Tax and Accounting Correspondent
Lynnley's Feed
Jul 12, 2012

Man United move to Caymans could benefit Glazers in IPO

By Nanette Byrnes and Lynnley Browning

(Reuters) – Companies often incorporate in the Cayman Islands for tax reasons. But in the case of Manchester United, the English soccer team seeking an initial public offering on the New York Stock Exchange, the advantage accrues to its controlling family, the Glazers, at the expense of new public investors.

As part of its IPO, the legendary sports franchise will use a new Cayman Islands company to sell shares, even though the club’s operations are in Britain.

Jul 12, 2012

Soccer’s Man United move to Caymans could benefit Glazers in IPO

July 12 (Reuters) – Companies often incorporate in the
Cayman Islands for tax reasons. But in the case of Manchester
United, the English soccer team seeking an initial public
offering on the New York Stock Exchange, the advantage accrues
to its controlling family, the Glazers, at the expense of new
public investors.

As part of its IPO, the legendary sports franchise will use
a new Cayman Islands company to sell shares, even though the
club’s operations are in Britain.

Jul 9, 2012

Socialite Denise Rich dumps U.S. passport

July 9 (Reuters) – Denise Rich, the wealthy socialite and
former wife of pardoned billionaire trader Marc Rich, has given
up her U.S. citizenship – and, with it, much of her U.S. tax
bill.

Rich, 68, a Grammy-nominated songwriter and glossy figure in
Democratic and European royalty circles, renounced her American
passport in November, according to her lawyer.

Jun 26, 2012

U.S. IRS offers reprieve to expat tax filers

By Lynnley Browning

(Reuters) – Many Americans living abroad will get a small reprieve from U.S. Internal Revenue Service rules on reporting foreign assets, the agency announced on Tuesday.

The IRS said it would allow some U.S. citizens, including dual citizens, who have not filed income tax returns or not disclosed their foreign bank accounts, to come forward without facing onerous penalties or the threat of prosecution.

Jun 20, 2012
via Tax Break

Officials outline IRS and Justice Department tax focus

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Notes from the Tax Underground: What do tax officials and tax lawyers worry about?

At New York University’s Tax Controversy Forum in New York last Friday, Michael Danilack, deputy commissioner (international) of the Internal Revenue Service, told hundreds of tax lawyers that being more strategic was essential to the agency.

Jun 17, 2012

Factbox: Major U.S. Tax Court transfer pricing cases

By Lynnley Browning

(Reuters) – The Internal Revenue Service lost two major cases in U.S. Tax Court in recent years dealing with transfer pricing, or how companies value asset transfers and related transactions between subsidiaries that cross international borders.

This field is one of the most contentious in the tax world, with the IRS often struggling to keep up with fast-moving corporations that legally manage transfer pricing to reduce their overall tax rates, but sometimes cross the line.

Jun 4, 2012
via Tax Break

U.S. tax prosecutor Downing resigns, joins Miller & Chevalier

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The logo of Swiss bank UBS at the company's Zurich office. Kevin Downing, the former U.S. Department of Justice Tax Division Attorney, had investigated UBS. REUTERS/Arnd Wiegmann

The U.S. prosecutor most responsible for piercing the veil of Swiss bank secrecy has joined the law firm of Miller & Chevalier, where he will focus on defending banks and other institutions involved in tax-related matters and controversies.

May 31, 2012

U.S. prosecutor in Swiss tax probe to exit

By Lynnley Browning

(Reuters) – The U.S. prosecutor most responsible for piercing the veil of Swiss bank secrecy has resigned, but tax experts said his exit was unlikely to slow Justice Department efforts to rein in American offshore tax evasion there.

Kevin Downing, 46, who for several years has led the department’s criminal probe of the Swiss banking industry, will leave effective June 4 to become a partner at a major law firm, a source familiar with the matter said on Thursday.

May 31, 2012

Prosecutor in Swiss bank cases resigns: source

By Lynnley Browning

(Reuters) – A top prosecutor responsible for a crackdown on Swiss banks and sellers of corporate tax shelters has resigned from the Justice Department, a source familiar with the matter said on Thursday.

Kevin Downing, 46, who has led agency criminal probes of the Swiss banking industry, and earlier of banks and accounting firms, is leaving to join a law firm, the source said.

May 31, 2012

U.S. prosecutor in Swiss bank cases resigns-source

May 31 (Reuters) – A top U.S. prosecutor responsible for a
crackdown on Swiss banks and sellers of corporate tax shelters
has resigned from the Justice Department, a source familiar with
the matter said on Thursday.

Kevin Downing, 46, who has led agency criminal probes of the
Swiss banking industry, and earlier of banks and accounting
firms, is leaving to join a law firm, the source said.