International
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June 14, 2024
Mining Co. Entity Can't Deduct Loan Interest, UK Court Says
A U.S. mining company's entity in the U.K. that was created to save taxes through the acquisition of a Texas-based firm cannot overturn the Upper Tribunal's decision that its U.K tax deductions weren't deserved, according to a Court of Appeal judgment.
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June 14, 2024
G7 Chiefs Agree On Using Frozen Russian Profits For Ukraine
Leaders from the Group of Seven countries reached a provisional agreement to use windfall profits from frozen and immobilized Russian state assets to back a $50 billion loan to Ukraine, they announced Friday, although details have to be ironed out before the end ot the year, said Italy's prime minister, Giorgia Meloni.
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June 14, 2024
Swiss Council OKs Tax Agreements With Angola, Germany
Switzerland's executive body, the Federal Council, approved a double taxation agreement with Angola and an amendment to an existing agreement with Germany, it announced Friday.
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June 14, 2024
Taxation With Representation: Kirkland, Arnold & Porter
In this week's Taxation with Representation, Noble Corp. PLC buys Diamond Offshore Drilling Inc., Cognizant buys Belcan, AlphaSense raises funding to buy Tegus, and Matador Resources Co. acquires a subsidiary of the EnCap Investments portfolio company Ameredev II Parent.
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June 14, 2024
ABA Tax Section Calls For Revision To Stock Buyback Regs
The U.S. Department of the Treasury and the IRS should narrow a rule in proposed regulations on the stock buyback tax regarding U.S. subsidiaries funding repurchases of their foreign parents' stock, the American Bar Association's Tax Section said in a letter released Friday.
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June 14, 2024
Full DC Circ. Won't Hear Foreign Disclosure Penalty Dispute
The D.C. Circuit declined to reconsider its ruling overturning a major U.S. Tax Court decision that had crimped the administrative collection arm of the Internal Revenue Service, letting stand a panel's restoration of the agency's power to more freely penalize undisclosed foreign corporations.
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June 14, 2024
UK Broker Denied Supreme Court Hearing Over Cum Ex Raids
Judges at a London court refused on Friday to allow a brokerage to challenge at the U.K. Supreme Court findings that a raid on its London office during an investigation into tax fraud in 2022 was legal, finding that the "outcome of any appeal would be no different."
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June 14, 2024
EU Transfer Pricing Law To Involve Basic Rights, Prof Says
A proposed European Union law on transfer pricing would, if adopted, mean the EU's charter of fundamental rights became relevant to transfer pricing disputes, a tax professor said Friday.
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June 13, 2024
Canada Should Look Beyond Capital Gains Tax Hike, IMF Says
Though Canada's proposed capital gains tax increase would be another positive development for a country that has largely fared well in its pandemic rebound, the country should consider more avenues to raise revenue, the International Monetary Fund said.
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June 13, 2024
Denmark Considering $302M Entrepreneur Tax Break Package
Denmark's finance ministry announced a package of more than 2.1 billion kroner ($302 million) in tax breaks and other measures for entrepreneurs that it says will help drive innovation and overall grow the country's attractiveness for startups.
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June 13, 2024
Labour Manifesto Targets Wealthy To Fill Funding Gaps
Labour set out plans in its election manifesto on Thursday to raise a total of more than £8.5 billion ($10.8 billion) in tax reforms that target wealthy taxpayers, although some analysts questioned whether the measures will add up.
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June 13, 2024
EU Eyeing Exchange Rules Linked To Min. Tax, Official Says
The European Union is looking to introduce rules regarding the exchange of information pertaining to the global minimum corporate tax, a top official in the EU's executive branch said Thursday.
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June 13, 2024
Swiss Finance Minister Defends Tax Competition
Switzerland's finance minister defended tax competition, saying citizens' right to move to lower-tax jurisdictions helps keep public authorities from taxing and spending to excess.
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June 13, 2024
EU Scales Back Talks On Proposed Law To Combat Shell Cos.
European Union countries have broadly agreed to work on a scaled-back legislative proposal to combat shell companies that would give each country more freedom to decide what anti-abuse action to take, an EU official said.
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June 12, 2024
Senate Budget Chair Seeks End To Carried Interest Tax Break
Lawmakers should end the favorable tax treatment of income from carried interest compared with ordinary earned income, Senate Budget Committee Chairman Sheldon Whitehouse said Wednesday.
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June 12, 2024
Digital Taxes May Take Hold Regardless Of Treaty Signing
An internationally agreed-upon freeze on digital levies may continue to thaw even if countries meet their impending deadline to sign a related treaty for new corporate tax rules, in part because the accord faces a hazy path to formal ratification.
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June 12, 2024
Feds Strike Deal Ending $7M FBAR Penalty Cases
The U.S. government agreed to settle a pair of foreign bank account reporting cases in which it had sought a total of $7 million from a former insurance broker and his wife's estate, according to a court order filed Wednesday in California federal court.
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June 12, 2024
Groups Push Back On Stock Buyback Tax Test's Scope
The U.S. Treasury Department's proposed stock buyback tax rules go too far in trying to assess whether the main purpose of a U.S. subsidiary's funding purchase of its foreign parent's stock is to avoid the tax, two groups said in comments released Wednesday.
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June 12, 2024
Aussie Senate's Final PwC Report Focuses On Integrity Recs
Australia's Senate released its final report Wednesday regarding PwC's marketing of confidential draft tax laws to clients, pushing for both consulting firms and the government to assure that the firms, particularly the Big Four, act with integrity.
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June 12, 2024
Treasury Issued Over $1B In Clean Vehicle Tax Credits
The clean vehicle tax credit of up to $7,500 has saved buyers more than $1 billion in total upfront costs since January, the U.S. Treasury Department announced Wednesday, saying the figures represent a major milestone in lowering transportation costs since the incentive was updated in 2022.
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June 12, 2024
Italy Investigating €13M VAT Fraud Involving Chinese Fabric
An Italian judge issued a freezing order against four people and a company as investigations continue into a scheme involving the illegal importation of Chinese fabric that caused over €13 million ($14.1 million) in value-added tax losses, the European Public Prosecutor's Office said Wednesday.
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June 12, 2024
New Dutch Gov't Agrees On Top Finance Official
The incoming right-wing Dutch government has agreed to appoint a conservative politician as finance minister and to maintain a separate position for the state secretary for taxation in order to comply with a recent Netherlands Supreme Court tax ruling on compensation to investors, Dutch media reported.
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June 11, 2024
US Issues Sanctions For $50M Guyana Gold Tax Evasion
Two Guyanese businessmen and a Guyanese official were sanctioned by the U.S. Treasury Department on Tuesday after a probe into a corruption scheme that helped the businessmen evade $50 million in gold export taxes that should have been paid to Guyana's government, Treasury said.
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June 11, 2024
Latvia Renominates EU Trade Commissioner To Retain Role
The Latvian government has renominated former Prime Minister Valdis Dombrovskis to retain his European Commission position as the commissioner for trade, the government announced Tuesday.
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June 11, 2024
Extension OK'd For Carbon Program Tax Exemption In Norway
An extension of a program that makes certain carbon emissions tax-exempt for some Norwegian businesses was approved by an official watchdog group Tuesday.
Expert Analysis
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Coke, 3M Tax Cases May Not Settle Blocked Income Debate
Even if the challenged U.S. Department of the Treasury regulation on blocked income is struck down by the U.S. Tax Court in the pending Coca-Cola and 3M cases, the obligations of a taxpayer that had, but failed to avail itself of, alternative means to secure payment will remain an open question, say Matthew Frank and Amanda Varma at Steptoe & Johnson.
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IRS Should Level The Field For R&D Tax Credits
A recent increase in denials of research and development tax credits to small businesses in the architectural, engineering and construction community shows the Internal Revenue Service should issue new guidance to ensure a fair playing field and an opportunity to continue innovating in the U.S., says Julio Gonzalez at Engineered Tax Services.
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Applying OECD Guidance On COVID-19 Transfer Pricing
In light of the recently released Organization for Economic Cooperation and Development's guidance on the transfer pricing implications of the pandemic, taxpayers should be prepared to explain and defend their transfer pricing decisions for fiscal year 2020 for contemporaneous documentation and in future tax audits, say Susan Fickling and TJ Michaelson at Duff & Phelps.
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Mitigate Key FCPA Risks With Tailor-Made Compliance
Multinational companies should take a pragmatic approach to Foreign Corrupt Practices Act compliance by being aware of key risk areas — such as inappropriate gift-giving, liability for third-party actions, and countries with recurring corruption issues — and implementing custom-designed procedures that evolve with their operations, says Howard Weissman at Miller Canfield.
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Tax Takeaways From India's Proposed Budget
Consultants at Deloitte discuss the tax implications of India's latest budget proposals, including the potential benefits for foreign portfolio investors and offshore funds migrating to India's new international financial services center, and the possible rise of M&A costs.
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A Tough Road Ahead for Democrats' Ambitious Policy Agenda
While Democrats in Congress are well on their way to enacting an initial COVID-19 relief bill, they will face challenges when pivoting to President Joe Biden's Build Back Better goals for job creation and economic revitalization, say Russell Sullivan and Radha Mohan at Brownstein Hyatt.
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Coca-Cola Tax Ruling Offers 5 Lessons For Multinationals
The U.S. Tax Court's decision that Coca-Cola owes more than $3.3 billion in taxes is instructive on important transfer pricing concepts, including those regarding intercompany agreements, the arm's-length standard and tax certainty, says Justin Radziewicz at Duff & Phelps.
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Start Preparing For Germany's Corporate Sanctions Act
Germany’s soon-to-be-adopted Corporate Sanctions Act carries a presumption of mandatory prosecution but also a defense in cases where reasonable precautions fail to prevent nonmanagers from committing crimes, so companies should start putting such compliance programs into place now, say attorneys at Arnold & Porter.
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Analyzing Illegality Defense Trend In Investor-State Arbitration
Cairn Energy v. India, a recent Permanent Court of Arbitration case, highlights the growing trend of states alleging illegal investor conduct to challenge tribunal jurisdiction or investor claim admissibility, say Caline Mouawad at Chaffetz Lindsey and Jessica Beess und Chrostin at Covington.
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Small Biz Should Self-Advocate For Tax Relief Under Biden
Small and medium-sized businesses have significant potential for achieving regulatory relief from the U.S. Department of the Treasury and other federal agencies during the Biden administration, but to do so they must define their priorities, leverage two federal statutes that require the Treasury to protect them and make their voices heard through communal e-advocacy, says Monte Silver at Silver & Co.
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Consider Mutual Agreement Procedures For Double Tax Relief
Taxpayers wary of using mutual agreement procedures for double taxation relief should revisit the process, which is more straightforward than many believe, lest they miss out on tax savings, says Monique van Herksen of Simmons & Simmons.
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A Road Map For US Involvement In Europe's Cum-Ex Probe
The dividend arbitrage trading strategy known as cum-ex continues to face regulatory scrutiny in Europe, and stateside regulators may soon follow suit with the U.S. Securities and Exchange Commission’s recent American depositary receipt probe as a guide for enforcement, says Joshua Ray at Rahman Ravelli.
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Congress Should Make TCJA Income Definition Permanent
Congress should not allow the Tax Cuts and Jobs Act's definition of adjusted taxable income, which includes depreciation and amortization, to expire in 2022 because it would discourage debt-free investment, running counter to the law's intent, says George Callas at Steptoe & Johnson.