I was catching up on my reading and stumbled upon something: Last week, the US and Barbados agreed to fix the treaty-shopping article of their income tax treaty. This treaty was the heart of a structure used by some of those great American corporations that reincorporated in Bermuda to avoid US tax. If I understand the significance of the amendment correctly — these deals are real complicated — the Bermuda/Barbados structure will trigger a lot more tax as soon as the amendment is ratified by the Senate. Also, new expatriations will be discouraged as planners see new taxes on the horizon. May talk about this more next week.
PS PART III of US Taxation of Multinationals will be delayed a day.
