United States: Why Has The IRS Outsourced Microsoft’s Transfer Pricing Audit To A Private Law Firm?

Perhaps it was just a matter of time until the Internal Revenue Service decided to “outsource” its tax audit and litigation function to a private entity, i.e., a law firm. As reported in the December 8th issue of Tax Notes, the Service has hired the law firm of Quinn Emanuel Urquhart & Sullivan LLP, at a cost of more than $2 million, to assist in the transfer pricing audit of Microsoft Corp., signaling a […]

By |December 9th, 2014|

Canada: Secured Creditors Can Appeal To Tax Court On Behalf Of A Bankrupt

The Tax Court of Canada recently confirmed in International Hi-Tech Industries Inc v The Queen, 2014 TCC 198, that in certain circumstances a secured creditor can commence or continue a tax appeal on behalf of a bankrupt estate.

The Appellant was a bankrupt corporation. Prior to bankruptcy, it granted a general security agreement (GSA) to its holding company and other related companies. The appeal related to alleged GST miscalculations of input tax credits (ITCs) by […]

By |December 9th, 2014|

Switzerland: Schweizerische Nationalbank : Swiss Say Foreign Millionaires Still Welcome After Vote

Swiss voters refused to give up a 152-year-old tax break for rich foreigners in Geneva and other wealthy areas that the government says helps the economy.

Fifty-nine percent voted against an initiative, sponsored by the Socialist Party, that would have abolished a system allowing foreigners to duck income and wealth taxes by negotiating lump-sum payments with Swiss cantons, the government said yesterday. Two other proposals, on the Swiss National Bank’s gold holdings and on immigration […]

By |December 8th, 2014|