International
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August 19, 2024
Chile Senate Panel OKs Bank Secrecy, Whistleblower Plans
Chile's Senate Finance Committee approved changes to a larger tax compliance bill's proposals for lifting the country's bank secrecy laws in certain situations and for creating an anonymous whistleblower process for reporting tax crimes.
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August 19, 2024
Treasury Floats Timing Shift For Foreign Currency Accounting
The U.S. Treasury Department proposed regulations Monday that would adjust the timing for when companies could opt to use the so-called mark-to-market accounting method for gains or losses that arise from foreign currency transactions.
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August 19, 2024
Swedish Advisory Body Considering Pillar 2 Updates
A Swedish advisory council is considering a proposal that would add administrative and other clarifications to the country's implementation of the Organization for Economic Cooperation and Development's global minimum tax on large multinational corporations.
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August 16, 2024
Kyocera Says It Doesn't Need Records For R&D Credits
Multinational electronics maker Kyocera said Friday that it wasn't required to keep any specific paperwork to back up its claim to research tax credits, contrary to the U.S. government's claims, according to a filing in South Carolina federal court.
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August 16, 2024
UK Dependency Considering Global Minimum Tax Bills
Jersey is considering draft legislation that would implement the Organization for Economic Cooperation and Development's 15% minimum tax on multinational entities making over €750 million ($828 million) annually, in line with a declaration from it and other U.K. crown dependencies to do so starting next year.
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August 16, 2024
Democratic Gov't Control Could Bolster US' Pillar 2 Plans
Vice President Kamala Harris and congressional Democrats would likely double down on plans to align the U.S. tax code with the global minimum tax designed by the Organization for Economic Cooperation and Development if they win total control of the federal government in the November elections.
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August 16, 2024
UN Votes For Global Services As First Priority Under Tax Pact
The United Nations voted Friday to make taxation of cross-border services the most prioritized topic for a legally binding agreement to be finalized by late 2027 alongside the organization's framework convention on international tax cooperation.
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August 16, 2024
IRS To Let Private Cos. Into Real-Time Biz Audit Program
The Internal Revenue Service is opening its compliance assurance process real-time audit program to privately held C corporations, including foreign-owned ones, for 2025, the agency announced.
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August 16, 2024
Taxation With Representation: Cleary, Kirkland, Skadden
In this week's Taxation with Representation, Mars Inc. sets a 2024 record with its $36 billion acquisition of Kellanova, Carlyle inks a $3.8 billion purchase with Baxter International Inc., and Performance Food Group Co. agrees to a $2.1 billion cash deal with Cheney Bros. Inc.
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August 15, 2024
Doctor Wants Contempt Fine Dropped In Foreign Asset Case
A doctor who incurred $1.1 million in liabilities for failing to report his foreign bank accounts is asking a Michigan federal court to waive his $20,000 civil contempt fine because the court restricted his only financial assets to paying the liabilities.
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August 15, 2024
Tax Pros Navigate Chaos, Rewards In Climate Law's 2nd Year
Energy tax attorneys have been knee-deep in project finance deals for the past year since the Inflation Reduction Act of 2022 triggered a flurry of clean energy investments, but the work, they say, has been fulfilling as part of broader efforts to save the environment.
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August 15, 2024
Taxes Could Be Key To Cutting Crypto Emissions, IMF Says
The growing environmental impact of crypto-asset mining and related data centers could be mitigated with tax measures aimed directly at such facilities, the International Monetary Fund said Thursday.
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August 15, 2024
Germany Seeks Input On Tightened Transfer Pricing Rules
Germany is poised to make multinational corporations responsible for showing the economic necessity of intra-group, cross-border debt relationships when they deduct expenses for financing with borrowed capital, according to a consultation by the federal government.
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August 15, 2024
Finland To Have EU's 2nd-Highest VAT Rate Starting Sept. 1
Finland's general value-added tax rate will jump to 25.5% from 24% starting Sept. 1, the country's tax agency said Thursday, putting it behind only Hungary for the highest VAT rate in the European Union.
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August 15, 2024
Aussie Senate Economics Committee OKs 15% Min. Tax Bill
The Australian Senate's Economics Legislation Committee said it supports the passage of a three-bill package that would implement the OECD's 15% global corporate minimum tax on large multinational entities, sending it to the entire Senate for approval.
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August 15, 2024
UK Plastic Packaging Tax Revenue Dipped By 6%
The U.K. collected £268 million ($344 million) from its tax on certain plastic packaging manufactured in or imported into the country in the 2023-2024 fiscal year, down 6% from the £285 million the year prior, HM Revenue & Customs said Thursday.
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August 14, 2024
PwC Owes $11M For Tax Errors, Real Estate Group Says
PwC should pay £8.9 million ($11.4 million) in damages to a real estate group for miscalculating its tax liabilities and mispricing its properties, which prompted several additional assessments and penalties, according to a claim in a London court.
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August 14, 2024
Baker McKenzie Adds Tax Expert To Monterrey Office
Baker McKenzie has added a partner from Turanzas Bravo & Ambrosi to its Monterrey, Mexico, office who brings more than 15 years of experience practicing international trade law with a focus on taxation and customs-related litigation.
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August 14, 2024
Kenya Tax Court Finds Chinese Firm Dodged $7.8M VAT
A Kenyan tax court affirmed an assessment that found a China-based firm used a series of shell companies to dodge over 1 billion Kenyan shillings ($7.8 million) in value-added tax payments, the Kenya Revenue Authority said Wednesday.
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August 14, 2024
Swiss Seeking Input On Delays Of Crypto-Asset Info Exchange
Switzerland's executive body, the Federal Council, is looking for public input on when it should begin automatically exchanging financial information regarding crypto-assets with countries with which it already has set up general automatic exchange of information agreements, its finance ministry said.
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August 14, 2024
EU General Court Jurisdiction Expanded To VAT Cases
The General Court of the European Union will be able to make preliminary rulings in cases involving the EU's common system of value-added taxes starting Oct. 1, following an expansion of the court's jurisdiction.
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August 14, 2024
Pros Lament Lack Of Ownership Clarity In New EU Law
The lack of a clear beneficial ownership definition in new European Union legislation designed to speed up the repayment of withholding taxes represents a missed opportunity — and could cause confusion for investors about whether they are in fact eligible for a refund, tax professionals say.
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August 14, 2024
Other Price Rises Offset German Tampon VAT Cut, Study Says
Germany's reduction in the value-added tax on female sanitary products, such as tampons, has led to higher prices on panty liners, a Munich-based think tank said in a news release Wednesday.
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August 13, 2024
Walz Backed Tax Hikes Funding Plans For Children, Families
As Minnesota's governor, Democrat Tim Walz, now the presumed vice presidential nominee of his party, separated himself from most other governors by signing into law numerous tax increases funding progressive priorities such as a paid family leave plan and the nation's largest child tax credit.
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August 13, 2024
Treasury's Loss Rules Take Broad Approach To Min. Tax Deal
The U.S. Treasury Department recently dashed the hopes of multinational corporations seeking regulations that would have carved out an international minimum tax agreement from interacting with long-standing domestic rules aimed at preventing companies from using the same economic loss twice.
Expert Analysis
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OFAC Designation Prosecutions Are Constitutionally Suspect
Criminal prosecutions based on the Office of Foreign Assets Control’s sanctions-related listing decisions — made with nearly unfettered discretion through an opaque process — present several constitutional issues, so it is imperative that courts recognize additional rights of review, say Solomon Shinerock and Annika Conrad at Lewis Baach.
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How The OECD Global Tax Proposal Could Affect M&A
Following agreement on the Organization for Economic Cooperation and Development’s Pillar Two proposal to introduce a global minimum tax, domestic implementation is expected to have a significant impact on international M&A transactions, with financial modeling, deal structuring, risk allocation and joint venture arrangements likely to be affected, say lawyers at Freshfields.
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UK Shares-Tax Proposals Offer Long-Awaited Modernization
The U.K. government's recent consultation on the introduction of a new tax on transactions in securities raises detailed legal and practical issues, but the prospect of a single digital stamp tax offering both streamlined legislation and administration will be welcomed, say Zoë Arnautov and Mark Sheiham at Simmons & Simmons.
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IRS Foreign Tax Credit Pause Is Welcome Course Correction
A recent IRS notice temporarily suspending application of 2022 foreign tax credit regulations provides wanted relief for the many U.S. multinational companies and other taxpayers that otherwise face the risk of significant double taxation in their international operations, say attorneys at Mayer Brown.
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IRS Criminal Probe Spells Uncertainty For Malta Pension Plans
The IRS’ recent scrutiny of Malta pension plan arrangements — and its unusual issuance of criminal administrative summonses — confirms that it views many of these plans as illegal tax evasion schemes, and the road ahead will not be smooth and steady for anyone involved, say attorneys at Kostelanetz.
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IRS Announcement Will Aid Cos. In Buyback Tax Planning
Recent IRS transitional guidance regarding current requirements for reporting and payment of the stock repurchase excise tax will help corporate taxpayers make decisions about records retention and establishing reserves for future tax payments, say Xenia Garofalo and Kyle Colonna at Eversheds Sutherland.
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Flawed Analysis Supports Common Law Tax Deficiency Ruling
The Colorado federal district court’s recent decision in Liberty Global, holding that the U.S. Department of Justice may assert a common law tax claim without the notice of tax deficiency required by the Internal Revenue Code, relies on a contorted reading of the statute and irrelevant case law, say Loren Opper and Christie Galinski at Miller Canfield.
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Review Of Repatriation Tax Sets Justices On Slippery Slope
The U.S. Supreme Court’s recent decision to review the constitutionality of the repatriation tax in Moore v. U.S. has implications for many tax rules involving unrealized amounts and could leave the court on the brink of invalidating large swaths of the Internal Revenue Code, say attorneys at Eversheds Sutherland.
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What To Make Of IRS' New Advance Pricing Guidance
Recent guidance on the IRS' goals for its advance pricing agreement system provides helpful insight into review and decision-making procedures for advance pricing agreement requests, but it also raises questions about the IRS' objectives, say Richard Slowinski and Stefanie Kavanagh at Alston & Bird.
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Reserved Investor Fund Would Plug Gap In UK Finance Market
The reserved investor fund recently proposed by HM Treasury has the potential to be a welcome tax-efficient addition to the U.K.’s canon of products for real estate investments, with attractive features for companies and, in particular, large asset managers, say lawyers at Herbert Smith.
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The Reciprocal Tax Bill Is A Warning Shot At Pillar 2
A bill recently introduced in the House of Representatives to reciprocally tax countries deemed to have imposed discriminatory taxes on U.S. citizens and businesses takes aim at countries implementing the global minimum tax treaty known as Pillar Two, with which the U.S. has not complied, says Alan Cole at the Tax Foundation.
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What Tax-Exempt Orgs. Need From Energy Credit Guidance
Guidance clarifying the Inflation Reduction Act’s credit regime, expected from the U.S. Department of the Treasury this summer, should help tax-exempt organizations determine the benefits of clean energy projects and integrate alternative energy investments into their activities, say attorneys at Morgan Lewis.
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How Foreign Info Return Penalty Case May Benefit Taxpayers
The U.S. Tax Court's recent decision that the Internal Revenue Service cannot penalize taxpayers for failing to file foreign corporation information returns may give similarly situated taxpayers an opportunity to also avoid penalties, provided they protect their rights before the decision is overturned or mooted by legislation, say attorneys at Arnold & Porter.