Financier Worldwide Magazine | July.01.2012
This article, about companies keeping up with more aggressive enforcement of taxation rules and regulations, quotes New York tax partner Peter Connors.
"Legislators and others will continue to make accusations regarding the use of offshore tax jurisdictions. However, many of the structures are legitimate and merely have been developed in the context of the country’s tax system. The tax systems, regulations and often treaties need to be changed," Connors stated.
In regards to dealing with regulators, Connors commented, "Companies should assume that every transaction of significance will be challenged. They should ask themselves ‘What information would I like to have if the transaction were challenged?’ If challenged, they should ask ‘How will I document the legitimacy of the strategy?’ Some redundancy should be built into quality control."
Connors continued, "There will be more and more cooperation among the international tax authorities, which will result in more and more information exchange. There will be more joint audits and obstacles to cooperation will drop. Taxpayers will continue to obtain advance pricing agreements to resolve controversy."