government would have prosecuted the case with such a small tax loss.  Certainly, probably his role as a Swiss banker himself probably was in the mix.'”

http://isaacbrocksociety.ca/2013/10/09/eighth-amendments-no-excessive-fines-clause-circumvented-through-plea-bargaining/

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FATCA: Breaking through Fear with a Swiss Referendum

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“The Swiss are likely to vote to overturn a FATCA agreement with the US Treasury Department, which has recently been ratified by Parliament. On October 8, a STOP-FATCA referendum committee has been set up, amid skepticism and fears of US reaction.  The best allies of the Swiss referendum abroad might be found in the United States, where James George Jatras and his web site RepealFatca.com are following the gathering of signatures with a mixture of joy and hope. If the referendum committee manages to gather 50’000 signatures by January 16, the Swiss people will be called on to vote on the matter in the course of the first half of 2014.”

http://isaacbrocksociety.ca/2013/10/19/fatca-breaking-through-fear-with-a-swiss-referendum-2/

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‘We Are Not A Myth’

“Innocent Families Negatively Impacted by FATCA. Treasury Dept. Says We Are A ‘Myth’.”

http://we-are-not-a-myth.tumblr.com/

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Swiss war game envisages invasion by bankrupt French

“Carried out in August, the apparently outlandish army exercise was based on the premise of an attack by a financially stricken France split into warring regions, according to Matin Dimanche, the Lausanne-based daily.  Famous for its bank secrecy laws, Switzerland often comes under criticism for allowing foreign account holders to hide their wealth from tax officials at home. This is by no means the first imaginary scenario dreamed up by the Swiss army. Last year, it carried out an exercise based on the premise that a huge wave of refugees crossed into the country after the implosion of the European Single Currency and ensuing chaos across the continent.”

http://www.telegraph.co.uk/news/worldnews/europe/switzerland/10344029/Swiss-war-game-envisages-invasion-by-bankrupt-French.html

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