As the FT notes this morning:
A simple rule meant to cut paperwork for US companies has grown into one of the biggest multinational tax breaks around, an FT/ProPublica report says. The rule is known as “check-the-box.” It allows US companies to shift profits from operations in high-tax countries simply by marking an Internal Revenue Service form that transforms subsidiaries into what the agency calls a “disregarded entity”. It costs the US and other countries billions of dollars in lost taxes a year and thrives thanks to determined business support, including a campaign two years ago that forced the Obama administration to retreat from altering it, and tax professionals worldwide who exploit its benefits.
The headline calls this an accidental tax break.
I don't believe that. The Rev Will Morris, a curate at St Martin's in the Field, London, likes to say he was behind the design of 'tick the box' when he worked for the IRS. I'm willing to believe him. At St Martin's I note the web site says of his role:
The work lives of our congregations are incredibly diverse. Some people are new to the workplace, others have decades of experience. And this is true across a wide range of occupations. Some of these younger people may have doubts, worries or concerns — ethical or practical — about their job that they cannot share with their peers or others at their place of work. Others may feel trapped in their current job, but not know how to find a new one. If you are interested in being mentored, in offering your experience as a mentor, frustrated in your own job, or interested in helping others consider how to find new jobs, please let Revd Will Morris know, and we will see if it is possible to start to match needs with experience. Contact william.morris@smitf.org
So what, you might ask, is a Church of England minister responsible for work mentoring in central London doing designing accidental tax breaks? Well, Rev Will Morris is no ordinary minister. This is a selected part of his CV, in which he makes proud boast of his involvement in this process:
Will Morris is currently Senior International Tax Counsel, and Director, European Tax Policy, in General Electric's corporate tax department. Since August 2003 he has been based in London, England and before that in Fairfield, CT. At GE Will works on a wide range of international tax matters relating to GE's foreign operations, with principal responsibility for coordinating GE's European tax policy program.
Until March 2000, Will was the Associate International Tax Counsel in the Office of Tax Policy at the U.S. Treasury in Washington, D.C. At Treasury he was responsible, among other things, for various highly unpopular (and, ultimately highly unsuccessful) anti-hybrid rules, as well as being one of the principal authors of the Treasury's 2000 Subpart F Study. He is also Chair of the European Tax Policy Forum, a registered UK charity that sponsors independent academic research into business tax issues, and chair of the AmCham EU CCCTB Task Force.
That CV does not also mention that he's chair of the CBI's tax committee - where I note no mention is made of his being a vicar either. No doubt that might though have influenced where Rev Morris was appointed when ordained, part time. Not for him St Barnabas by the Graveyard in Peckham or Tottenham. No, he got trendy Trafalgar Square where I am sure his debonair ways are appreciated.
But don't think for a minute Rev Will Morris thinks it is his task to preach good news to the poor - even though his parish church has long been associated with that concern. Far from it.
Will Morris is paid by GE to be a full time tax lobbyist.
His European Tax Policy Forum is happily pro-tax haven.
He is working relentlessly at the OECD to block country-by-country reporting in multinational corporations' accounts - which many of the world's leading development agencies think would massively help developing countries collect the tax owed to them and at the same time help expose tax haven abuse that so many multinational corporations undertake in their relationships with such countries.
And when I discussed the chance of their being a general anti-avoidance principle in the UK to stop tax avoidance I was pretty much told that it all depended on whether the CBI agreed - which means for all practical purposes Rev Will Morris. So I asked him if he agreed. And he doesn't, not at all. He wants the tax abuse opportunities to continue, of course.
I'm going to leave the fact Will Morris is ordained out of this discussion - except to say I think what he does in his day job is utterly and completely opposed to what I mean Christianity to mean.
What I am saying is two things. First, if Will Morris was involved given his subsequent activity I find it hard to believe that the abuse it allowed was not deliberate. It may not have been, but I'm entitled to say I find that hard to believe.
Second, if you want to identify a single person who stands more clearly in the way of tax reform in the UK then Will Morris is it.
The Rev Will Morris is the man seeking to make the rich richer. And the poor poorer. That's because the Rev Will Morris is the best friend of tax havens there is in the UK right now - making sure their abuse by multinational corporations remains hidden from view because he is working tirelessly to maintain their secrecy.
And the Rev Will Morris is the biggest supporter of tax abuse in this country right now because he is the person who will block measures to help stop it.
And he is one the principle proponents through the CBI of corporate tax cuts from which the wealthy benefit whilst the poor pay more.
Bad work vicar, very bad work indeed. And certainly not a mission from God, but definitely good for Mammon.
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These people give Jesus a bad name. There are plenty of decent people out there who look at these right wing vicars, tea party supporters etc and say Jesus is not on our side, he is on “theirs”, that he not on the same side as the poor but on the side of their oppressors. Wolves in sheep’s clothing, indeed.
Richard you write:- “…. the Rev Will Morris is the best friend of tax havens there is in the UK right now — making sure their abuse by multinational corporations remains hidden from view because he is working tirelessly to maintain their secrecy.”
Perhaps Rev Will Morris should read Nicholas Shaxson’s excellent book “Treasure Islands”.
Here his precious havens tax havens are shown as …
* Having declared war on, honest law-abiding people around the world.
* Where wealthy individuals hold over ten trillion dollars offshore
* The most important single reason why poor people and poor countries stay poor
Apparently there is no depth to which people are prepared to sink in their defence of the greedy pursuit of power and material wealth — including patronising the Christian church.
The Reverend Will Morris should devote less time to supporting repulsive tax havens and more to reading the scriptures including Matthew: Chapter 6:Verse 24 :-
“No one can serve two masters, for either he will hate the one and love the other; or else he will be devoted to one and despise the other. You can not serve both God and Mammon.”
In the meantime readers are reminded of the PSG “Song of Songs” Chapter 1 Verse 1 :-
“Never, invest or bank a single cent in the pigsties known as the Isle of Man, Jersey and Guernsey.”
The “trader” Alessio Rastani would appear to be the sort of chappie the Rev Will Morris would encourage to swell his stylish Trafalgar Square congregation.
Should have plenty to chat about over a cup-of-tea after the service …
…you really couldn’t make it up. Can’t help but contrast this with Henry Porter’s bucolic piece in the Guardian the other day, in which he concluded…
Sorry, I must have got my HTML stuff seriously wrong, please delete it Richard!
At labour party conf will have problems doing that – sorry
Does the Arch of Cant know? Has anybody told him? Does he have any influence?
Don’t know
As a Christian, this sickens me. Did Jesus not say “Render unto Caesar the things which are Caesar’s”?
When we use words like “pigsties” to describe island nations, we are in danger of condemning the entire island communities, rather than condemning the unacceptable tax haven activity which occurs within them. This is not fair or acceptable. By all means, expose the injustice, but DON’T condemn the whole island!
Fair point – I should have blocked that
Douglas Resident
The term “pigsties” describes the habitat provided by the island’s governments for their occupant and secretive “finance industries”.
This is not intended to be discourteous to the honest, indigenous people of the Isle of Man who are held in high regard throughout the world — indeed members of the PSG have genial connections with both the Manx business and social communities.
Regrettably when Dark Age governments of offshore secrecy jurisdiction combine with the mischief of 21st century financial monkey business democratic politics are emasculated — resulting in the absurd situation where the finance industry is allowed autonomy and freedom whilst the pervasive secrecy of these places renders them intolerant of criticism and the local people repressed by a complete lack of freedom of information.
Manx people best quality. Manx government lowest quality
I don’t see why the authors of this report think that ticking the box is in itself a tax break, because there are no schemes structures or arrangements achieved by ticking the box that couldn’t be structured by using a limited partnership if such an entity was available in the foreign country.
Uncle Sam simply decided that rather than quibble over whether a particular form of foreign partnership should be respected for US tax purposes a lot of time and money would be saved by all parties by giving US parents the option to treat unlisted subsidiaries for US tax purposes as though they were effectively US LLPs.
I expect that neither the Reverend gentleman nor the Archbishop of Canterbury will lose much sleep over this.
This may suggest that both the Reverend gentleman and Dr Rowan Williams are more interested in cultivating kudos rather than taking a Christian concern in the hunger and unrest facing a large part of the world’s 7 billion population — hunger and unrest largely created by the global hothouse for criminality a.k.a. tax havens.
This is not God’s work. Rather the work of shabby, covetous inhuman hypocrites.
good sensationalist stuff…………as usual (and its becoming a common failing for this sort of thing) it fails to mention the anti-arbitrage reglations in the UK which HMRC can use to attack this sort of structure if they are so minded…………
as Mark T points out you can acheive the same result with a partnership anyway – CTB elections are not aggressive/sexy tax planning they are an admin reducing election – again, not very sensationalist. but why let facts get in the way of a good blog……….
Oh dear, excuses, excuses
Of course retrospective action can be taken
The point is it should not happen in the first place
Is that really so hard to understand
Why should the government have to waste so much effort on anti social and abusive behaviour?
Mark T has missed the point that ‘tick the box’ FACILITATED tax abuse. It obviously didn’t legislate it. I suspect Mark T would find that if this legislation hadn’t been passed the man hours spent by IRS in investigating these ‘moneyboxes’ would certainly have cost 100 times less than the tax avoided as a result of it.
Steve knows perfectly well that while HMRC may be a Rotweiler for SMEs it is a poodle for the big 4 & the large corporations who know exactly how to neuter it.
What has this got to do with HMRC? CTB is a US tax issue.
You can check the box on a Uk company to make it transparent from a US perspective which can give tax advantages in the Uk or us
The point is that hmrc can use anti arb regs to block any Uk advantage, but nobody seems interested in this point.
I was not aware the big 4 were exempt from applying certain pieces of tax regulation William, thanks for enlightening me