International
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June 18, 2024
Hungary Aims To Fight Evasion, Foster Certainty As EU Chair
Hungary, the incoming chair of the European Union council of member states, said Tuesday that it will prioritize fighting tax evasion and ensuring legal certainty for taxpayers during its time in the role.
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June 17, 2024
$2.1B Danish Tax Fraud Defendant Pushes For Separate Trials
An attorney facing trial alongside his clients on allegations of filing $2.1 billion in fraudulent tax refund claims in Denmark urged a New York federal court to hear his case separately, saying disparate legal arguments could confuse a jury if only one trial is held.
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June 17, 2024
OECD Tax Plan Is Developing Nations' Best Choice, Prof Says
Developing countries could gain more revenue from the OECD's multilateral plan to tax the digital economy than the U.N. Tax Committee's bilateral alternative because they have small treaty networks, many customers and few large companies, an academic argued Monday during an Oxford University panel.
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June 17, 2024
Saudi Arabia Should Boost Non-Oil Tax Revenue, IMF Says
Saudi Arabia has had an "unprecedented economic transformation" in recent years, but maintaining such growth will require further tax efforts, particularly when it comes to non-oil revenue generation, the International Monetary Fund said.
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June 17, 2024
OECD Clarifies Rules For Global Minimum Tax
The OECD-led international negotiating body working on fundamental changes to corporate tax law clarified rules under the global minimum tax on deferred tax and securitization, the organization said Monday.
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June 17, 2024
EU Approves Italian Fee Cut For Boats Using Cleaner Energy
The European Commission approved an Italian plan Monday which, by waiving a fee, incentivizes boats to use a cleaner way of obtaining electricity.
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June 14, 2024
US Urges 5th Circ. To Back $2M Tax Bill For Tire Imports
The Fifth Circuit should overturn a lower court's ruling that a Houston truck company was not an importer responsible for nearly $2 million in excise taxes on tires it bought from a Chinese manufacturer, the U.S. told the Fifth Circuit on Friday.
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June 14, 2024
Eaton Says Court Improperly Required Int'l Employee Evals
An Ohio federal court should reconsider its decision that multinational power management company Eaton must disclose the personnel records of its foreign employees that were requested by the Internal Revenue Service in a transfer pricing investigation, the company told the court.
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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.
Expert Analysis
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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.
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OECD Delays Are Imperiling Digital Tax Deal
As the Organization for Economic Cooperation and Development continues to push back its deadline for a digital tax overhaul, countries are beginning to pursue unilateral solutions and the negotiations are turning political, decreasing the likelihood of an agreement, says Joyce Beebe at Rice University.
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Mitigating IRS Cryptocurrency Enforcement Risk In 2021
The IRS seems poised to shift focus in 2021 from education to enforcement of virtual currency tax laws, and noncompliant taxpayers should consider whether they are eligible to file amended returns or voluntary disclosures to mitigate the risk of civil penalties, criminal investigation or prosecution, say Don Fort and Lawrence Sannicandro at Kostelanetz & Fink.
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2020's Key Tax Controversy Developments
Andrew Roberson and Kevin Spencer at McDermott highlight 2020's key tax controversy developments, offering their perspective on important tax decisions, the Internal Revenue Service’s cooperative audit program, informal tax return amendment procedures, Large Business & International Division campaigns, and handling virtual appeals conferences during the pandemic.
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Justices Likely To Shield Treasury From Preemptive Action
Recent U.S. Supreme Court oral arguments in CIC Services v. Internal Revenue Service suggest the court will resolve a circuit split by ruling the Anti-Injunction Act shields the U.S. Department of the Treasury from preemptive challenges — bad news for those hoping to challenge unfavorable regulations, says Monte Silver at Silver & Co.
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Response Options For Danish Cum-Ex Interview Targets
As the Danish tax authority prepares for the first of a three-part U.K. trial involving cum-ex fraud, U.K. recipients of interview requests from the Danish prosecutorial agency should neither automatically accept, nor ignore the invitations, despite that agency's seeming lack of power to compel their attendance, says David Corker at Corker Binning.
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Advancing The Democratic Tax Agenda In 2021
Even with a divided government starting next year, Democrats will have a major effect on tax policy, pursuing legislative compromises and regulatory changes in service of President-elect Joe Biden's tax plan, and potentially reversing many Trump administration initiatives, say Russell Sullivan and Radha Mohan at Brownstein Hyatt.
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M&A Poised For Growth In The Biden Era
The M&A market is well positioned for recovery and growth under a Biden administration and divided Congress, which will likely gain control over the coronavirus pandemic, pass a stimulus package, and provide greater transparency in antitrust enforcement, say attorneys at Debevoise.
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Final BEAT Regs Still Contain Pitfalls For Taxpayers
Recently finalized U.S. Department of the Treasury regulations retain a taxpayer-friendly election allowing corporations to waive deductions to avoid the base erosion and anti-abuse tax, but neglect to include recourse for companies that waive more deductions than necessary, say attorneys at Ropes & Gray.
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Post-Election Tax Policy Scenario 3: A Divided Government
Attorneys at Brownstein Hyatt consider whether Democrats and Republicans will find common ground on tax policies and legislation regarding COVID-19 relief, domestic research and manufacturing, pension and retirement savings, foreign taxation of U.S. companies, and infrastructure development if the upcoming election results in a divided government.
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Post-Election Tax Policy Scenario 2: A Democratic Sweep
Russell Sullivan and Radha Mohan at Brownstein Hyatt consider former Vice President Joe Biden’s perspective that a better economy addresses income inequality, and the likelihood of passing specific tax measures in the event of a Democratic sweep, despite varying party perspectives.