After spending the late 1950’s struggling to make ends meet in Hamburg, the Beatles engaged Brian Epstein in early 1962 to help realize their commercial potential, and within a few years they were earning rock star riches. So imagine George Harrison’s horror at finding out that Harold Wilson’s Labour government had passed a 95% supertax levied on the band’s earnings. No surprise, then, that the first song on the Beatles’ 1966 release Revolver had George choking out lyrics like: “Should five percent appear too small, be thankful I don’t take it all, ‘cos I’m the Taxman.” The Beatles broke up a few years later, but perhaps they ushered in a revolution of the taxation variety, for bands from the British Isles (U2 and the Rolling Stones, inter alia) have been setting up Irish corporate structures and Dutch pass-throughs to minimize…

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Is the IRS out to get you? Are there unresolved questions about your eligibility or status that are preventing you from moving forward? Have you been contacted recently, only to be asked for more documentation or information? Have you had to retain legal counsel to sort through all the new requirements? If you have experienced similar problems, you are not alone. Millions of Americans are coming to terms with their own frustrating IRS experiences. Some law makers even want to advance a new IRS tax, to help pay for regulating the IRS! But let’s not get ahead of ourselves. There’s already enough going on with Interest Rate Swaps. Interest Rate Swaps have never been so simple and yet so fraught with questions and compliance issues. Many market participants are experiencing this right now as they go back into the market…

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The Foreign Account Tax Compliance Act (FATCA) The Foreign Account Tax Compliance Act (FATCA) goes into effect January 1, 2013, and may have an adverse tax impact on certain payments made in derivative transactions.

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