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Base Erosion And Profit Shifting (OECD Project)
The OECD G20 Base Erosion and Profit Shifting Project (or BEPS Project) is an OECD/ G20 project to set up an international framework to combat tax avoidance by multinational enterprises ("MNEs") using '' base erosion and profit shifting'' tools. The project, led by the OECD's Committee on Fiscal Affairs, began in 2013 with OECD and G20 countries, in a context of financial crisis and tax affairs (e.g. Offshore Leaks). Currently, after the BEPS report has been delivered in 2015, the project is now in its implementation phase, 116 countries are involved including a majority of developing countries. During two years, the package was developed by participating members on an equal footing, as well as widespread consultations with jurisdictions and stakeholders, including business, academics and civil society. And since 2016, the OECD/G20 Inclusive Framework on BEPS provides for its 140 members a platform to work on an equal footing to tackle BEPS, including through peer review of t ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Feargal O'Rourke
Feargal O'Rourke (born 3 August 1964) is an Irish accountant and corporate tax expert, who was the managing partner of PwC in Ireland. He is considered the architect of the ''Double Irish'' tax scheme used by U.S. firms such as Apple, Google and Facebook in Ireland, and a leader in the development of corporate tax planning tools, and tax legislation, for U.S. multinationals in Ireland. Personal O'Rourke comes from an established Fianna Fáil political family. He is the son of former Irish minister Mary O'Rourke, nephew of former Irish Tánaiste Brian Lenihan Snr, and cousin of former Irish Finance Minister Brian Lenihan Jnr, and former Irish Minister of State Conor Lenihan. He chaired the college branch of Fianna Fáil at UCD and joined the national executive on graduation. Double Irish O'Rourke was once labeled the "great architect" of the ''Double Irish'' base erosion and profit shifting ("BEPS") tool, as used by U.S. multinationals in Ireland such as Google, a known cl ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
CNBC
CNBC is an American List of business news channels, business news channel owned by the NBCUniversal News Group, a unit of Comcast's NBCUniversal. The network broadcasts live business news and analysis programming during the morning, Daytime television in the United States, daytime trading day, and early-evening hours, with the remaining hours (such as weekday prime time and weekends) are filled by business-related Television documentary, documentaries and reality television programming, as well as occasional NBC Sports presentations. CNBC operates an accompanying financial news website, CNBC.com, which includes news articles, video and podcast content, as well as subscription-based services. CNBC's headquarters and main studios are located in Englewood Cliffs, New Jersey, while it also maintains a studio at the Nasdaq MarketSite in Times Square, New York City. CNBC was originally founded in April 1989 as the Consumer News and Business Channel, a joint venture between NBC ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Direct Taxes
Although the actual definitions vary between jurisdictions, in general, a direct tax is a tax imposed upon a person or property as distinct from a tax imposed upon a transaction, which is described as an indirect tax. There is a distinction between direct and indirect taxes depending on whether the tax payer is the actual taxpayer or if the amount of tax is supported by a third party, usually a client. The term may be used in economic and political analyses, and may have legal implications in some jurisdictions. In the United States of America, the term has special constitutional significance because of two provisions in the U.S. Constitution that any ''direct taxes'' imposed by the national government be apportioned among the states on the basis of population. It is also significant in the European Union, where direct taxation remains the sole responsibility of member states. General meaning In general, a direct tax is one imposed upon an individual person ( juristic or natural) o ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Tax Treaties
A tax treaty, also called double tax agreement (DTA) or double tax avoidance agreement (DTAA), is an agreement between two countries to avoid or mitigate double taxation. Such treaties may cover a range of taxes including income taxes, inheritance taxes, value added taxes, or other taxes. Besides bilateral treaties, multilateral treaties are also in place. For example, European Union (EU) countries are parties to a multilateral agreement with respect to value added taxes under auspices of the EU, while a Convention on mutual administrative assistance in tax matters, joint treaty on mutual administrative assistance of the Council of Europe and the Organisation for Economic Co-operation and Development (OECD) is open to all countries. Tax treaties tend to reduce taxes of one treaty country for residents of the other treaty country to reduce double taxation of the same income. The provisions and goals vary significantly, with very few tax treaties being alike. Most treaties: * define ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Irish Section 110 Special Purpose Vehicle (SPV)
An Irish Section 110 special purpose vehicle (SPV) or section 110 company is an Irish tax resident company, which qualifies under ''Section 110'' of the '' Irish Taxes Consolidation Act 1997'' (TCA) for a special tax regime that enables the SPV to attain "tax neutrality": i.e. the SPV pays no Irish taxes, VAT, or duties. Section 110 was created in 1997 to help International Financial Services Centre (IFSC) legal and accounting firms compete for the administration of global securitisation deals, and by 2017 was the largest structured finance vehicle in EU securitisation. Section 110 SPVs have made the IFSC the third largest global Shadow Banking OFC. While they pay no Irish tax, they contribute €100 million annually to the Irish economy in fees paid to IFSC legal and accounting firms. In June 2016, it was discovered that US distressed debt funds used Section 110 SPVs, structured by IFSC service firms, to avoid Irish taxes on €80 billion of Irish domestic investments. ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Securitization
Securitization is the financial practice of pooling various types of contractual debt such as residential mortgages, commercial mortgages, auto loans, or credit card debt obligations (or other non-debt assets which generate receivables) and selling their related cash flows to third party investors as securities, which may be described as bonds, pass-through securities, or collateralized debt obligations (CDOs). Investors are repaid from the principal and interest cash flows collected from the underlying debt and redistributed through the capital structure of the new financing. Securities backed by mortgage receivables are called mortgage-backed securities (MBS), while those backed by other types of receivables are asset-backed securities (ABS). The granularity of pools of securitized assets can mitigate the credit risk of individual borrowers. Unlike general corporate debt, the credit quality of securitized debt is non- stationary due to changes in volatility that are time ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Corporation Tax In The Republic Of Ireland
Ireland's Corporate Tax System is a central component of Ireland's economy. In 2016–17, foreign firms paid 80% of Irish corporate tax, employed 25% of the Irish labour force (paid 50% of Irish salary tax), and created 57% of Irish OECD non-farm value-add. As of 2017, 25 of the top 50 Irish firms were U.S.–controlled businesses, representing 70% of the revenue of the top 50 Irish firms. By 2018, Ireland had received the most U.S. in history, and Apple was over one–fifth of Irish GDP. Academics rank Ireland as the largest tax haven; larger than the Caribbean tax haven system. Ireland's "headline" corporation tax rate is 12.5%, however, foreign multinationals pay an aggregate of 2.2–4.5% on global profits "shifted" to Ireland, via Ireland's global network of bilateral tax treaties. These lower effective tax rates are achieved by a complex set of Irish base erosion and profit shifting ("BEPS") tools which handle the largest BEPS flows in the world (e.g. the Double Ir ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Caterpillar Inc
Caterpillar Inc., also known as Cat, is an American construction, mining and other engineering equipment manufacturer. The company is the world's largest manufacturer of construction equipment. In 2018, Caterpillar was ranked number 73 on the ''Fortune'' 500 list and number 265 on the Global ''Fortune'' 500 list. Caterpillar stock is a component of the Dow Jones Industrial Average. Caterpillar Inc. traces its origins to the 1925 merger of the Holt Manufacturing Company and the C. L. Best Tractor Company, creating a new entity, California-based Caterpillar Tractor Company. In 1986, the company reorganized itself as a Delaware corporation under the current name, Caterpillar Inc. It announced in January 2017 that over the course of that year, it would relocate its headquarters from Peoria, Illinois, to Deerfield, Illinois, scrapping plans from 2015 of building an $800 million new headquarters complex in downtown Peoria. Its headquarters are located in Irving, Texas, since 2022 ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Tax Inversion
A tax inversion or corporate tax inversion is a form of tax avoidance where a corporation restructures so that the current parent is replaced by a foreign parent, and the original parent company becomes a subsidiary of the foreign parent, thus moving its tax residence to the foreign country. Executives and operational headquarters can stay in the original country. The US definition requires that the original shareholders remain a majority control of the post-inverted company. In United States federal legislation, US federal legislation a company which has been restructured in this manner is referred to as an inverted domestic corporation, and the term "corporate expatriate" is also used, for example in the Homeland Security Act of 2002. The majority of the less than 100 material tax inversions recorded since 1993 have been of US corporations (85 inversions), seeking to pay less to the US corporate tax system. The only other jurisdiction to experience a material outflow of tax inv ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Double Irish Arrangement
The Double Irish arrangement was a base erosion and profit shifting (BEPS) corporate tax avoidance tool used mainly by United States multinationals since the late 1980s to avoid corporate taxation on non-U.S. profits. (The US was one of a small number of countries that did not use a "territorial" tax system, and taxed corporations on all profits, no matter whether the profit was made outside the US or not, in contrast to "territorial" tax systems which tax only profits made within that country.) It was the largest tax avoidance tool in history. By 2010, it was shielding US$100 billion annually in US multinational foreign profits from taxation, and was the main tool by which US multinationals built up untaxed offshore reserves of US$1 trillion from 2004 to 2018. Traditionally, it was also used with the Dutch Sandwich BEPS tool; however, 2010 changes to tax laws in Ireland dispensed with this requirement. Despite US knowledge of the Double Irish for a decade, it was the Eur ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Time (magazine)
''Time'' (stylized in all caps as ''TIME'') is an American news magazine based in New York City. It was published Weekly newspaper, weekly for nearly a century. Starting in March 2020, it transitioned to every other week. It was first published in New York City on March 3, 1923, and for many years it was run by its influential co-founder, Henry Luce. A European edition (''Time Europe'', formerly known as ''Time Atlantic'') is published in London and also covers the Middle East, Africa, and, since 2003, Latin America. An Asian edition (''Time Asia'') is based in Hong Kong. The South Pacific edition, which covers Australia, New Zealand, and the Pacific Islands, is based in Sydney. Since 2018, ''Time'' has been owned by Salesforce founder Marc Benioff, who acquired it from Meredith Corporation. Benioff currently publishes the magazine through the company Time USA, LLC. History 20th century ''Time'' has been based in New York City since its first issue published on March 3, 1923 ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
