International
-
August 01, 2024
Taxpayers Find Belgian Pillar 2 Request Sudden, Intrusive
Belgian demands for detailed information that must be supplied within a short deadline are troubling taxpayers within the scope of the global minimum corporate tax, who said the country's quest for information is more challenging than that imposed by other governments.
-
August 01, 2024
UK Capital Gains Tax Liabilities Decline, HMRC Says
Capital gains tax liability in the U.K. declined in the 2022-2023 tax year, HM Revenue & Customs said in a news release Thursday.
-
July 31, 2024
Treasury's New 'Killer B' Rules May Revive Controversies
Recent U.S. Treasury Department regulations centered on contentious 2011 guidance aimed at so-called Killer B transactions have revived long-standing questions about how much authority rule writers have to target what they perceive as corporate tax avoidance in these maneuvers.
-
July 31, 2024
'Tax Avoidance' Fuels Global Reporting Pushback, Pro Says
A lobbying effort from multinational corporations to dissuade states from adopting mandatory worldwide combined reporting aims to keep billions of dollars in profits that were shifted into tax-friendly jurisdictions beyond the reach of tax administrators, a retired researcher from a progressive think tank said Wednesday.
-
July 31, 2024
Cos. Insist Chevron Ruling Doesn't Change Deduction Claims
A medical device company and a food services firm that are each challenging Internal Revenue Service denials of dividend deduction claims told the U.S. Tax Court that the recent U.S. Supreme Court decision overturning Chevron deference doesn't change the validity of their arguments.
-
July 31, 2024
SEC Asked For Public Tax Reporting By Group With $2.3T
The U.S. Securities and Exchange Commission was asked Wednesday to begin a rulemaking procedure to require public country-by-country reporting of tax by nearly 90 investment funds, labor unions, activists and others with combined assets over $2.3 trillion.
-
July 31, 2024
Americans Overseas Launch Residence Taxation Lobby Group
An advocacy group representing U.S. citizens living abroad announced it has officially registered as a lobbyist to continue to push Congress to pass residence-based taxation laws for the benefit of individuals comparable to those for corporations.
-
July 31, 2024
Senators Ask Treasury To Limit Biofuel Tax Credit Eligibility
The U.S. Treasury Department shouldn't grant biofuel production tax credits to companies that use foreign-sourced feedstocks, a coalition of Republican and Democratic senators said in a letter published Wednesday.
-
July 31, 2024
DMH Stallard Adds Tax Atty To London Practice
DMH Stallard LLP hired a tax attorney for its London office who spent more than a decade at HM Revenue & Customs working on compliance and policy, according to a news release.
-
July 31, 2024
Large UK Cos. Expect Major Pillar 2 Administrative Burden
While businesses largely reported they expect the U.K.'s implementation of the OECD's corporate global minimum tax to have little to no impact on the amount of tax they pay, they also are concerned about the law's administrative burden, HM Revenue & Customs said.
-
July 31, 2024
Australia Seeking Members For Pillar 2 Working Group
The Australian Taxation Office said it is seeking members to join a working group focused on the country's implementation of the Organization for Economic Cooperation and Development's Pillar Two global minimum tax.
-
July 31, 2024
EU Seeks Feedback On Effectiveness Of Anti-Avoidance Law
The European Commission said Wednesday that it is looking for feedback on how the European Union's anti-tax avoidance directive has fared since going into force in 2020, in particular concerning the bloc-wide implementation of the OECD's global minimum corporate tax standards.
-
July 31, 2024
French Politician Wants VAT Cut For Repairs To Churches
A French politician is asking the European Commission to consider expanding the scope of rate reductions for value-added taxes to include the renovation of historic monuments, including churches, according to a letter released Wednesday.
-
July 30, 2024
IRS Spinoff Guidance Raises Practical Concerns, NY Attys Say
Recent IRS guidance narrowing the corporate spinoff transactions that revenue officials will approve as tax-free ahead of time doesn't adequately consider the practical and commercial factors involved in these transactions, the New York State Bar Association's Tax Section said Tuesday.
-
July 30, 2024
Israeli Man Seeks To Avoid Discovery In $3.6M FBAR Case
A federal court should not order the Israeli founder of a pet toy company to show cause for defying its discovery orders in the U.S. government's $3.6 million case over his failure to report foreign bank accounts because he is ending his defense, his attorneys said Tuesday.
-
July 30, 2024
Kyocera Chides Gov't Attack On Jurisdiction In $7M Tax Case
The government's attempt to defeat a South Carolina federal court's jurisdiction is improper because it relies on a roughly $44 million assessment lodged months after electronics maker Kyocera filed an amended complaint for a $7 million federal tax refund, according to the company.
-
July 30, 2024
Ropes & Gray Adds Partner To Int'l Tax Practice
Ropes & Gray LLP recently added a tax adviser with a wealth of experience navigating transactions, funds and investments for clients as a partner in its New York office, the firm said.
-
July 30, 2024
Chubb Says It Would Be Harmed By US-Swiss Treaty
Chubb and its shareholders would be significantly harmed by the terms of a proposed new bilateral tax treaty between the U.S. and Switzerland because it would be denied tax relief despite having been domiciled in Switzerland for over 15 years, the global insurer said in a letter released Tuesday.
-
July 30, 2024
Husch Blackwell Hires UB Greensfelder Partner In St. Louis
Several years after Husch Blackwell LLP's newest partner, Garrett Reuter Jr., graduated from law school, he joined Greensfelder Hemker & Gale PC to work alongside his late father. Now, he's bringing clients he grew up watching his father work with, to a new platform.
-
July 30, 2024
UK Healthcare Ex-Directors Banned For £30M In Unpaid Taxes
Two former directors of a defunct U.K. healthcare company are banned from holding executive positions at any business after failing to pay more than £30 million ($38.5 million) in taxes, the government's insolvency agency said Tuesday.
-
July 30, 2024
Israel Moving To Adopt Portion Of Global Minimum Tax
Israel's Ministry of Finance said it is working to adopt a portion of the Organization for Economic Cooperation and Development's 15% global minimum tax on large multinational entities starting in 2026 while delaying consideration of two other portions.
-
July 30, 2024
Tax Pros Vent Displeasure At EU Disclosure Law
Tax professionals commenting on a European Union disclosure law by the deadline Tuesday vented long-held displeasure at the measure, which requires tax preparers to reveal cross-border strategies.
-
July 30, 2024
Pension Tax Reform Could Unlock £100B For UK Growth
Changing how pensions are taxed in the U.K. could potentially unlock more than £100 billion ($128 billion) for domestic investment over the next five years, according to a recent analysis by a pensions consultancy.
-
July 29, 2024
Utah Biz Groups Latest To Challenge Corp. Disclosure Law
Several small-business associations in Utah became the latest group to challenge the Corporate Transparency Act's disclosure requirements, telling a federal court Monday the statute violates several constitutional provisions, including the guarantee of due process.
-
July 29, 2024
Immigrants Paid $96.7B In Taxes In 2022, ITEP Study Says
Unauthorized immigrants paid $96.7 billion in federal, state, and local taxes in 2022 but received few benefits in return, according to a new study released Monday, whose authors said granting such taxpayers work authorization would boost tax revenue and economic activity.
Expert Analysis
-
How Japan's Implementation May Change The Pillar 2 Debate
Japan’s outline of proposed legislation adopting a primary component of the Organization for Economic Cooperation and Development's 15% global minimum tax will increase pressure on countries — including the U.S. — that have not committed to adopting Pillar Two, says Takato Masuda of Nishimura & Asahi.
-
Foreign Tax Credit Proposal Is Some Help, But More Is Needed
New foreign tax credit regulations proposed by the U.S. Treasury Department provided some measure of relief on cost recovery and royalty withholding, two of the most troublesome aspects of the 2021 final foreign tax credit regulations, but the final regulations are still harmful to many taxpayers, making litigation inevitable, say attorneys at Fenwick.
-
IRS' Tax Gap Statistics Don't Paint A Full Compliance Picture
The Internal Revenue Service's recent report indicating a widening tax gap sheds important light on tax compliance, underlines key pressure points and provides insights into how tax administration could be improved; but tax gap estimates also have their limits, says Joyce Beebe at Rice University.
-
How High Court Could Change FBAR Penalty Landscape
On Wednesday, the U.S. Supreme Court will hear Bittner v. U.S., a case that will affect many people penalized for failing to file a Report of Foreign Bank and Financial Accounts, and there are important procedural implications should the government's position be reversed, say Reuben Muller and Andreas Apostolides at Cole Schotz.
-
IRS Memo May Change IP Royalty Tax Prepayment Planning
A recent Internal Revenue Service advice memorandum finding a taxpayer was not permitted to prepay tax on contingent royalties after contributing intellectual property offshore is a noteworthy departure from earlier guidance that highlights potential differences between actual and deemed licenses, says William Skinner at Fenwick.
-
What IRS Funding Increase Means For Taxpayers
The Internal Revenue Service will first use the influx of funding from the Inflation Reduction Act to address customer support and personnel issues, but with over half the money allocated to enforcement, corporations and high-net-worth individuals will face increased scrutiny, say Patrick McCann Jr. and Jasen Hanson at Chamberlain Hrdlicka.
-
6 Tax Considerations For Life Sciences Collaboration Deals
Given recent IRS guidance and changes to certain tax rates and deductions, biotech and life sciences companies entering into collaboration agreements should assess several unique taxation issues affecting matters ranging from research and development expenditures to profit-sharing terms, say attorneys at Orrick and Andersen Tax.
-
Rushed Multilateral Negotiations Caused Two-Pillar Tax Mess
Cracks appearing in the two pillars of the 2021 global tax plan stem from a multilateral tax policy process that rushed to issue rules without first resolving fundamental differences between countries or ensuring that the U.S., a key player, could implement them, says Jefferson VanderWolk at Squire Patton.
-
Key Considerations For Seeking Relief From Double Taxation
Caroline Setliffe and E. Miller Williams at Eversheds Sutherland lay out the Organization for International Cooperation and Development’s mutual agreement procedure for settling double-taxation disputes, and discuss six factors U.S. taxpayers doing business in multiple countries should consider when determining the most advantageous form of relief.
-
2 Tax Decisions Hold Key Transfer Pricing Takeaways
Richard Slowinski and Stefanie Kavanagh at Alston & Bird discuss two recent decisions in cases against the IRS — Eaton Corp. from the Sixth Circuit and Medtronic from the Tax Court — that may help clarify when the agency can cancel an advance pricing agreement, but leave unanswered questions about which pricing method applies to high-value intercompany licensing transactions.
-
Digital Taxation Is Necessary, But Tough To Manage
The U.S. government has started to tackle complex new tax laws as the digital economy continues to grow, but this demands guidelines that will facilitate the growth while protecting investors and the government's finances, say attorneys at Cadwalader.
-
Company Considerations For Cash Award Incentives: Part 2
Excerpt from Practical Guidance
Cash awards can help companies address some issues associated with equity awards to compensate employees, but due to potential downsides, they should be treated as a tool in a long-term incentive program rather than a panacea, say Denise Glagau and Kela Shang at Baker McKenzie.
-
Company Considerations For Cash Award Incentives: Part 1
Excerpt from Practical Guidance
Denise Glagau and Kela Shang at Baker McKenzie discuss what companies must consider when offering cash awards outside of U.S. jurisdictions, and explain how some challenges associated with equity awards may be addressed with cash awards.