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How the US Deals with Tax Avoidance

David Blumenthal Tax Partner Dewey Ballantine compares the US and UK approaches to tax avoidance
In the last issue Anne Fairpo discussed the Circular 230 Regulations and commented on how HMRC is increasingly looking to the US for inspiration in its efforts to counter tax avoidance.
It does indeed seem reasonable to suppose that when the UK Revenue decided to introduce rules last year requiring the disclosure of tax avoidance schemes by their promoters it was influenced at least in part by the adoption of similar rules in the US just four years earlier. Similarly there is a US precedent for the 'arbitrage' rules in this year's Finance Act preventing the use of hybrid entities to claim tax deductions in two jurisdictions or not pay tax...

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