However we expect things to be much better on the offshore front this quarter as the firm has bagged new contracts in the region and firm oil prices have stimulated interest in offshore drilling.
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This rule can apply where there is a relatively greater amount of indebtedness in the U.S. than offshore, and net interest expense exceeds a specified percentage of adjusted taxable income.
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And if Russia plays ball it will strike a hard bargain - perhaps securing an interest in Cyprus's offshore gas industry, yet to be developed.
What the American people deserve is a complete and honest presentation by Romney of how his wealth was accumulated, where it is now invested, what purpose is served by all the various offshore vehicles in which he has an interest and what his financial relationship with Bain Capital has been since his retirement from the company.
The disastrous BP oil spill has raised awareness of the risk of offshore drilling, and is likely to create renewed interest in abundant and clean-burning natural gas as an alternative for many uses.
In the event, the only private operators who expressed interest in the more than 20 routes - the offshore company V Ships, and Dunoon's Western Ferries - pulled out.
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Practically none of the public or private sector professionals I have spoken to over the past decade with respect to this major, emerging national security challenge had any interest in unnecessarily disadvantaging U.S. firms and driving business offshore, often to foreign competitors.
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In return for escaping criminal charges, taxpayers accepted into the current version of the OVDP must file eight years of amended tax returns, pay all back taxes, interest and penalties due (including a 20% accuracy penalty on offshore-related underpayments) and pay an FBAR penalty equal, in most cases, to 27.5% of the maximum held in the undisclosed offshore accounts during the eight year period.
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Gilly should also be aware that if she leaves her money offshore French social taxes also apply at 11% on any investment income such as bank interest, as there is no 'nil' band for social taxes for French residents.
The offshore C-Corp may not shield this type of UBIT as it does for leverage and interest expense.
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