its not like it was years ago when CitiCorp set up theri stock trading units in the Islands for a similar purpose..
Citi went farther. They did things like declare a particular desk in a skyscraper in NY to be legally in the Cayman Islands.
The IRS was not amused.
Do you have a source on this? I'd love to read more about this.
I wish I did. I heard about it because I used to work with someone who had worked there some years previous.
I'm vaguely aware of Citi's tax plan, but I'd have to look into it. If I can learn the details, I'll start a series of case studies that break down the tax strategies of different fortune 500 companies.
The problem with googling this is that it only tells you the basic premise and fails to tell you the problems and the reality of actually applying these tax models.
As someone who's worked on these tax models in the past, I can tell you that its never as picture perfect as they make it sound. These companies are always getting audited even though these plans were drafted, approved and done by the "big 4 accounting firms."
It was a running joke that the big 4 plans it and the law firms would defend it. It was like we were self-generating projects for us to work on by creating a new "plan" every other year. The IRS always comes back and audits these clients.