International
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June 10, 2024
Canadian Gov't Proposes Capital Gains Tax Hike
A new tax rate on capital gains realized annually above CA$250,000 ($181,700) by individuals and on all capital gains realized by Canadian corporations would go into effect this month under a proposal introduced by Canada's finance minister Monday.
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June 10, 2024
Big Tech Urges US Reprisal Over Canada's Impending DST
The Office of the U.S. Trade Representative should open formal dispute proceedings with the Canadian government in response to a 3% digital services tax that is expected to soon pass in the Canadian Senate, business groups with members in the U.S. tech industry said Monday.
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June 10, 2024
UN Aims To Finish Drafting Tax Convention By Fall 2026
The United Nations should aim to finish a framework convention on international tax cooperation and early protocols that address taxation of the digital economy, cross-border services and high-net-worth individuals by September 2026, according to draft terms of reference open for comment through June 21.
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June 10, 2024
3rd Prime Suspect Arrested In €50M Italian VAT Fraud Ring
The Italian Financial Police arrested a third person suspected of leading a value-added tax fraud scheme involving sales of over 3 million Apple AirPods that caused an estimated €50 million ($54 million) in losses, the European Public Prosecutor's Office said Monday.
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June 10, 2024
Authorities Arrest Danish Suspect In €85M VAT Fraud In Kenya
A Dane suspected of leading an €85 million ($91 million) value-added tax fraud ring was apprehended in Kenya after having fled Denmark late last year, the European Public Prosecutor's Office said Monday.
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June 10, 2024
Latvia Parliament Passes Parts Of Minimum Tax Directive
Under pressure from the European Union, Latvia's Parliament approved a bill transposing portions of the bloc's directive to implement the Organization for Economic Cooperation and Development's Pillar Two standards to prevent tax base erosion and profit shifting.
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June 10, 2024
Singapore Seeks Opinions On OECD's Minimum Tax Plan
Singapore is seeking public feedback on a proposal that would introduce the Organization for Economic Cooperation and Development's corporate global minimum tax, the country's Ministry of Finance said Monday.
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June 10, 2024
EU Commission Invites Experts To Anti-Tax-Evasion Forum
The European Union's executive arm issued a call Monday for nongovernmental organizations to apply to join a platform that discusses measures against tax evasion and avoidance outside the bloc.
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June 10, 2024
EU Countries To Aim Again For VAT Deal, Agenda Says
European Union countries will again discuss proposed changes to the bloc's value-added tax laws at a meeting next week, aiming to find a deal after one country blocked agreement, according to a meeting agenda.
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June 10, 2024
Lib Dems Vow To Raise Capital Gains Tax For UK's Wealthiest
The U.K.'s third-largest political party vowed on Monday to raise taxes on the country's wealthiest individuals if it wins the next election, in a bid to raise £5 billion ($6.4 billion) for the National Health Service.
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June 10, 2024
What Tax Experts Hope To See In Labour's Manifesto
Labour's policy manifesto, expected to be unveiled on Thursday, will be studied by tax lawyers for more detail on the fiscal planning being carried out by the clear favorite to win the general election, including a final word on lifetime pension savings.
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June 07, 2024
IRS Updates EV Battery Reporting Guide For Tax Credits
The Internal Revenue Service provided updated guidance Friday for automakers planning to provide a report on meeting the battery sourcing requirements that can qualify their new electric vehicle models for the consumer tax credit of up to $7,500.
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June 07, 2024
NZ Sets Foreign Investment Interest Deemed Rate Of Return
New Zealand has set the deemed rate of return for attributing interest on foreign investment funds — one of the ways to calculate income from such sources for tax purposes — at 8.63% for the 2023-24 income year, the country's revenue agency said.
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June 07, 2024
Dentons Adds Pair Of Husch Blackwell Tax Attys
Two South Carolina tax attorneys have joined Dentons' corporate, tax and private client practice as partners after moving from Husch Blackwell LLP, the firm announced on Thursday.
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June 07, 2024
Halliburton Wrongly Denied $11.3M Deduction, Court Told
The Internal Revenue Service is arbitrarily and wrongfully refusing to refund Halliburton over $11.3 million in tax deductions taken for a payment to a foreign government to secure the safety of the company's employees, Halliburton told a federal court.
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June 07, 2024
Chile Says Filing Restriction Program Stopped $203M In Fraud
Chile's tax agency said Friday that its strategy for blocking value-added tax fraud via fraudulent invoices prevented the disbursement of 186 billion Chilean pesos ($203 million) of incorrect value-added tax credits since the start of 2023 through April 2024.
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June 07, 2024
Taxation With Representation: Vinson, Latham, Ropes & Gray
In this Week's Taxation with Representation, Waste Management buys Stericycle, Becton Dickinson pays $4.2 billion for Edwards Lifesciences' critical care products unit, Aquiline Capital Partners raises over $3.4 billion in fund capital, and Bain Capital buys PowerSchool Holdings.
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June 07, 2024
Swiss Launch Consultation On Data Exchange Law
The Swiss government said Friday that it has begun a consultation on a law concerning the international exchange of salary data, which it says is needed to support laws pertaining to the taxation of cross-border workers.
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June 07, 2024
Tax Discriminates Against Risky Assets, Dutch Court Says
The Netherlands must compensate investors for a tax on investment income that discriminates against riskier assets by using calculations of fictitious returns, the Dutch Supreme Court said.
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June 06, 2024
Medtronic Urges 8th Circ. To Back Its Transfer Pricing Method
Medical device maker Medtronic reiterated Thursday its bid for the Eighth Circuit to revive its method for pricing intangible property that was licensed to a Puerto Rican affiliate, arguing the government's concessions show why the company's approach is more reliable.
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June 06, 2024
Oil Cos. Stifle Bids For Tax Transparency, SEC Letters Show
At least three oil companies have stifled proposals initiated by the nonprofit Oxfam America for public country-by-country reporting of business activities, profits and taxes this year, according to letters from the U.S. Securities and Exchange Commission obtained by Law360.
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June 06, 2024
Australia Seeking Feedback On Tax Returns For Biggest Cos.
The Australian Taxation Office said it is reaching out to advisory firms and other groups about plans to introduce a supplementary goods-and-services tax form for the country's biggest companies.
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June 06, 2024
Fox Rothschild Brings On Tax Pro From Atlanta Boutique
Fox Rothschild LLP has added an attorney in Atlanta from tax law boutique Wiggam Law to strengthen the firm's taxation and wealth planning department.
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June 06, 2024
EU Must Improve Country-By-Country Reporting, Group Says
While there has been an uptick in voluntary country-by-country public disclosures, the large multinational corporations that do so make up just 2% of all large companies and account for less than 5% of global revenue and profits, necessitating further improvements, an EU-funded research group said Thursday.
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June 06, 2024
Co. Did Not Abuse UK-Ireland Tax Agreement, Tribunal Affirms
The fact that an Ireland-based company benefited from the U.K.-Ireland double-taxation agreement when it acquired an £83.5 million ($106.8 million) investment doesn't mean it entered the transaction only for tax benefits, the U.K.'s Upper Tribunal said, affirming a lower court.
Expert Analysis
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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.
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Post-Election Tax Policy Scenario 1: A Republican Sweep
Attorneys at Brownstein Hyatt analyze tax policies implemented by the Trump administration, such as the Tax Cuts and Jobs Act, and consider what will be on the agenda if Republicans gain full control of both the legislative and executive branches in the election.
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Defensive Strategies For High-Net-Worth Individual Tax Audits
When representing high-net-worth individuals in a tax audit, defensive strategies that cooperate with the examiner and respond to government requests should reflect the overarching goal of preserving client objections, privileges, limitations periods and any other rights in case there is future litigation, says Patrick McCann at Chamberlain Hrdlicka.
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Canadian Tax Ruling Signals Cross-Border Structure Security
After the Tax Court of Canada's recent ruling in AgraCity v. The Queen that the company's arm's-length tax arrangements with a foreign subsidiary were legitimate, and a similar result in a different matter, Canadian taxpayers can have confidence that their cross-border related party transaction structures will be upheld, says Matt Billings at Duff & Phelps.
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Preparing The Next Generation Of Female Trial Lawyers
To build the ranks of female trial attorneys, law firms must integrate them into every aspect of a case — from witness preparation to courtroom arguments — instead of relegating them to small roles, says Kalpana Srinivasan, co-managing partner at Susman Godfrey.
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Mentorship Is Key To Fixing Drop-Off Of Women In Law
It falls to senior male attorneys to recognize the crisis female attorneys face as the pandemic amplifies an already unequal system and to offer their knowledge, experience and counsel to build a better future for women in law, says James Meadows at Culhane Meadows.