International
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July 11, 2024
Biz Officials Call For Simpler Tax Rules In Light Of Pillar 2
Business representatives said Thursday that tax compliance rules need to be simplified as new minimum tax rules, known as Pillar Two, are added to the existing regime.
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July 11, 2024
Failure Of Pillar 1 Would Yield Worse Alternatives, Panel Says
A failure of the Pillar One agreement to reallocate corporate taxing rights would lead to alternatives that are worse, with the return of national digital services taxes worldwide, tax officials and academics said Thursday.
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July 10, 2024
Engineer Who Faced Export Charges Cops To Tax Counts
A Chinese-born engineer has pled guilty to two counts of filing a false tax return related to allegations that he and his wife omitted gross income from their tax returns between 2015 and 2019, after Texas federal prosecutors initially charged the couple with export violations and fraud.
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July 10, 2024
Portugal Enacts Pillar 2 As Part Of Economic, Tax Package
Portugal's Council of Ministers approved the minimum tax provision known as Pillar Two in a package of economic and tax measures designed to boost the country's economic growth, the council announced.
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July 10, 2024
OECD Publishes Pillar 2 Technical Reporting Language Draft
The Organization for Economic Cooperation and Development published a draft of technical details required to digitally input and disseminate information required for Pillar Two global minimum tax returns Wednesday.
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July 10, 2024
Americans Overseas Ask for Clarity In Foreign Trust Regs
An advocacy group representing U.S. citizens living abroad urged the U.S. Treasury Department to clarify proposed rules for reporting transactions with foreign trusts, contending that guidance should explain which common pension arrangements are exempt from disclosure obligations.
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July 10, 2024
Curtis Mallet-Prevost To Open Law Office In Saudi Arabia
Curtis Mallet-Prevost Colt & Mosle LLP has obtained a license to practice law in the Kingdom of Saudi Arabia, the firm announced this week.
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July 10, 2024
HMRC, CPS Beat Financier's Claim Over Botched Prosecution
HM Revenue and Customs and the Crown Prosecution Service have beaten claims of malicious prosecution and misfeasance in public office by a corporate financier following a failed criminal fraud case, with a judge finding that they had enough evidence to pursue him.
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July 10, 2024
French Left's Tax Pledges May Go Unfulfilled
The tax policy pledges put forward by the leftist bloc of parties that won the most seats in France's legislative election may not be fulfilled given the bloc's failure to win an outright majority.
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July 10, 2024
India's High Court Nixes Challenge To Taxing Of Tour Vehicles
The Indian Supreme Court dismissed a group of petitions challenging border taxes imposed by state governments on tour company vehicles because it said the litigation should have begun in a different court.
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July 10, 2024
Attempts To Scrap EU Tax Veto Are Useless, Hungary Says
Attempts by European Union countries to try to remove the requirement of unanimity for delicate policy decisions such as tax law and adding new EU member states are futile, Hungary's minister for European affairs said Wednesday.
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July 09, 2024
House Panel OKs Tax Breaks For More Education Expenses
The House Ways and Means Committee sent several education-related tax bills to the full House of Representatives on Tuesday, including legislation that would make additional elementary and secondary school expenses eligible for tax-advantaged education savings accounts.
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July 09, 2024
Irish Budget To Allocate €1.4B To Fund Tax Measures in 2025
The Irish government on Tuesday published the details of its €8.3 billion ($9 billion) budget for 2025, including €1.4 billion set aside to fund tax measures.
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July 09, 2024
India High Court Says Rights To Sell Liquor Aren't Taxed
The rights to sell the alcoholic beverage arrack are not taxed because the liquor vendors who purchase them do not fit into the definition of "buyer" under Indian tax law, the Supreme Court of India ruled.
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July 09, 2024
Finnish Tax Take Drops Amid Slowing Real Estate Market
The Finnish government's tax revenue declined 0.4% last year to €42.3 billion ($45.7 billion) as collections from levies on real estate purchases and car registrations each declined by more than 20%, the country's tax authority said Tuesday in a news release.
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July 09, 2024
EU, India Wary Of Overlap From UN's Global Tax Work
Indian and European Union officials agreed during a meeting that the negotiations around a framework convention on international tax cooperation at the United Nations shouldn't overlap efforts of the ongoing OECD-led global tax overhaul, an EU executive department said.
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July 09, 2024
UK's Non-Dom Taxpayer Count Increased 7%
A growing number of taxpayers in the United Kingdom claimed last year that their permanent home is outside the country, qualifying them for a non-domiciled tax exemption in the crosshairs of lawmakers, HM Revenue & Customs said Tuesday.
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July 09, 2024
5 Firms Steer $513M Ryan-Altus Cross-Border Tax Deal
Dallas-based tax services and software provider Ryan said Tuesday it has inked a deal to acquire the property tax business of Altus Group Ltd. for CA$700 million ($513.4 million), enlisting three firms to assist on a deal that will expand its footprint in Canada, the U.S. and the U.K.
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July 09, 2024
Maltese Case Tests EU Cooperation To Fight VAT Fraud
The case of a Maltese man arrested on suspicion of a key role in Sweden's largest value-added tax fraud illustrates how European countries are trying to boost their imperfect cooperation to combat such fraud, which causes billion-euro losses.
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July 09, 2024
Mishcon De Reya Adds Blick Rothenberg Partner
Mishcon de Reya has added a former director from Blick Rothenberg to its corporate tax team in London as a partner, the firm announced in a statement.
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July 09, 2024
Companies Deliberate Pillar 2 Prep After OECD Signals Relief
Multinational corporations facing the Pillar Two global minimum tax in various jurisdictions are weighing comments from OECD officials that hint at more relief as they decide whether to prepare to comply with the rules now or gamble on the prospects of permanent safe harbors.
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July 09, 2024
Left Group Likely To Chair EU Parliament's Tax Body
A member of the Left group in the European Parliament is expected to chair the body's tax subcommittee, a document seen by Law360 on Tuesday showed.
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July 09, 2024
EU Proposes Diplomatic VAT Exemptions Go Digital
The European Commission proposed that certificates for diplomatic exemptions from value-added taxes should switch from paper versions to an electronic form, a document said.
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July 09, 2024
Commission Asks For EU Pressure On French, Italian Deficits
The European Commission proposed that European Union finance ministers put pressure on France, Italy and five other EU countries to lower their budget deficits, leaving it up to the countries to decide the details of tax hikes and spending cuts, the commission announced Tuesday.
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July 08, 2024
Hong Kong Enacts Patent Box Tax Regime
The Hong Kong government began implementing a tax incentive known as a patent box for income derived from intellectual property in the jurisdiction, the Inland Revenue Department announced.
Expert Analysis
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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.
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The Nuts And Bolts Of IRS Domestic Content Tax Credit
Recent IRS guidance provides specifics on how renewable energy projects can qualify for bonus tax credits by meeting U.S. domestic content rules, but also creates a qualification framework that will be complicated for project developers to navigate, say Scott Cockerham and Wolfram Pohl at Orrick.
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Taxing The Digital Economy: The Good, The Bad And The Ugly
U.S. tech companies should watch for important developments in international taxation, including the resolution of Apple's decade-old state aid case, growing frustration with the Organization for Economic Cooperation and Development's global tax plan and adoption of the digital services tax instead, says Joyce Beebe at Rice University's Baker Institute for Public Policy.
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Big Tax Changes For Multinational Cos. In Budget Proposal
The Biden administration’s fiscal year 2024 budget proposes changes that would materially alter decades-old Internal Revenue Code provisions, requiring a shift in multinational corporations' tax planning strategies comparable to that required after enactment of the Tax Cuts and Jobs Act, say Xenia Garofalo and Kyle Colonna at Eversheds Sutherland.
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Senate Credit Suisse Report Puts Attention On Banks, Trusts
The Senate Finance Committee's recent finding that Credit Suisse violated a plea agreement struck over its role in enabling offshore tax evasion has important ramifications for banks and trusts, including how they onboard, document and report on transactions relevant to U.S. reporting requirements, say Will Barry and Ian Herbert at Miller & Chevalier.
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Seeking IRS Accountability For Faulty Microcaptive Notice
Like the taxpayers in Standard Insurances v. U.S. seeking to expand earlier wins in microcaptive insurance cases that limit IRS use of improperly obtained information, others should consider ways to hold the agency accountable and provide incentive for it to follow the law going forward, says Joshua Smeltzer at Gray Reed.
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Biden Admin. Proposals Both Encourage And Thwart EV Adoption
While the Biden administration has been aggressively focused on promoting electric vehicles from the start, its recently issued guidance on EV tax credits and its restrictive new auto emissions proposal create a sense of implementation whiplash that may frustrate manufacturers and consumers, says Levi McAllister at Morgan Lewis.
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The Key Issues Keeping Transfer Pricing A Top Tax Concern
Several challenges preventing a global economic reemergence from the pandemic era are making practitioners reevaluate commonly used transfer pricing models, and embrace new technologies and ways of doing business, say Farnaz Amini and Sophia Castro Jurado at Marcum.
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Curtailing Offshore Tax-Advantaged Investment In China
The U.S. government's plans to establish a new outbound investment regime hold the potential to arrest Chinese companies' increasing use of offshore, tax-advantaged locations to raise capital, says David Plotinsky at Morgan Lewis.
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Cos. May Want To Wait Out US-EU Green Incentives Fight
As the European Union considers measures to compete with the Inflation Reduction Act's incentives for U.S. production of clean tech, and EU and U.S. officials discuss a possible compromise, companies in the green sector should consider taking a wait-and-see approach to investment decisions, says Todd Thacker at Goldberg Segalla.
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India's Budget Proposals May Ease Entry For Certain Sectors
India’s recently released budget includes proposals to facilitate doing business in Gujarat International Finance Tec-City and moderate thousands of compliance requirements, opening up new opportunities for foreign businesses in the digital infrastructure, manufacturing and renewable energy sectors, say Mukesh Butani and Seema Kejriwal at BMR Legal.