International
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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.
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July 08, 2024
Top International Tax Cases Of 2024: Midyear Report
With a U.S. Supreme Court decision affirming a key 2017 tax provision on repatriation, millions of dollars in FBAR penalties upheld and a French ruling confirming the U.S. government's access to foreign bank accounts, the IRS stacked up important court victories on international enforcement in the first half of 2024. Here, Law360 reviews those and other significant rulings from the past six months.
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July 08, 2024
Italy Outlines Details On Local Min. Tax Under Global Deal
The Italian Finance Ministry published plans for implementing a global rule that allows countries to tax the local affiliates of multinational corporations if their effective tax rates dip below an internationally agreed-upon 15% minimum.
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July 08, 2024
Reeves Sets Out Plans For Pensions Investing, Fiscal Review
HM Treasury will work to direct pensions investment to British businesses, create a national wealth fund and conduct a fiscal review into government finances, Rachel Reeves said in her first public speech as chancellor on Monday.
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July 08, 2024
EU Court To Rule On Lithuania Denying Corp. Tax Break
A Lithuanian court asked the European Union's highest court to determine whether Lithuania applies EU law correctly when blocking tax exemptions for dividends transferred to a parent company from a subsidiary in another EU country, a document published Monday said.
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July 08, 2024
Feds Seize $63M LA Estate Tied To Armenian Bribe Probe
The U.S. Department of Justice said Monday that it will seize a $63 million Los Angeles estate that it claims was bought with bribe payments for the family of a former Armenian government official.
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July 08, 2024
German Leaders OK Legislative Package With Tax Cuts
Leaders in Germany's three-party government agreed to a legislative package that would result in tax cuts if enacted, an outline of the agreed-to measures said.
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July 08, 2024
Leftist Bloc That Wants To Tax Rich Wins French Election
A left-wing bloc that promises to increase taxes on the rich won a plurality of seats in elections to the lower house of France's legislature but fell far short of gaining an outright majority.
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July 05, 2024
How Reshaped Circuit Courts Are Faring At The High Court
Seminal rulings from the U.S. Supreme Court's latest term will reshape many facets of American society in the coming years. Already, however, the rulings offer glimpses of how the justices view specific circuit courts, which have themselves been reshaped by an abundance of new judges.
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July 05, 2024
Breaking Down The Vote: The High Court Term In Review
The U.S. Supreme Court's lethargic pace of decision-making this term left the justices to issue a slew of highly anticipated and controversial rulings during the term's final week — rulings that put the court's ideological divisions on vivid display. Here, Law360 takes a data dive into the numbers behind this court term.
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July 05, 2024
The Sharpest Dissents From The Supreme Court Term
The U.S. Supreme Court's session ended with a series of blockbuster cases that granted the president broad immunity, changed federal gun policy and kneecapped administrative agencies. And many of the biggest decisions fell along partisan lines.
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July 05, 2024
The Firms That Won Big At The Supreme Court
This U.S. Supreme Court term featured high-stakes oral arguments on issues including gerrymandering, abortion and federal agency authority, and a hot bench ever more willing to engage in a lengthy back-and-forth with advocates. Here's a look at the law firms that argued the most cases and how they fared.
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July 05, 2024
Top Federal Tax Cases To Watch In The 2nd Half Of 2024
In the coming months, the U.S. Treasury and the IRS will defend rules designed to go after what they consider as abusive tax practices, including the economic substance doctrine, the Corporate Transparency Act and the moratorium on employee retention tax credits. Here, Law360 looks at key federal tax cases to watch in the rest of 2024.
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July 05, 2024
Starmer Picks Reeves For Treasury To Steer Growth Aims
Prime Minister Keir Starmer has handed the reins of the U.K.'s fiscal and economic policy to Rachel Reeves, formally naming her as the next chancellor of the exchequer in the first of a round of cabinet appointments on Friday.
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July 05, 2024
EU Imposes Anti-Subsidy Duties On Chinese EVs
The European Commission imposed provisional import duties of 17.4% to 37.6% on electric vehicles made in China to compensate for what it said were unfair state subsidies throughout the manufacturing and sales process.
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July 05, 2024
EU Official Says Members Blind To Cross-Border Business
A senior European Union tax official has criticized EU member states for failing to adjust their tax systems to help particularly smaller businesses wanting to carry out activities in multiple countries within the bloc.
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July 04, 2024
Labour's Big UK Election Win Clears Way For Tax Reform
Labour's victory in the U.K. general election clears the way for plans to raise taxes on the rich to close a widening spending gap, but it could also mean wider fiscal reform in the new government's first budget later this year.
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July 04, 2024
Labour Sweeps Tories From Power In UK Election Rout
Keir Starmer was poised to become Britain's next prime minister on Friday after his Labour Party ousted Rishi Sunak's Conservatives in a landslide general election victory, ending 14 years of Tory government with a pledge of "national renewal."
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July 04, 2024
EU Should Tighten Fiscal Policies In 2025, Advisers Say
European countries using the euro should tighten their fiscal policies "sizably" next year, combining raising taxes with cuts to spending, depending on national circumstances, an advisory board has said.
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July 03, 2024
Ex-Defense Contractor Evaded Taxes On $350 Million, US Says
A former defense contractor and his wife face a 30-count indictment alleging they were involved in a decadeslong scheme to defraud the U.S. government and avoid taxes on more than $350 million in income, the Department of Justice announced Wednesday.
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July 03, 2024
Warren, Other Pols Push Yellen For Corp. Minimum Tax Rules
Sen. Elizabeth Warren and three other lawmakers urged Treasury Secretary Janet Yellen for the department to quickly release regulations to implement the corporate alternative minimum tax in a letter released Wednesday.
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July 03, 2024
Australia Clarifies Hybrid Mismatch Tax Rules
The Australian Taxation Office issued guidance Wednesday further clarifying two aspects of its hybrid mismatch rules designed to prevent multinational corporations from exploiting differences in tax treatment between jurisdictions.
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July 03, 2024
Former OECD Deputy Tax Director Joining KPMG Australia
A former deputy tax director for the Organization for Economic Cooperation and Development is joining KPMG Australia as a partner starting next month, the firm said Wednesday.
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July 03, 2024
Fox Rothschild Hires Pryor Cashman Nonprofit Leads
Fox Rothschild LLP announced Wednesday the hiring of two Pryor Cashman LLP partners for its corporate department in New York.
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July 03, 2024
Slovenia Tax Incentives Impair Decarbonization, OECD Says
Slovenia's reduced tax rates for certain harmful fossil fuels have hurt the country's efforts to limit its carbon emissions, the Organization for Economic Cooperation and Development said Wednesday.
Expert Analysis
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High Court Ax Of Atty-Client Privilege Case Deepens Split
The U.S. Supreme Court's recent dismissal of In re: Grand Jury as improvidently granted maintains a three-way circuit split on the application of attorney-client privilege to multipurpose communications, although the justices have at least shown a desire to address it, say Trey Bourn and Thomas DiStanislao at Butler Snow.
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US-India Advance Pricing Resolutions Should Reassure Cos.
The United States' and India's tax authorities' recent resolution of a significant number of pending advance pricing agreements should reduce taxpayer uncertainty, reassure companies of the nations' good working relationship and improve India's investment environment, say Miller Williams and Caroline Setliffe at Eversheds Sutherland.
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Stock Buyback Excise Tax Guidance A Mixed Bag For SPACs
Recent IRS guidance on the new stock repurchase excise tax includes a welcome exception for publicly traded special-purpose acquisition companies but does not exclude redemptions in connection with a de-SPAC transaction, and further guidance is needed to clarify ambiguities around the exception's application, say Olga Bogush and Evgeny Magidenko at ArentFox Schiff.
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The IRS' APA Rulemaking Journey: There And Back Again
Attorneys at Dentons examine recent challenges in which taxpayers successfully argued Internal Revenue Service rulemaking was invalid under the Administrative Procedure Act, how tax exceptionalism and U.S. Supreme Court regulatory deference prompted such challenges, and similar challenges the agency will likely face following this line of cases.
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ECJ Fiat Ruling Sets Clear Boundaries For EU State Aid Law
The European Court of Justice's recent landmark decision in Fiat v. Commission limiting the commission’s attempts to circumvent the lack of EU powers in the area of tax law has important implications in EU state aid law and beyond, say Andreas Reindl and Pietro Stella at Van Bael.
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Unpacking The Interim Guidance On New Stock Buyback Tax
The U.S. Department of the Treasury and Internal Revenue Service's recent notice on applying the newly effective excise tax on stock repurchases provides much-needed clarity on the tax's scope, which is much broader than anticipated given its underlying policy rationale, say attorneys at Eversheds Sutherland.
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IRS Will Use New Resources To Increase Scrutiny In 2023
The new year promises to be a busy one for the Internal Revenue Service, which is poised to apply the boost in funding provided by the Inflation Reduction Act to bolster and expand its enforcement capability, and there are four areas to watch, say attorneys at Skadden.
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How Japan's Implementation May Change The Pillar 2 Debate
Japan’s outline of proposed legislation adopting a primary component of the Organization for Economic Cooperation and Development's 15% global minimum tax will increase pressure on countries — including the U.S. — that have not committed to adopting Pillar Two, says Takato Masuda of Nishimura & Asahi.
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Foreign Tax Credit Proposal Is Some Help, But More Is Needed
New foreign tax credit regulations proposed by the U.S. Treasury Department provided some measure of relief on cost recovery and royalty withholding, two of the most troublesome aspects of the 2021 final foreign tax credit regulations, but the final regulations are still harmful to many taxpayers, making litigation inevitable, say attorneys at Fenwick.
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IRS' Tax Gap Statistics Don't Paint A Full Compliance Picture
The Internal Revenue Service's recent report indicating a widening tax gap sheds important light on tax compliance, underlines key pressure points and provides insights into how tax administration could be improved; but tax gap estimates also have their limits, says Joyce Beebe at Rice University.
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How High Court Could Change FBAR Penalty Landscape
On Wednesday, the U.S. Supreme Court will hear Bittner v. U.S., a case that will affect many people penalized for failing to file a Report of Foreign Bank and Financial Accounts, and there are important procedural implications should the government's position be reversed, say Reuben Muller and Andreas Apostolides at Cole Schotz.
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IRS Memo May Change IP Royalty Tax Prepayment Planning
A recent Internal Revenue Service advice memorandum finding a taxpayer was not permitted to prepay tax on contingent royalties after contributing intellectual property offshore is a noteworthy departure from earlier guidance that highlights potential differences between actual and deemed licenses, says William Skinner at Fenwick.
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What IRS Funding Increase Means For Taxpayers
The Internal Revenue Service will first use the influx of funding from the Inflation Reduction Act to address customer support and personnel issues, but with over half the money allocated to enforcement, corporations and high-net-worth individuals will face increased scrutiny, say Patrick McCann Jr. and Jasen Hanson at Chamberlain Hrdlicka.