Attracted by the Netherlands’ policies and extensive network of tax treaties, IBM joins companies such as Yahoo! Inc., Google Inc. and Cisco Systems Inc. that have used Dutch subsidiaries to cut taxes.
Failure by an FFI to disclose information on their US clients, including account ownership, balances and amounts moving in and out of the accounts, will result in a requirement to withhold 30 percent tax on payments of US-sourced income.
Trusts are often used as a vehicle to reduce or eliminate gift and estate tax while bequeathing wealth to children or other beneficiaries, but are subject to taxes on their own earnings, from investments, interest and other forms of income.
When Actavis Inc. changed its incorporation to Ireland in October, the New Jersey-based drugmaker helped CEO Paul Bisaro avoid the law’s bite by handing him more than $40 million of stock as much as three years ahead of its schedule, then promising
The reporting requirement previously existed for accounts held by nonresident aliens residing in Canada, but now extended to all other countries with which the United States had an income tax treaty or information exchange agreement.