Tax Risk Management requires seven steps to ensure complete compliance by taxpayers, in an international environment where tax authorities are becoming better equipped and organized in closing tax gaps. Part of the process of tax authorities is the formation of Large Tax Units that expect to...

This paper summarizes the key features of tax risk management and sets out the typical steps that should be followed. It follows a typical Six Sigma process in going about tax risk management. This paper discusses tax risk management, in particular, in the context of Section 404 of the U.S....

This paper provides a practical overview and normative analysis of international tax planning ideas for entities who are establishing or restructuring their business affairs. In particular, in an international financial hub, such as Hong Kong, taxation advisors and lawyers need to be...

I've been asked for my perspective on the progress we have made since starting the journey over two years ago which raised with CEOs, company directors and Boards the consideration of tax risks as part of good corporate governance.Anecdotal evidence suggests that companies have made good...

In this paper I derive a straightforward condition, which I call the Arm's Length Dual Condition (ALD), for a controlled price to be, or not to be, arm's length. A proof of the validity of this condition is carried out with respect to the Resale Price, the Cost Plus and the Transactional Net...

This Article analyzes the incorporation decisions of relatively new, U.S.-based private business enterprises with global ambitions. Such startup firms generally organize as U.S. corporations. This Article theorizes this dominant structure and its exceptions, drawing from prior literature and...

While the world taxpayers focus on aggressive tax planning, the world jurisdictions try to deal with that especially under the leadership OECD. Until now, it is hard to say that jurisdictions are successful to solve this problem. And some other countries have started to take unilateral measures...

The trust is the most useful device that New Zealand offers to non-residents in the field of international tax planning. So long as settlors, beneficiaries, and income are all foreign the trust is unlikely to attract New Zealand tax. The residence of the trustee has no effect on the tax benefits...