Category: International Tax Planning

04

Oct2017
President Trump and the Republican party issued a tax reform “framework” plan on September 27. It’s only 9 pages long so we don’t yet have full details and it has yet to be enacted. Given that, what’s in store for US businesses, US Olim, and everyone else? Business Taxation The framework proposes ... Read More
October 4, 2017Leon Harris

27

Sep2017
The Israeli Tax Authority published final instructions regarding Reverse Vesting shares on June 5 (Circular 5.2017. This will be of interest to many people in the Start-Up Nation. Until now, founders and key personnel holding 10% or more of a company seemed to miss out on the opportunity to pay only 25% tax ... Read More
September 27, 2017Leon Harris

19

Jul2017
The world’s tax treaties have just undergone instant plastic surgery. Unfortunately, they aren’t as pretty as they used to be. One of the surgeons in attendance was the Israeli finance minister, Moshe Kahlon. It all happened on June 7 in Paris, when the OECD held a grand signing ceremony fora new ... Read More
July 19, 2017Leon Harris

08

Jun2017
Once upon a time in Never Land, a high tax country, Old Macdonald Inc. (OMI) hit upon a way of converting carrots into 24 carat pure gold at minimal cost. Unable to believe its good fortune, OMI licenses this knowhow to its subsidiary company OMI Offshore Ltd in Utopia, an ... Read More
June 8, 2017Leon Harris

22

Mar2017
March 22, 2017Leon Harris

22

Mar2017
March 22, 2017Leon Harris

23

Jan2017
At his inaugural speech on January 20, President Trump espoused two economic principles: "Buy American and Hire American". What else can the rest of the world expect? Immediately after the inauguration, the White House website provided a few more insights (https://www.whitehouse.gov/america-first-foreign-policy) "The world must know that we do not go abroad in ... Read More
January 23, 2017Leon Harris

27

Dec2016
Wouldn't it be nice if you could complain about tax authority bureaucracy. Now you can, if the complaints relate to failed attempts to apply tax treaty dispute resolution procedures. But hurry, there isn't much time to file the complaint. The Background – BEPS: On October 5, 2015 the OECD published a comprehensive ... Read More
December 27, 2016Leon Harris

26

Dec2016

Your Taxes: Apple Sauce

The European Commission announced on August 30, 2016 that that Ireland granted undue tax benefits of up to €13 billion to Apple (http://europa.eu/rapid/press-release_IP-16-2923_en.htm).  The Commission said this is illegal under EU state aid rules, because it allowed Apple to pay substantially less tax than other businesses. Ireland must now recover ... Read More
December 26, 2016Leon Harris

26

Dec2016
The OECD has issued revised draft guidance on profit splits within multinational groups for transfer pricing purposes (BEPS Actions 8-10, Revised Guidance on Profit Splits July 4 – September 5, 2016). Israel joined the OECD in 2010. Why is this important? We live in a global village, but customers in each country ... Read More
December 26, 2016Leon Harris