When Queen Victoria opened the Great Exhibition in 1851, Britain was the world’s leading industrial power, producing more than half its iron, coal and cotton cloth. Well, I don’t think Her Late Majesty would be very amused to hear from her great-great granddaughter how the country she bequeathed to her descendants in perpetuity is currently faring…
GILTI pleasures
Just when you thought it was safe to put the Ibuprofen back in the medicine cabinet, the IRS has issued proposed GILTI (Global Intangible Low-Taxed Income) regulations in addition to the long anticipated final ones. (For an explanation of what was supposed to be going on, see Tax Break February 10, 2019). Back in my…
Ain’t no Bonanza
Jay Leno once went walkabout in New York asking innocent passers-by if they could name a country beginning with the letter 'U'. Apart from the usual camera induced deer-in-the-headlights non-responses, a few bright sparks came up with Uganda and Uruguay. At the close of the piece, as the camera faded out, Leno was heard asking:…
GILTI until proven simple
Appearing on Johnny Carson's Tonight show in 1975, the ex-governor of California quipped: 'We live in the only country in the world where it takes more brains to figure out your income tax than it does to earn the income.' A little over a decade later, the same gentleman put his pen where his mouth…
Another bite of Apple?
In October 1962, at the height of the Cuban Missile Crisis, John F Kennedy quietly signed into law the most extra-territorial tax system in the history of the human race. As the world faced MAD (Mutually Assured Destruction), it perhaps wasn't the most important thing on the minds of American CEOs that week. Buried in…
Who wants to live forever?
There was a time, not long ago, when the ideal higher education of a tax specialist was a combination of law and accounting. With the gradual death by asphyxiation of income tax planning, the ambitious young prospective practitioner might add a third arrow to his bow - doctor of medicine. Many would argue that, despite frustrating…
The Unsatanic Taxes
Nobody who has read Salman Rushdie’s classic ‘Midnight’s Children’ can be indifferent to the juxtaposition of India and Midnight in a phrase or sentence. So, the recent announcement that India’s new GST law (VAT by any other name would smell as sweet) would come into effect, amidst much fanfare, at midnight on July 1 was…
Going it alone?
Ever since Marilyn Monroe’s less famous namesake, James, came up with his Doctrine almost two centuries ago, America has toyed with isolationism. They tried it in the First World War, and it didn’t work. They tried it in the Second World War, and it didn’t work. And Barack Obama has spent his presidency unsuccessfully trying…
Putting a Price on Morality
'If you prick us, do we not bleed?' Well, not if we are a company. This was the point on which I was reduced to a state of heckling at the Lisbon conference described in my previous post. A Breakout 'Conversation' - Breakout 'Sessions' are SO last decade - on 'Tax and Morality' was irresistible. (Look,…
The spotlight beside the golden door
Fifty years ago today, the New York Times announced that Elizabeth Taylor had failed in her attempt to renounce US citizenship. Required to disavow 'all allegiance and fidelity' to the United States, she found herself unable to do so. Now, allegiance and fidelity are terms Ms Taylor had a lot of experience disavowing - eight lots…
Tax Break 