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"Fifty-seven other scheme users cannot meet the tax demand, even if they were to sell all of their assets including their family home, " Mr Huitson's barrister claimed, drawing on a small survey of the scheme's users.
BBC: Offshore tax avoiders face ?100m tax bill
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For one: Make all personal tax information available online for users.
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"It is, in essence, a hidden tax on all non-residential users, " Bilas said.
CNN: graphic
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Ronnie Ludwig, of accountants Saffery Champness, said the High Court ruling meant that users of other "off the shelf" tax avoidance schemes could no longer sleep easily.
BBC: Offshore tax avoiders face ?100m tax bill
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In February the Clinton Administration proposed 16 tax law changes, including stiffer penalties for shelter-users and excise taxes on promoters' fees.
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The second part is the incidence upon the users of the financial markets: a fairly obvious result of a transactions tax.
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The users of fossil fuels pay nothing towards that cost, but a carbon tax would build some of those costs into the price of oil, gas, and coal.
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Yet tax laws ignore the very fact that each time data is involved, users become part of the operations.
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Granted, we weren't able to seriously tax it due to having no internet connection and no pre-loaded HD multimedia, but casual users probably won't notice a significant boost in screen transitions.
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The amount of profits that should be declared to the local tax authority would diminish profits transferred to pay for intangible assets located abroad, depending on the number of users and the intensity of data collection.
FORBES: Corporate Tax 2.0: Why France and the World Need a New Tax System for the Digital Age