{ "media_type": "text", "post_content": "What type of consulting is it when you tell the client what to do to minimize the amount of taxes?", "post_id": "5a38d517cb982400136c449e", "reply_count": 15, "vote_count": 3, "bowl_id": "552d1d24dc1c586b09d2d051", "bowl_name": "Consulting" }

What type of consulting is it when you tell the client what to do to minimize the amount of taxes?

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Fraud

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Tax strategy

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Any one may so arrange his affairs that his taxes shall be as low as possible; he is not bound to choose that pattern which will best pay the Treasury; there is not even a patriotic duty to increase one's taxes. Judge Learned Hand

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TLDR: For the borderline fraud usually it’s highly specialized Tax lawyers from firms who play in the grey areas of the Tax law. For basic tax planning for credits it’s usually the rest of us. I came from the Federal Tax Department. There are legitimate scenarios where the client was never taking a credit or correctly tracking tax accounting to applying the code to minimize their taxes- let’s call that user error. In the past 5 years there have been major hacking scandals of Tax boutique firms that do exactly what you are talking about and it’s usually highly specialized tax law firms playing around the grey area of the Tax law. Big 4 doesn’t like to take the risks those firms do and I’ve seen clients turned down to attempting to do these schemes under our watch.

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Apple’s core strategy is creating a Temporary Tax difference to reduce their taxes by not bringing their profits back into the US and therefore not having to pay US income tax. They are sitting on cash/investments in a non US bank account. If they ever did bring that cash back to the US- they would be taxed on it and they are waiting for a tax holiday. Another thing companies like to do is negotiate with jurisdiction for tax breaks- a.la. Amazon a few months ago

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OP- Grey area Tax planning is not done by the Big 4. The type of consultant is usually an LLM’s- Masters of Law in Tax not a CPA. Big four tax planning is typically about applying a well known process the client may have missed. It’s not about creating aggressive tax haven holding companies.

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I came from the practice- there is a difference between planning to be tax efficient and being someone who minimizes the amount of taxes you pay. There are business rules you can apply that are standard practice like apply for credits or tax schemes that sit in the grey area of the Tax law.

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What KPMG said

But if Apple does it..?

Might be transfer pricing, depending on client’s industry

Wait for it: Tax

So to clarify is this something that the consulting arms of Big 4 do, not accounting?

They have tax practices, the people that do it are CPAs, can be cross sold with more traditional consulting, not part of audit work typically

KPMG, there are tax practices at all of the big four that will advise on tax efficient structuring. Those people are often accountants.

Got it, it does seem grey

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