International
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June 21, 2024
US Formally Suspends Part Of Tax Treaty With Russia
The U.S. government has provided formal notice to Russia suspending, via mutual agreement, parts of the countries' double-taxation treaty.
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June 21, 2024
Big 4 Continue Push For Broader Irish Dividend Exemption
The Big Four accounting firms reiterated support for Ireland's plans to implement a corporate tax exemption for foreign-sourced dividends and foreign branch profits, but they found the latest proposal still too narrow and complicated to qualify for, according to comments released Friday.
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June 21, 2024
Norway Seeking Feedback On Undertaxed Profits Rule
Norway is looking for feedback on a proposal that would implement the undertaxed profits rule, one component of the Organization for Economic Cooperation and Development's 15% corporate global minimum tax plan, the country's Finance Ministry said.
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June 21, 2024
OECD Official Sees Amount B Deal Helping With Amount A
The Organization for Economic Cooperation and Development is close to a final deal on a key part of its efforts to establish new international taxing rights under Amounts A and B of its Pillar One plans, according to the organization's tax chief.
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June 21, 2024
Taxation With Representation: Travers Smith, Potamitis Vekris
In this week's Taxation With Representation, RSK Group Ltd. gets a £500 million ($632 million) investment, Boston Scientific Corp. acquires Silk Road Medical Inc., Masdar takes a part of Terna Energy SA, and Tate & Lyle PLC buys CP Kelco from JM Huber Corp.
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June 21, 2024
EU Digital Tax Is Backup If Pillar 1 Stalls, French Official Says
Finalizing the Pillar One agreement to reallocate corporate taxing rights globally should remain a paramount goal, but if the effort stalls, the European Union should revive its plan for a digital tax of mostly U.S.-based tech giants, French Finance Minister Bruno Le Maire said Friday.
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June 21, 2024
Estonia Again Blocks Agreement On VAT Deal
For the second straight month, Estonia blocked agreement Friday on a European Union proposal for platform companies such as Airbnb, Uber and Estonia-based Bolt to collect value-added tax on behalf of service providers.
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June 21, 2024
Next UK Gov't Urged To Ease Private Healthcare Insurance Tax
Whoever wins the U.K. election on July 4 should introduce tax breaks on private medical insurance to relieve pressure on the National Health Service, a consultancy warned Friday.
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June 20, 2024
German Court Convicts 5 In €52M VAT Fraud In Cars, Masks
Five people who played roles in a value-added tax fraud scheme involving the trade of luxury cars and medical face masks that caused over €52 million ($55.7 million) in losses were convicted by a Berlin court, the European Public Prosecutor's Office announced Thursday.
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June 20, 2024
EU Court Rejects Co.'s Portuguese Tax Breaks Appeal
An appeal contesting a European Commission decision against a Portuguese tax exemption scheme was rejected by the European General Court, which found a Panama-based food company unable to prove why recovering the illegal state aid should be prohibited.
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June 20, 2024
China Denies Tax Crackdown As 2 Cos. Report $80M In Bills
China's tax authority denied a nationwide crackdown on companies' old tax returns Thursday, less than a week after a chemical firm facing 500 million yuan ($69 million) in additional liabilities halted production and a beverage maker reported owing 85 million yuan.
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June 20, 2024
UK Tax Pros Largely Support 2027 Carbon Border Tax Plan
Two groups representing tax professionals welcomed the U.K. government's plan to introduce a carbon border tax on certain carbon-intensive imports by 2027, but specifics regarding both default embedded emissions values and carveouts for smaller businesses must be ironed out, they said.
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June 20, 2024
Norway's $95M Yearly Dividend Tax Losses Spur Joint Audit
Norway's tax agency announced a joint audit with other Nordic tax agencies, saying it loses an estimated 1 billion kroner ($95 million) a year in withholding taxes that should be paid by foreign shareholders on dividends but aren't due to aggressive tax planning.
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June 20, 2024
Canada Lawmakers OK Digital Tax, Advance Min. Tax
Canada's Senate passed a 3% digital services tax that would target the revenue of large technology companies, following through on a plan that has drawn criticism from the U.S. and groups representing American tech giants.
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June 20, 2024
UK Tax Gap Continues Downward Trend, HMRC Says
The U.K. has continued to shrink its estimated tax gap, reaching a new low of 4.8% in the 2022-2023 tax year, following a trend of decreases over the past almost two decades, HM Revenue & Customs said Thursday.
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June 20, 2024
G20 Should Not Give Up On Pillar 1, Gentiloni Says
The Group of 20 rich and developing countries should not give up on the Pillar One agreement to reallocate corporate taxing rights globally, European Union tax commissioner Paolo Gentiloni said Thursday, pointing to a G20 summit in November as crucial.
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June 20, 2024
EU Adopts Sanctions On Russian LNG, Oil Tanker Fleet
The European Union agreed in principle Thursday on the 14th economic sanctions package against Russia since its war against Ukraine began, targeting liquefied natural gas, dual-use goods and technologies, and a fleet of oil tankers from non-EU countries.
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June 20, 2024
Repatriation Tax Doesn't Violate Constitution, Justices Rule
The U.S. Supreme Court upheld the 2017 federal tax overhaul's mandatory repatriation levy on Thursday, finding the measure applies to the earnings of foreign corporations with U.S. shareholders and therefore does not raise constitutional questions about taxing unrealized income.
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June 20, 2024
German Casino Tax Regime Is Illegal State Aid, EU Says
Germany's special tax system for public casino operators violates the European Union's law on state aid law, the bloc's executive branch and treaty regulator said on Thursday.
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June 19, 2024
EU Commission Tells France, Italy To Lower Budget Deficits
The European Commission told France, Italy and six other European Union countries to rein in their big budget deficits on Wednesday, although their governments can decide themselves on the details of spending cuts and tax hikes.
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June 19, 2024
Problems With VAT Law Still Not Resolved, Estonia Says
Estonia said Wednesday that it continues to have concerns about a proposed change to the European Union's value added tax law, which the small northeastern European country said would hurt small businesses.
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June 18, 2024
IRS Guidance Doesn't Perceive Spinoff Abuse, Official Says
Recent IRS guidance limiting the corporate spinoffs that revenue officials will approve as tax-free ahead of time was designed to reflect the drafters' current views, rather than suggest perceived abuse of these transactions, a U.S. Treasury Department official said Tuesday.
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June 18, 2024
AbbVie Says IRS Can't Treat $1.6B Break Fee As Capital Loss
The Internal Revenue Service cannot reclassify as a capital loss a $1.6 billion payment AbbVie made to an Irish biotechnology company after their failed merger and thereby raise the pharmaceutical giant's tax bill by $572 million, the company's attorneys told the U.S. Tax Court.
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June 18, 2024
Lithuania Legislature Approves Bank Windfall Tax Extension
The Lithuanian legislature voted to extend a temporary "solidarity tax" on bank profits through 2025, expecting to generate between €50 million ($53.7 million) and €70 million, it said Tuesday.
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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.
Expert Analysis
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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.
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5 Ways Firms Can Avoid Female Atty Exodus During Pandemic
The pandemic's disproportionate impact on women presents law firms with a unique opportunity to devise innovative policies that will address the increasing home life demands female lawyers face and help retain them long after COVID-19 is over, say Roberta Liebenberg at Fine Kaplan and Stephanie Scharf at Scharf Banks.
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IRS Real Estate Push Should Wake Up Foreign Investors
Two recently announced Internal Revenue Service audit campaigns targeting nonresident alien investment in U.S. real estate should prompt foreign investors to prepare for greater scrutiny as the agency works to improve tax compliance around such transactions, say attorneys at Holland & Knight.