Permanent Subcommittee on Investigations

Dividend Tax Abuse: How Offshore Entities Dodge Taxes On U.S. Stock Dividends

Date: September 11, 2008
Time: 9:00am
Location: Room 106, Dirksen Senate Office Building
Agenda:

The Permanent Subcommittee on Investigations hearing, “Dividend Tax Abuse: How Offshore Entities Dodge Taxes On U.S. Stock Dividends,” examined how some financial institutions have designed, marketed, and implemented transactions to enable foreign taxpayers, including offshore hedge funds, to dodge millions of dollars of taxes on U.S. stock dividends. The hearing also examined whether current law relating to dividend taxation and withholding should be strengthened. The Subcommittee issued a Subcommittee staff report in conjunction with the hearing summarizing its investigative findings and recommendations. Witnesses included representatives of U.S. financial institutions, offshore hedge funds, a tax expert, and the Internal Revenue Service.

Exhibits 1 – 34

In conjunction with this hearing, the Subcommittee Staff issued a report entitled, “Dividend Tax Abuse: How Offshore Entities Dodge Taxes on U.S. Stock Dividends.”  The Report is available via the link located at the top left corner of this webpage. 

Witnesses

Panel 1

REUVEN S.

AVI-YONAH

Irwin I. Cohn Professor of Law

University of Michigan School of Law

Panel 2

JOSEPH M.

MANOGUE

Treasurer

Maverick Capital, Ltd.

Panel 2

RICHARD

POTAPCHUK

Director of Treasury and Finance

Highbridge Capital Management LLC

Panel 2

GARY I.

WOLF

Managing Director

Angelo, Gordon & Co.

Panel 3

JOHN

DEROSA

Managing Director, Global Tax Director

Lehman Brothers Inc.

Panel 3

MATTHEW

BERKE

Managing Director and Global Head of Equity Risk Management

Morgan Stanley & Co.

Panel 4

THE HONORABLE DOUGLAS H.

SHULMAN

Commissioner

Internal Revenue Service

Related Links

Printed Hearing Record