Experts expect corporate tax inversions to survive new rules

Originally published April 6, 2016 at 1:39 pm | Updated April 6, 2016 at 5:11 pm FILE – In this Nov. 23, 2015, file photo, the Allergan logo appears above a trading post on the floor of the New York Stock Exchange. (AP Photo/Richard Drew, File) FILE – In this Nov. 23, 2015, file photo, the Allergan logo appears above a trading post on the floor of the New York Stock Exchange. Allergan and Pfizer called off Wednesday, April 6, 2016, a record $160 billion merger after the... (AP Photo/Richard Drew, File) TOM MURPHY The Associated Press President Barack Obama scored a victory this week when Pfizer scrapped a $160 billion overseas deal that would have kept a chunk of the drugmaker’s profits beyond the U.S. tax man’s reach. But recent, aggressive federal actions that discouraged Pfizer Inc.’s combination with another drugmaker, Allergan PLC, won’t stop all so-called inversions, or deals that end with a company relocating to another country — at least on paper — and trimming its U.S. tax bill in the process. Tax and legal experts say these deals, which have come under growing criticism from politicians, will remain attractive to some companies until the U.S. pursues a massive tax law overhaul. “There may be a temporary respite from inversions, but the large financial benefits … are still there,” said Bret Wells, a tax lawyer and law professor at the University of Houston. Most Read Stories 0 null Americans, including a Bellevue man, show up in Panama Papers 0 null Costco gets creative to meet shoppers’ huge appetite for organics 0 null Tech firms in pricey San Francisco see exodus to Seattle 0 Russell Wilson talks to the media in the Seattle Seahawks locker room at Virginia Mason Athletic Center as the team cleans out their lockers Monday, Jan. Seahawks' Russell Wilson finds out he's descended from royalty 0 null Garfield teacher fired over field-trip allegations fights for her job Unlimited Digital Access. $1 for 4 weeks. Even the Obama administration, which has taken several steps to discourage inversions in recent years, says Congress ultimately must step into this fight. In an inversion, a U.S. corporation and a foreign company combine into a parent company based in the foreign country. For tax purposes, the U.S. company becomes foreign-owned, even if all the executives and operations stay in the U.S. Inversions have become particularly popular in health care. They allow companies to avoid paying additional taxes that the U.S. government would impose on money earned overseas and then transferred back to the parent. They can reduce corporate tax liability in other ways, and they provide some relief from the U.S. corporate tax rate of 35 percent, which is the highest in the industrialized world. But Obama and others have said these deals shortchange the country because corporations fail to pay their fair share of taxes. Earlier this week, the Treasury Department announced a third round of regulations designed to limit the practice and make it less lucrative for companies. The new regulations seek, among other things, to limit inversion benefits like tax deductions that can stem from internal corporate borrowings. Pfizer cited the new regulations in scuttling its deal. These rules will make it harder for U.S. companies to find a foreign deal partner, said Donald Goldman, a professor at Arizona State University’s W.P. Carey School of Business. He added that the regulations “will definitely have a chilling effect on inversions.” They actually will come close to killing the practice, according to Robert Willens, president of a New York-based tax and accounting service and a former Lehman Brothers managing director. But he said some narrowly tailored deals that have the right balance of U.S. and foreign ownership should survive. He cited as an example the pending $14.6 billion combination of Milwaukee-based Johnson Controls Inc. and Ireland’s Tyco International, companies that make security and other building control systems. Johnson Controls spokesman Fraser Engerman said the company was reviewing the new Treasury regulations and wouldn’t speculate on what impact they might have on the Tyco deal. At least one company that has already completed an inversion isn’t having second thoughts. Medical device maker Medtronic PLC, which completed a nearly $43 billion combination with Ireland’s Covidien last year, said Wednesday that it has done a preliminary review of the Treasury rules and concluded that they do not have a material financial impact on the company. Treasury Secretary Jacob Lew has said the new rules are designed to make inversions less economically beneficial for companies, but only anti-inversion legislation from Congress can stop the transactions. Leaders in the Republican-controlled Congress say the issue underscores the need for comprehensive tax reform, but such a massive undertaking is unlikely in an election year that also is the last year of Obama’s presidency. “We really need to scrub the whole code,” Senate Majority Leader Mitch McConnell, R-Ky., told reporters on Tuesday. “The chances of doing a tax reform this year are pretty slim.” ___ AP writer Andrew Taylor contributed to this report from Washington, D.C. Murphy reported from Indianapolis. ___ Corrects spelling of lawyer in fourth paragraph

Lehman creditors' recovery may soon reach $7.8 billion

Mon, Jul 13 13:10 PM EDT NEW YORK (Reuters) - The trustee liquidating Lehman Brothers Holdings Inc's brokerage unit on Monday asked a federal bankruptcy judge for permission to distribute another $1.89 billion to unsecured creditors, boosting their total recovery to $7.78 billion. James Giddens, the trustee, said the creditors will have recouped 35 cents on the dollar, up from 27 cents so far, if the proposed third payout wins approval from U.S. Bankruptcy Judge Shelley Chapman at an August 4 hearing in Manhattan. "This result, in the largest broker-dealer insolvency in history, could not have been anticipated in the dark days of the financial crisis when this liquidation began," Giddens said in a court filing. Lehman had been Wall Street's fourth-largest investment bank before seeking Chapter 11 protection on Sept. 15, 2008. Roughly 111,000 former customers of the brokerage have already been paid more than $106 billion, and senior creditors have also been paid in full. Giddens said the latest payout includes $1.18 billion that he had held in reserve. He said this included $583 million for disputes over Barclays Plc's (BARC.L) hurried purchase of much of the brokerage unit a few days after the bankruptcy filing. Those disputes were settled on June 5. The case is In re: Lehman Brothers Inc, U.S. Bankruptcy Court, Southern District of New York, No. 08-01420. (Reporting by Jonathan Stempel in New York; Editing by Christian Plumb)

Sekisui House agrees to buy Tokyo property for $720 million: sources

In March Sekisui House Ltd, a Japanese home builder, agreed to buy an office building in Tokyo, which was also owned by daVinci, for 74 billion yen. Fri, Mar 28 00:04 AM EDT By Junko Fujita TOKYO (Reuters) - Japan's Sekisui House Ltd (1928.T) is buying an office tower in central Tokyo for 74 billion yen ($720 million), as property prices rise to levels that allow lenders to recoup losses from a bust that followed the global financial crisis. The Osaka-based home builder has agreed to buy the 20-storey, 41-year-old Kokusai Akasaka Building in an upscale commercial and business district, according to four people briefed on the deal. The tower is largely occupied by affiliates of NTT DoCoMo Inc (9437.T), Japan's largest mobile phone operator. The deal, expected to close by Monday, confirms the ongoing revival in Tokyo's prime commercial property market after an ill-fated series of highly leveraged investments that failed spectacularly after a 2006-2007 real estate boom collapsed. The value of the Kokusai Akasaka property had cratered after it was bought in 2006 by then-aggressive property investor K.K. daVinci Holdings for about 100 billion yen, almost entirely financed by debt. Another daVinci property, an iconic office tower in south-central Tokyo's Shiba district, was bought last year by a group including United States insurance magnate Maurice "Hank" Greenberg's C.V. Starr & Co and Asia Pacific Land. Investors are returning to the property market in Japan, where Prime Minister Shinzo Abe's aggressive government spending and loose-money policies have started to pull the economy out of 15 years of deflation. Land prices in Japan's three largest cities - Tokyo, Osaka and Nagoya - rose for the first time in six years last year and declines slowed elsewhere, a government survey showed this month. The debt behind the 2006 Kokusai Akasaka deal was packaged into 97.5 billion yen of commercial mortgage-backed securities arranged by Lehman Brothers, the investment bank whose failure triggered the global crisis. When the market collapsed in 2008, investors could not make payments on the loans and the building's ownership shifted to a group of lenders. A Sekisui House spokesman declined to comment. The company largely relies on housing property for its revenue, earning just 2.4 percent of its 1.8 trillion yen in sales from office properties last year. It owns the Osaka landmark Hommachi Garden City, Tokyo's Garden City Shinagawa Gotenyama and the Ritz-Carton, Kyoto building in Japan's ancient capital of Kyoto. ($1 = 102.1350 Japanese Yen) (Reporting by Junko Fujita; Editing by William Mallard, Edmund Klamann and Kenneth Maxwell)

Lone Star buys former Lehman "Excalibur" assets

Fri, Apr 13 12:24 PM EDT

FRANKFURT, April 13 (Reuters) - Private equity company Lone Star agreed to buy the former Lehman Brothers "Excalibur" portfolio from Germany's Bundesbank, which is managing the sale of securities that the defaulted U.S. investment bank had posted as collateral for funding in 2008.

The Bundesbank said on Friday it had sold Excalibur to Lone Star for an undisclosed sum. The vehicle has a nominal value of 1.4 billion euros ($1.8 billion), compared with 2.16 billion originally. The deal is due to close at the end of the month.

Excalibur is the largest position in a portfolio of assets which Lehman had posted as collateral at the Bundesbank for taking 8.5 billion euros from the European Central Bank in 2008. Lehman defaulted in September 2008.

Mussolini congratulates Hitler!

Excerpts from Iraq Occupation Times:
Congratulating Nazi Israel by the American cowboys is like fascist Italy congratulates Nazi Germany for its accomplishments.

Israel is in real danger of being seriously crippled. Like Israel, Nazi Germany had the most sophisticated weapons but ended up in ruins. Jews blinded with arrogance. The days of blitz kriegs have long since gone.

According to Jewish calendar, Israel was established some 62 years ago. But despite its huge military arsenal and massive American financial, military and high-tech aids and investment, Israel is still threatened with extinction. One of the reasons for this is the fact that Israeli practices are comparable to those of Nazi Germany.

Since the world had justified the destruction of Berlin and Dresden in order to end Nazi atrocities; the destruction of Tel Aviv and the surrounding areas (Dan Gosh, Herzilia, Lod,Yahuda) will put an end to Israeli Nazi-style crimes. Almost 3.5 million Israelis and most of the 350 high-tech industries are situated in these areas. Albeit denied by Yehud Barak, Israel is preparing for a war on Syria, Hamas, Hezbullah and Iran; most probably by this summer. As there are open threats from Lieberman-Netanyahu alliance to Syria and Egypt, equally, Ahmedinejad and Hassan Nassarallah have been sending their own predictions about the imminent demise of Israel. Whether the war will take place or not, the Israelis will continue to live without peace as long as their country remains in breach of 39 UN Security Council Resolutions, practices Nazi-style atrocities against Palestinians in the occupied territories and desecrate Islam holy places. The Americans have been a party to sixty two years of Israeli bloodshed and miseries.Today there is Ahmedinejad, tomorrow there will be another Arab or Muslim with much bigger bombs and missiles that may pulverise Israel on a biblical scale.

Naturally the US wants Arabs to acquire as much US-made weapons as they can afford as long as they don't use them against Israel. On the otherhand, the US supplies as much weapons as Israel wants as long as they use them to commit atrocities against Arabs and Muslims.
The Americans are extremely stupid for thinking that the Arab people will buy this doctrine.

Arabs and Muslims must hit first if they ever want to win against Israel. They did attack Israel on Octocer 1973 and sent the Israelis gasping for US help. There is no need to talk, action is needed.Israel is ripe for picking.

Who said that only Israel can have all types of weapons of mass destruction including Nukes and the relevant delivery systems while Arabs can't have anything to defend themselves or to deter further Israeli atrocities? Times has changed for everyone in the M.E. The Israelis are living in the past and are looking for an excuse to start a war. But the the outcome will be different and may be disastrous for the Jewish state on its 62nd anniversary.


Goldman: Fleece Christians and fatten Jews!
Everytime someone investigates Jewish fraudsters AIPAC raise the flag of anti-Semitism-. No Matter how one looks at it, Jews have raped America and fleeced Americans.

It is not a secret that the Jewish financial mafia(s) of America has been fleecing Americans for decades, bribing US legislators and diverting part of the proceeds to Israel. Everything was going well until the sub-prime disaster that brought the US economy on the verge of collapse. This colossal fraud has opened the American eyes to Jewish fraudsters like Lehman Brothers, Bernie Madoff, Rotstein, Bear Stern and lately Goldman Sachs (GS). Preparing the ground for the current SEC investigation, Blankfein, CEO of GS has spent $300000 on a number of influential legislators during March 2010 alone.

What Blankfein has to explain is why GS made parcels of real estate loans, gave them high credit ranks and sold them mostly to Christian and Muslim investment funds; while at the same time asked Jewish funds e.g. Paulson and Co. to short sell them. It is clear that GS knew ahead of time that the contents of the real estate parcels were rotten. While GS made a relatively small loss on selling the parcels, it made $billions short selling them either through their own daughter company (s) or through Paulson and co. Despite the apparent anger of some legislators, in reality nothing will happen to either Goldman Sachs or to its CEO. It is in the interest of US politicians to have high-contributing Jews in control of the financial institutions and the media. It is too early for the American Zombies to wake up and send to the White House a cowboy carrying a Swastika.

The world is justified in being outraged enraged by Jewish fraudsters!
At the beginning it was the Jewish-managed sub prime real estate crisis that almost caused an economic meltdown of America and the world. It was natural for the US legislator to investigate the biggest Jewish fraudster of all time, Goldman Sachs (GS). Few days ago, Standard and Poor downgraded Greece bonds to Junk. One mustn’t forget the role of Goldman Sachs who helped the Greek government to mask the true extent of its deficit through a derivatives deal that legally circumvented the EU Maastricht deficit rules. At some point, GS knew that the so-called cross currency swaps will mature, and swell the country's already bloated deficit. The American Labour Unions plan to march on Wall Street to denounce the Jewish practices of profiting while causing massive unemployment and speculating while millions of Americans lost their homes and savings.

The greedy Wall Street Shylocks must be made to pay for all the miseries they caused to people in America and in other parts of the world. The projected Obama financial regulations don’t go far enough as they will leave the Jewish financial mafias in control of Wall Street. It is more important for the American laws to treat the Jewish organised financial crimes and racketeering the way Italian mafia crimes are treated. The crimes of the Italian mafias affect people lives on a limited scope while the Jewish financial crimes cause miseries to people throughout the world.


Solving US problems by cloning a Hitler!!!


Yesterday 20.05.10, the US senate passed Obama bank regulations bill to the anger of Jewish-controlled Wall Street. The bill aimed to clipping the fangs of the Jewish financial Dracula (s) who have been robbing Americans out of their wealth and bankrupting the country. Using scores of financial instruments e.g. hedge funds, derivatives or asset stripping, put America on its knees. Most of the financial regulators were Jews and acted colsely with the Jewish mafia controlling Wall Street. It is another way for Obama to blame the Jews for what has happened to America and similar to Hitler realisation that the Jews were causing German economic miseries.
At the same time, American scientists announced the successful production of a bacterium whose genome was produced by a computer. One doesn’t need much intelligence to connect the dots and expect the production of an American Hitler with a true final solution to US and world financial problems.

The fact that the Jews made an industry out of the holocaust bothers many. Furthermore, the Jews have exaggerated their losses considering all those who died in Hitler's concentration camps as Jewish. Millions of communists, misfits, democrats and homosexuals were sent to their death. Only the Jews got compensated and not the others. Germany was forced on paying $$$$ to Israel although no Israeli was killed by Hitler since Israel was established some three years following the collapse of Nazi Germany.

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Netanyahu is definitely stronger than Obama!
Following Obama’s and his administration dealings with Brooklyn-born ,street-wise, corrupt and terrorist Benjamin Netanyahu; one can’t help but conclude that the leader of the tiny state of Israel is much stronger than Obama, the leader of the only remaining super power. Despite repeated invitations to the Whitehouse, and frequent visits of Clinton, Mitchell and Joe Biden to Israel coupled with generous military package promised to Israel defence minister, assassin Yehud Barak, Netanyahu remains defiant about the building of illegal settlements in Palestinian occupied territories. Netanyahu wanted to extort as much concession from Obama as he possibly could knowing the extent of the Jewish control of Washington D.C. and the Jewish role during the mid-term election in November 2010. It is said that Obama has put a condition that he will authorise military attacks on Iran only if the negotiations with Mahmoud Abbas were on-going. Hapless Obama, like many US Presidents before him, were led from the nose by the Jews while choking on their own promises..

Afghanistan and Iraq had nothing to do with 9/11
It is not only Ahmedinejad and Robert Fisk of the Independent.co.uk who are skeptical about who was/were behing the 9/11 attacks. Why Americans refuse to make us see the trials of those accused on TV? Why keep so many evidence in secret filres? You must have heard that the Pentagon has bought and destroyed 10000 copies of Black Heart because the author wrote that Mohammed Atta, the Egyptian in charge of the group that flew passenger planes into the WTC on 9/11was known to the CIA and FBI as a member of Al-Qaeda. So why did they allow him to train in America on flying planes? In the UK, documents related to the death/suicide of Dr Kelly, Iraq Weapon Inspector, was kept in closed files for 75 years? Furthermore, documents related to the killing of John F.Kennedy in 1963 was also kept locked for 75 years.
People are naive to believe the official version of events. Intelligence services serve the interests of some dark forces not known to the public.

Whether its ISI or Taliban, the convoy of 30-trucks carrying fuel to NATO forces were set on fire by rocket-propelled grenades today 01.10.10. But the Pakistani army generals and the intelligence services will soon protect the road against some generous payments (bribes). One doesn't expect much from a government led by a crook like Zardary. It was his late wife, Benazir Bhutto, who made the deals with the Americans in support of their campaign in Afghanistan.


Adnan Darwash, Iraq Occupation Times

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Symbiosis between money and politics undermines democracy

Someone has once stated “It is easier for a man to pass through the eye of a needle than a rich man to enter the kingdom of heaven”. But what if the Rich man controls the banks, the media the legislators, the judiciary and centres of decision making? The worst case scanario is manifested by Italian Prime Minister (PM) Silvio Berlusconi. He bribed late PM Benito Craxi, to gain control of state owned monopolies including four TV channels. After becoming Italian PM for the second time, Berlusconi succeeded in passing laws delaying any investigation accusing him of illegal activities while he remains occupying the post of PM.

In America, it is a must for big corporations and financial institutions, including crooks like Bernie Madoff and Rotstein, to contribute to the election funds of US politicians and legislators. During the thirties, the Italian Mafias did put law enforcement officers and Judges on their payroll. At one time, thirty US senators owed their seats to the mafia. But when too many complaints filed against certain illegal practices by names likes Al-Capone, Colombo, Luciano and Genovese the Americans started to cry wolf until the mafia activities became ‘legal’.

In the US today, a new group of untouchables with names like Goldberg, Goldstein, Goldsmith, Silverstein, Spielberg, Bloomberg and Greenberg…etc are in control of the financial institutions, the media and Washington D.C Politics. A good example is Mike Bloomberg. He made $9billion working for Goldman Sachs, established his own media corporation and went to become the mayor of New York in the hope of becoming the next US President. Because of the heavy influence of the Jewish money in US politics, no-one in his right mind can criticise Israel or have an honest and open dialogue about the pro-Israeli US foreign policy.

The same American Rich men have started to invest heavily on politics in West and East Europe. In recognition for the Jewish contribution, British PM Margaret Thatcher appointed five Jewish Cabinet Ministers in her first cabinet: Nigel Lawson, Keith Joseph, Leon Brittan, Lord Young, and George Younger. All have worked to rip off the United Kingdom by privatising the state monopolies to the benefit of their friend and allies. As an example, Lord Young privatised the communication firms, left the government and got himself a $5 million job with Cable and wireless.

The same US Rich men worked to rip off the Russian state monopolies that ended up in the hands of mostly Jewish Oligarchs.(A member of a small governing faction.
)

In trying to clarify the role of US money in British politics, Tony Blair promised during the election campaign to open up the books. But later on, he changed his mind after becoming the PM and after his party treasurer, Jewish Lord Levi, showed him the extent of US money involvement in his party donations. It was not a mere coincidence that Tony Blair has joined G.W. Bush in marching on Baghdad to Israeli drums.
The bad Rich men are ruining the world by launching wars, supporting autocrats, promoting corruption, carrying out dirty works and conspiring to silence or to assassinate their foes; through their control of the mighty United States of America.Adnan Darwash, Iraq Occupation Times

Symbiosis:(A relationship of mutual benefit or dependence.
) Politicians need Bankers to win seats. Similarly, Bankers need politicians in order to use Tax payer money to pay for their losses.

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So as long as "greed comes in all races and colors" we should let certain untouchables to continue bribing politicians, misusing taxpayer money and waging wars. It is undemocratic to let a small group of blood suckers to lead Americans or any other people from the nose. The preacher president Obama is playing the game by the rules of Washington snakes.
Iraq is full of snakes and terrorists who had entered Baghdad behind US tanks.