peony

Documents: Country Reports

This section collects various documents that have been produced by a country of interest to the international tax community. Some are country tax reform reports, and others are simply documents of current or historical interest.

Australia

Report of the Commonwealth Taxation Review Committee.
(January 31, 1975) (Link to University of Syndey, Classic Texts in Australian and International Taxation Law).

European Community

Commission of the European Communities, Company Taxation in the Internal Market, Brussels, 23.10.2001, Staff Working Paper (2001).

India

Kannan Srinivasan, Money laundering & Capital Flight (2004)

Italy

Philip Morris Case (2002) (subsidiary treated as PE of members of unitary group).

Japan

National Tax Agency, APA Program Report (2003).

Mexico

Letter dated 9 February 2009 from Mexican Finance Secretary Agustin Carstens to U.S. Treasury Secretary Timothy Geithner. The letter asks the Treasury to consider a proposal for the automatic sharing of information regarding interest paid by banks of one country to residents of the other to help detect and prevent tax evasion, money laundering, terrorist financing, drug trafficking, and organized crime.

United States

US Senate Permanent Subcommittee on Investigations, Tax Haven Abuses: the Enablers, the Tools and Secrecy (2006).
US Treasury, Guidance on Repatriation of Foreign Earnings Under the American Jobs Creation Act (2005).
US Treasury, Corporate Inversion Transactions: Policy Implications (2002).
US Treasury, The Deferral of Income Earned Through U.S. Controlled Foreign Corporations (2000).
Survery of Current Business, U.S. Resource Flows to Developing Countries and Multilateral Organizations, 1993–97 (1999).
David Evans, The $150 Billion Shell Game (2004).
GAO, International Taxation: Information on Federal Contractors With Offshore Subsidiaries (2004).
Statement of U.S. Treasury Secretary Paul O'Neill, May 10, 2001,criticizing the OECD for going too far in its attempts to curtail international tax evasion through effective exchange of information.

OECD and Former U.S. Treasury Secretary Paul O'Neill

According to the New York Times, U.S. Treasury Secretary Paull O'Neil pulled the rug out from under a promsing initiative begun by the OECD during the Clinton administration. That initiative would have required offshore financial centers that were facilitating tax evasion to provide detailed information to requesting states on a routine basis.

O'Neill, under pressure from U.S. banking interests and anti-tax zealots, issued a statement in May of 2001 claiming that the OECD had gone too far in combating tax evasion. He stated that he was only willing to support the OECD initiative if it was limited to "exchanging specific and limited information necessary for the prosecution of illegal activity."

Having lost the support of its most powerful member, the OECD pulled back, resulting in the ineffective OECD TIEA issued in 2002.