International
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May 03, 2024
US Trade Position Seen Contradicting Stance In Pillar 1 Talks
The U.S. trade representative's withdrawal of support for digital trade proposals has caused tax policy observers to worry that the U.S. position on trade is undermining that of U.S. Treasury Department officials negotiating a taxing rights overhaul at the OECD known as Pillar One.
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May 03, 2024
Finland's Stance On Swiss Treaty Recalls Ended Portugal Deal
Finland's plan to renegotiate its tax treaty with Switzerland in response to concerns about pension tax avoidance has some observers worried that the country will cancel that accord as it did a treaty with Portugal in recent years.
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May 03, 2024
Taxation With Representation: Skadden, Wachtell, Davis Polk
In this week's Taxation With Representation, L'Occitane International said its executive director and chair is leading an offer to buy the company's shares he doesn't already own, UMB Financial agreed to purchase Heartland Financial USA, Medline said it agreed to acquire Ecolab's global surgical solutions business and The Mosaic Co. said it agreed to sell its stake in a phosphate production joint venture.
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May 03, 2024
IRS Can Assess Foreign Info Disclosure Penalty, DC Circ. Says
The D.C. Circuit on Friday overturned a major U.S. Tax Court ruling that had struck down the Internal Revenue Service's authority to assess and administratively collect penalties from taxpayers for failing to file an information return on their interests in a foreign corporation.
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May 03, 2024
Final EV Tax Credit Regs Add New Battery Tracing Test
The U.S. Treasury Department unveiled final regulations Friday for the up to $7,500 electric vehicle tax credit that include a more detailed process for automakers to trace the battery supply chain to qualify for the credit's domestic content requirements.
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May 03, 2024
German's Austrian Ski Holiday Ends With Arrest In VAT Probe
A German citizen on a skiing holiday in Austria was arrested over a large-scale value-added tax fraud scheme, the Finance Ministry in Vienna said in a statement on Friday.
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May 02, 2024
Claimed Panama Papers Leaker Fights To Hide ID In €5M Suit
A person claiming to be the Panama Papers leaker told a federal court they would fear for their life if the court made them disclose their identity in a €5 million ($6.3 million) suit against Germany, protesting a magistrate judge's suggestion that the suit be tossed because the person wouldn't identify themselves.
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May 02, 2024
IRS To Boost Audit Rates By 50% On Wealthy, Werfel Says
The Internal Revenue Service plans to nearly triple audit rates on corporations with assets over $250 million and increase audit rates by more than 50% on wealthy taxpayers with more than $10 million in total positive income by 2026, Commissioner Daniel Werfel said Thursday.
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May 02, 2024
Latest Stock Buyback Tax Rules May Still Have Wide Reach
The U.S. Treasury Department recently floated regulations that narrow an earlier proposal aimed at preventing foreign-parented corporations from circumventing a new excise tax on stock buybacks, but the regulations still characterize avoidance in ways that could include routine intercompany transactions.
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May 02, 2024
HMRC Asked To Investigate Firm On Dodging Sanctions
HM Revenue & Customs should investigate a German-owned garage door manufacturer for violating sanctions by importing products from Belarus into the U.K., but instead authorities brushed off the case and now the company might receive a license, a U.K. lawmaker said.
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May 02, 2024
Canada Budget Seeks To Establish Corp. Min. Tax Standards
Budget proposals submitted to Canada's Parliament by the finance minister would implement the Organization for Economic Cooperation and Development's global corporate minimum tax standards as part of the country's overarching budget plans.
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May 02, 2024
OECD-Asia Group Helping Reform Agenda, OECD Head Says
A group that brings together countries from the mostly Western Organization for Economic Cooperation and Development and Southeast Asia to discuss issues, including tax, is helping countries make changes, the head of the OECD said Thursday.
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May 02, 2024
Airlines Slam Increase In German Air Passenger Tax
The increase in Germany's air passenger tax on May 1 will weaken the country's economy and damage the aviation industry's ability to cut down on its carbon use, an airline group said on Thursday.
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May 01, 2024
No Relief For Fla. Adviser Convicted In $80M Trading Scam
The Eleventh Circuit on Wednesday affirmed the conviction of a Florida investment adviser who bilked more than $80 million from the hundreds of people he persuaded to invest in a fraudulent company, after concluding he was not in custody when he made statements to the police.
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May 01, 2024
Middle East, North African Gov'ts Back UN For Corp. Tax Talks
Governments should make a high-level commitment to address corporate tax reform within the United Nations' framework convention on international tax cooperation, an intergovernmental group of Middle Eastern and North African countries said Wednesday.
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May 01, 2024
Think Tank Says 'Distortive' DSTs Not The Right Way Forward
As jurisdictions around the world continue to struggle with how to adequately tax the increasingly digital economy, they should look to expand their consumption taxes, not enact digital services taxes, the Tax Foundation said.
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May 01, 2024
Liberty Global Defends $109M Tax Refund Bid In 10th Circ.
Telecommunications giant Liberty Global urged the Tenth Circuit to revive the company's $109 million tax refund bid, arguing a lower court rejected the claim by wrongly disregarding intercompany transactions that are permitted under legislation involving the repatriation of foreign profits.
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May 01, 2024
UN Must Improve Corp. Tax Rules, Platforms, Some Gov'ts Say
Governments must commit to improving existing corporate tax rules and platforms created at the OECD within the terms of reference for a United Nations framework convention on global tax cooperation, two tax officials who participated in drafting those rules said Wednesday.
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May 01, 2024
HMRC Simplifies Late Filing Penalties For Digital Filers
U.K. taxpayers voluntarily filing their personal income tax returns using a program intended to modernize the country's tax system will receive more leniency and access to a simpler penalty structure in cases of late filing, HM Revenue & Customs said.
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May 01, 2024
Hong Kong Proposes Amended Automatic Info Exchange List
Hong Kong is considering adjusting the list of countries it automatically exchanges financial information with by subtracting nine jurisdictions and adding 11, which the country's tax authority said is in line with recommendations from the Organization for Economic Cooperation and Development.
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May 01, 2024
Swiss Sends Amendment To Serbian Tax Treaty To Parliament
Switzerland's executive body, the Federal Council, sent to the country's parliament Wednesday an amendment for the country's double-taxation treaty with Serbia that would bring it in line with the OECD's base erosion and profit shifting standards, the council said.
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April 30, 2024
India, Belgium, Others Support UN Taking On Wealth Taxation
Governments should make a high-level commitment to reach agreement on the taxation of wealthy individuals within the United Nations framework convention on international tax cooperation, representatives of India, Belgium, Austria, Nigeria and Kenya said Tuesday.
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April 30, 2024
Yellen Says US Pushing To Protect R&D Credit Under Pillar 2
U.S. Treasury Department negotiators are continuing to advocate for more favorable treatment of the country's research and development tax credit under the Pillar Two global minimum tax rules, Treasury Secretary Janet Yellen told the House Ways and Means Committee on Tuesday.
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April 30, 2024
German Banker Gets 3 Years For €93M Cum-Ex Tax Evasion
A German court on Tuesday sentenced a former bank board member to three years and two months in prison for his part in a €93.4 million ($100 million) so-called cum-ex dividend tax fraud.
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April 30, 2024
HMRC Proposes Special Economic Zone Tax Relief Extensions
HM Revenue & Customs proposed Tuesday to extend the time to claim tax relief measures available in special economic zones in the U.K. to 2031 in England and to 2034 in other parts of the country.
Expert Analysis
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BigLaw Needs More Underrepresented Attorneys As Leaders
Hiring more women, people of color and members of the LGBTQ community to BigLaw positions of power is the first key to making other underrepresented attorneys believe they have an opportunity for a path to leadership, says Ernest Greer, co-president at Greenberg Traurig.
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Advancing Racial Justice In The Legal Industry And Beyond
In addition to building and nurturing a diverse talent pipeline, law firms should collaborate with general counsel, academics and others to focus on injustices within the broader legal system, says Jonathan Harmon, chairman at McGuireWoods.
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Diversity Work Doesn't Have To Be Reserved For Partners
Serving on my firm's diversity committee as an associate has allowed me to improve access, support and opportunity for minority attorneys at the firm, while building leadership skills and fostering meaningful relationships with firm management and industry professionals, says Camille Bent at BakerHostetler.
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Foreign Income Regs Provide Some Clarity But Issues Remain
The U.S. Department of the Treasury recently released final regulations on global intangible low-taxed income and foreign-derived intangible income that largely addressed the numerous technical issues plaguing these sections but left the high GILTI rate and other substantive problems unresolved, says Robert Kiggins at Culhane Meadows.
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New Unified High-Tax Election Brings Planning Challenges
The U.S. Department of the Treasury's recently released high-tax election regulations for global intangible low-taxed income create unwanted planning challenges by conforming to the stricter Internal Revenue Code Subpart F high-tax exclusion, rather than aligning with the GILTI election rules as many hoped, say attorneys at Mayer Brown.
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EU's Tax-Centered State Aid Campaign May Have Peaked
The European Commission's recent tax-related state aid investigations of the likes of Apple, McDonald's and Nike may have reached their limit as changes in international tax rules, the rapid growth of digital companies and COVID-19 reprioritize the commission's anti-competitive initiatives to broader issues focused on tech giants, says Joyce Beebe at Rice University.
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Get Ready For IRS Repatriation Enforcement
Beginning this fall, taxpayers should expect to see IRS enforcement efforts with respect to their repatriation tax liabilities, including audits that will likely focus on taxpayers' earnings and profits calculations, classification of assets as cash versus noncash, and how taxpayers determined foreign tax credits, say David Fischer and Teresa Abney at Crowell & Moring.
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Canadian Tax Ruling Boosts Cross-Border Deal Confidence
The Queen v. Cameco Corp., a recent Canadian appellate decision and the first case to test Canada's transfer pricing recharacterization rules, has significant implications for cross-border intragroup transactions and the intersection of Canadian tax law with the Organization for Economic Cooperation and Development’s guidance, says Matt Billings at Duff & Phelps.
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HSBC Suit Shows Challenge Of Designing Tax Relief Laws
Investors' recent lawsuit against HSBC over film-related tax avoidance schemes spotlights the difficult balancing act of crafting practical tax relief legislation while safeguarding against abuse, says Andrew Parkes at Andersen Tax.
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Regulatory Concerns For US Cos.' Offshore Service Centers
As more U.S. companies open and use offshore service-delivery centers amid the pandemic, assessment of important tax, intellectual property, cybersecurity and employment considerations can help mitigate regulatory risk and maximize the company's return on investment, says Sonia Baldia at Baker McKenzie.
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5 Biz Tax Reforms To Aid Long-Term Pandemic Recovery
As Congress negotiates another COVID-19 relief package, it should consider business tax measures that provide liquidity and encourage economic recovery by focusing budgetary resources on activities and circumstances connected to the pandemic and associated economic slowdown, says George Callas at Steptoe & Johnson.
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Altera Could Bolster State Transfer Pricing Scrutiny
The reasoning of the Ninth Circuit's Altera v. Commissioner decision — which the U.S. Supreme Court recently declined to review — could provide state tax authorities with an argument for additional discretion when challenging transfer pricing arrangements between affiliated entities, say attorneys at Eversheds Sutherland.
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10 Tips For A Successful Remote Arbitration Hearing
As I learned after completing a recent international arbitration remotely, with advance planning a video hearing can replicate the in-person experience surprisingly well, and may actually be superior in certain respects, says Kate Shih at Quinn Emanuel.