2014

Bloomberg and Tax Analysts Quote Caplin & Drysdale Member Elan Keller About Implications of Tax Information Exchange Standard

NEW YORK, Nov. 25, 2013 /PRNewswire/ -- Caplin & Drysdale's Elan P. Keller recently spoke with Bloomberg and Tax Analysts concerning the implementation of an automatic tax information exchange standard and its immediate consequences for taxpayers and practitioners.  Multinational taxpayers must begin taking a holistic approach to their tax planning, focusing on the global environment instead of merely U.S. consequences.  "Now the multinational will need to focus, almost equally, on how the other jurisdictions are going to look at this and whether they are going to get access to information [from revenue authorities].  They will in particular need to be able to demonstrate a business purpose for a transaction, in each jurisdiction," said Mr. Keller.  

"Sophisticated multinational corporations are already adapting to the shift toward automatic exchange of information, but other taxpayers should be taking a harder look at their tax risk management structures and creating processes to avoid transactions that lack an economic substance or a business purpose.  Providing evidence of business purpose and economic substance is the best way to combat an attack from any revenue authority.  The trend is that jurisdictions want to work closely with each other and find it in their best interests to be transparent, and that's something that taxpayers should be paying attention to."

About Elan P. Keller
Elan P. Keller is a partner in Caplin & Drysdale's Corporate, Business & Transactional Tax, International Tax, Tax Controversies practice groups in the firm's New York office.  Clients seek his advice on matters involving tax due diligence and structuring cross-border and domestic M&A transactions; the U.S. aspects of inbound and outbound operations; transfer pricing; corporate restructurings, reorganizations and distributions; capital markets and structured finance transactions; infrastructure and leasing transactions; and oil, gas, energy, and natural resource transactions.  Mr. Keller can be reached at 212.379.6030 or ekeller@capdale.com.

About Caplin & Drysdale
Since 1964, Caplin & Drysdale has been a leading provider of tax, tax controversy, and related legal services to corporations throughout the United States and around the world. With offices in New York and Washington, DC, the firm also provides counseling on matters relating to bankruptcy, creditors' rights, political activity, exempt organizations, complex litigation, employee benefits, private client services, corporate law, and white collar defense.  For more information, please visit us at www.caplindrysdale.com.

Disclaimer
This communication does not provide legal advice, nor does it create an attorney-client relationship with you or any other reader. If you require legal guidance in any specific situation, you should engage a qualified lawyer for that purpose. Prior results do not guarantee a similar outcome.

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SOURCE Caplin & Drysdale



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