Given the amount of money at stake, which could eventually come to more than $2 billion in back taxes and fines, the attempt by UPS to create an ‘arm’s length’ reinsurance company in Bermuda appears to have been remarkably clumsy, according to Judge Ruwe’s 114-page opinion.
In laying the groundwork for the restructuring of its shipper’s risk program in 1983, the company seems to have drawn up little or nothing in the way of documentation that could later be used to give the appearance that the change was driven by sound business reasons, rather than a desire to avoid US taxes.
UPS offered little evidence to show it was not avoiding US taxes
25 years ago
Topics
Bermuda Fraud Insurance Tax USAKeywords
Allen Dougherty Overseas Partners Ltd. UPS