Tonight at 7 pm EST on CNN's Erin Burnett Outfront, there will be a feature on Romney's offshore accounts, including the tax planning motivations that one suspects may underlie them. I gather that Erin will name me as a source (via e-mail correspondence) for the basic tax analysis.
Nothing surprising or novel, at least so far as my contribution is concerned. Apart from the secrecy angle, which I assume isn't tax-related (as it's hard to believe Romney would commit outright fraud), I emphasized the tax planning objectives of avoiding (1) certain deduction limitations and (2) the debt-financed UBIT rules. David Miller discusses these issues, and others associated with using offshore entities, in much greater detail (though without specific reference to Romney) here.
Has anyone asked if tort liabiility is impacted by having accounts offshore? Might this be a reason? I am rather stunned that with all the experts this has not been mentioned.
ReplyDeleteIt was my understanding that there is an impact. Suing people in these other jurisdictions is not the gimme that it has become in the US.
Spreading risk probably more of an issue for people with a lot of wealth as well, and my guess is they are EVEN more likely to be sued than the rest of us.
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