International
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May 30, 2024
Ex-KPMG Manager Joins Davis+Gilbert As Tax Partner
A former managing director at KPMG has joined New York law firm Davis+Gilbert LLP as a tax partner in its corporate and transactions practice, Davis+Gilbert announced.
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May 30, 2024
Tax Pros Agree With HMRC's Mandatory Agent Reporting Plan
Two groups representing tax professionals in the U.K. have agreed with a proposed rule requiring practitioners to register with HM Revenue & Customs while also supporting a secondary rule that would require membership with a professional body.
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May 30, 2024
Russian Gas Ex-CFO Says $44M FBAR Penalty Is Excessive
The former chief financial officer of a Russian gas company who was sentenced to seven years in prison for hiding money in Swiss banks told a Florida federal court that the $44 million in foreign account reporting penalties the government is seeking is illegally high.
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May 30, 2024
Panama Papers Leak Led To $283M In Swedish Tax Revenue
The Swedish Tax Agency said Thursday it has corrected the tax assessments of roughly 100 people and companies connected to the so-called Panama Papers leak, capturing roughly 3 billion Swedish kronor ($283 million) in added tax revenue.
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May 30, 2024
Legal Advice On Corp. Setups Protected, ECJ Adviser Says
A law firm's legal advice, even that concerning the setting up of a corporate investment structure, is within the scope of legal professional privilege guaranteed by European Union law, an adviser to the EU's highest court said Thursday.
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May 30, 2024
EU's Top Court Rules Spanish Regional Energy Taxes Illegal
European Union energy tax law forbids Spanish regions to set their own rates for excise duty on energy, the EU's top court said Thursday, finding that possible exemptions did not apply in the Spanish case.
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May 30, 2024
Freeze On UK Tax Thresholds Set To Expire in 2028, Hunt Says
Chancellor Jeremy Hunt said on Thursday that the freeze on income tax thresholds will continue until 2028, despite promises by the Conservative government to reduce the overall taxation burden in the future.
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May 30, 2024
Italian Rules On Internet Companies Unlawful, ECJ Finds
Amazon, Google, Airbnb and other internet companies have won their fight against a law requiring them to provide Italian authorities with information about their operations as the European Union's highest court ruled Thursday that the obligation breaches of the bloc's rules.
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May 29, 2024
Irish Court Denies $19.2M Tax Payment To Australia
The Australian Taxation Office lost a bid to have a now-liquidated Australian investment company repay a AU$29 million ($19.2 million) tax debt after an Irish court determined the payment should instead go to a lender.
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May 29, 2024
Colombian Court Affirms Fossil Fuel Tax Break Must Stay
The Constitutional Court of Colombia affirmed its decision to strike down a law denying fossil fuel companies the ability to offset corporate income tax liabilities with deductions for royalty payments despite a severe impact to public finances, the country's president said.
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May 29, 2024
Baker McKenzie Grows Tax Practice With Ex-KPMG Adviser
Baker McKenzie announced the hiring of an experienced Chicago-based tax adviser as a principal who most recently spent sixteen and a half years at Big Four accounting firm KPMG.
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May 29, 2024
Belgium Opens Pillar 2 Mandatory Reporting Form
Belgium's finance ministry opened Wednesday its mandatory notification system for entities in scope of its implementation of the Organization for Economic Cooperation and Development's global corporate minimum tax known as Pillar Two, starting a 45-day clock for such companies to register.
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May 29, 2024
Next UK Gov't Should Invest In Tax System, Pros Say
Improving the administration of the U.K. tax system should be a focus of the country's next government if it hopes to improve economic growth, a group representing tax professionals said, laying out issues that need to be addressed.
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May 29, 2024
IMF Report Suggests Germany Should Increase Taxes
Germany could consider increasing taxes to help pay for needed expenditures, an International Monetary Fund report said, adding that this would be a necessary complement to a more generous fiscal policy.
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May 29, 2024
Three EU Countries Urge Tax Reform To Boost Investment
Three smaller European Union countries, Austria, Croatia and Slovenia, are backing tax reforms in the 27-country bloc to support investment in capital markets, including exemptions from capital gains tax for long-term retail investment products, according to a joint declaration.
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May 28, 2024
Lithuania Seeks CJEU Ruling On Gaming Co.'s $1.1M Tax Bill
Lithuanian tax authorities have asked the Court of Justice of the European Union whether the past economic justification for a video game company's structure allows it to avoid €1 million ($1.1 million) in tax payments, according to court documents.
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May 28, 2024
Mich. Doctor Denied Release From Contempt In FBAR Fight
A Michigan doctor will stay jailed for civil contempt after a federal judge found Tuesday that he failed to back up claims that he cannot pay his more than $1 million in foreign bank account reporting penalties due to a bank's bankruptcy and his criminal history.
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May 28, 2024
Global Tax Body Provides Crypto Risk Assessment Red Flags
The Internal Revenue Service and four international tax authorities issued an advisory to financial institutions on the dangers of cryptocurrency in relation to tax evasion, money laundering and other illicit activities, identifying certain risk factors worth their attention.
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May 28, 2024
Tax Lawyer Rejoins Mayer Brown In DC From Latham
Mayer Brown LLP has rehired a tax partner from Latham & Watkins LLP, who joins the firm in Washington, D.C., to continue working with clients to best utilize renewable energy tax credits, the firm announced Tuesday.
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May 28, 2024
OECD Issues Voluntary Disclosure Program Guidance
The Organization for Economic Cooperation and Development issued guidance for tax administrations that are considering implementing voluntary disclosure programs before adopting the group's automatic information exchange standards.
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May 28, 2024
Moldova Joins OECD Fight Against Tax Avoidance
Moldova has joined the more than 140 jurisdictions looking to rein in tax base erosion and has committed to instituting changes in line with the Organization for Economic Cooperation and Development's anti-tax avoidance standards, the organization said in a news release Tuesday.
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May 28, 2024
9th Circ. Won't Touch IRS Bid For Tax Liability On Bookie
A bookie who pled guilty to helping run an illegal sports gambling ring out of Peru can't escape his ensuing $100,000 tax liability under a Ninth Circuit ruling that declined to expunge his conviction after he argued the taxes are disproportionately punishing.
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May 28, 2024
EU Needs Boost From New Incomes, Say Macron, Scholz
France and Germany want the European Union to find new revenue sources for the common EU budget, possibly from new taxes, to finance investments in joint projects, leaders of both countries said Tuesday.
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May 28, 2024
Greenberg Traurig Adds Tax Pro From MoFo In London
Greenberg Traurig LLP added to its deep bench of legal talent by recruiting a tax partner from Morrison & Foerster to join the firm's London office and co-chair its tax practice, the firm said.
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May 28, 2024
Labour Party Rules Out Any Additional Tax Rises
The Labour Party on Tuesday ruled out introducing any more tax rises in addition to measures it has already announced in the event it wins the July 4 general election.
Expert Analysis
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The Highs And Lows Of Tax Controversy In 2021
Lawrence Hill at Steptoe & Johnson reviews the ups and downs of tax controversy practice in 2021, including the continued effects of the pandemic, troubling decisions on attorney-client privilege and an IRS comeback on transfer pricing.
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Lessons From IRS For A New HMRC Whistleblowing Model
Andrew Park at Andersen considers whether the public interest would be better served in allowing the U.K.'s tax enforcers, HM Revenue & Customs, to offer larger and more certain cash incentives to people blowing the whistle on tax misdemeanors — similar to the IRS model for whistleblowers.
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The Benefits Of Competent Authority In Int'l Tax Disputes
Multinational enterprises seeking relief from double taxation in a changing international tax landscape should consider utilizing the competent authority process, which provides both taxpayers and domestic tax regulators an efficient and effective means of dispute resolution, say David Farhat and Eman Cuyler at Skadden.
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How OECD Transfer Tax Initiative Affects Smaller Businesses
Small and midsize enterprises with cross-border transactions need to consider redefining tax strategies and operational models in light of the Organization for Economic Cooperation and Development's base erosion and profit shifting initiative, even though the agency's new tax guidelines are aimed at large multinational enterprises, says Ganesh Ramaswamy at Kreston Rangamani.
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What The New OECD Double-Tax Procedure Statistics Tell Us
Monique van Herksen and Clive Jie-A-Joen at Simmons & Simmons consider the Organization for Economic Cooperation and Development’s recent report on double taxation cases resolved in 2020 under the mutual agreement procedure process, and examine whether the process has improved dispute resolution mechanisms since its implementation five years ago.
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Navigating FCPA Risks Of Minority-Owned Joint Ventures
The U.S. Department of Justice and U.S. Securities and Exchange Commission will likely continue to focus on third-party risks under the Foreign Corrupt Practices Act, so companies with minority-owned joint ventures should take several steps to mitigate related compliance challenges, say Ben Kimberley at The Clorox Company and Addison Thompson at Covington.
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Questions To Ask If Doing Business In A Corruption Hot Spot
Businesses facing new scrutiny after the U.S. Department of Justice's recently announced task force for combating human trafficking in Central America, the release of the Pandora Papers and continuing fallout from 2019's Panama Papers, should address compliance risks by having employees ask three questions about every transaction, say attorneys at White & Case.
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How The Global Tax Agreement Could Backfire For Biden
If the $3.5 trillion spending package fails, the federal tax code will not conform to the recent 15% global minimum tax agreement spearheaded by the U.S., which would embarrass the Biden administration and could lead to retaliatory tax measures by other nations, says Alex Parker at Capitol Counsel.
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Pandora Papers Reveal Need For Greater Tax Enforcement
The recent Pandora Papers leak is a reminder of the importance of transparency laws and proper funding for enforcement efforts against tax evasion as bad actors increasingly operate in the shadows, says Daren Firestone and Kevin Crenny at Levy Firestone.
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Parsing New Int'l Tax Reporting Rules For Pass-Throughs
Attorneys at Grant Thornton unpack the Internal Revenue Service’s new pass-through entity reporting requirements for international tax matters and the accompanying guidance for penalty relief, and suggest how companies should prepare for what may be the most significant change to the partnership compliance function in decades.
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A Look At Global Tax Enforcement Developments: Part 2
Excerpt from Practical Guidance
Sean Craig at LexisNexis examines recent investigations by the Joint Chiefs of Global Tax Enforcement and their impact on U.S. taxpayers, as well as the growing significance of transfer pricing disputes and policies for future enforcement.
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A Look At Global Tax Enforcement Developments: Part 1
Excerpt from Practical Guidance
Sean Craig at LexisNexis looks at how international initiatives, such as the Joint Chiefs of Global Tax Enforcement, are addressing cryptocurrency-related tax evasion, and how the COVID-19 pandemic and increasing demands for governmental welfare programs are driving global tax policy.
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EU Climate Plan Should Involve Taxing Pollution, Not Borders
In order to crack down on greenhouse gas emissions, the European Union proposes to levy carbon emissions at its borders and to overhaul its long-standing energy tax framework, but the latter would hold polluters directly accountable, giving it the better chance for success, says Rebecca Christie at Bruegel.