International
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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.
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June 12, 2024
Groups Push Back On Stock Buyback Tax Test's Scope
The U.S. Treasury Department's proposed stock buyback tax rules go too far in trying to assess whether the main purpose of a U.S. subsidiary's funding purchase of its foreign parent's stock is to avoid the tax, two groups said in comments released Wednesday.
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June 12, 2024
Aussie Senate's Final PwC Report Focuses On Integrity Recs
Australia's Senate released its final report Wednesday regarding PwC's marketing of confidential draft tax laws to clients, pushing for both consulting firms and the government to assure that the firms, particularly the Big Four, act with integrity.
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June 12, 2024
Treasury Issued Over $1B In Clean Vehicle Tax Credits
The clean vehicle tax credit of up to $7,500 has saved buyers more than $1 billion in total upfront costs since January, the U.S. Treasury Department announced Wednesday, saying the figures represent a major milestone in lowering transportation costs since the incentive was updated in 2022.
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June 12, 2024
Italy Investigating €13M VAT Fraud Involving Chinese Fabric
An Italian judge issued a freezing order against four people and a company as investigations continue into a scheme involving the illegal importation of Chinese fabric that caused over €13 million ($14.1 million) in value-added tax losses, the European Public Prosecutor's Office said Wednesday.
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June 12, 2024
New Dutch Gov't Agrees On Top Finance Official
The incoming right-wing Dutch government has agreed to appoint a conservative politician as finance minister and to maintain a separate position for the state secretary for taxation in order to comply with a recent Netherlands Supreme Court tax ruling on compensation to investors, Dutch media reported.
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June 11, 2024
US Issues Sanctions For $50M Guyana Gold Tax Evasion
Two Guyanese businessmen and a Guyanese official were sanctioned by the U.S. Treasury Department on Tuesday after a probe into a corruption scheme that helped the businessmen evade $50 million in gold export taxes that should have been paid to Guyana's government, Treasury said.
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June 11, 2024
Latvia Renominates EU Trade Commissioner To Retain Role
The Latvian government has renominated former Prime Minister Valdis Dombrovskis to retain his European Commission position as the commissioner for trade, the government announced Tuesday.
Expert Analysis
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What To Make Of IRS' New Advance Pricing Guidance
Recent guidance on the IRS' goals for its advance pricing agreement system provides helpful insight into review and decision-making procedures for advance pricing agreement requests, but it also raises questions about the IRS' objectives, say Richard Slowinski and Stefanie Kavanagh at Alston & Bird.
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Reserved Investor Fund Would Plug Gap In UK Finance Market
The reserved investor fund recently proposed by HM Treasury has the potential to be a welcome tax-efficient addition to the U.K.’s canon of products for real estate investments, with attractive features for companies and, in particular, large asset managers, say lawyers at Herbert Smith.
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The Reciprocal Tax Bill Is A Warning Shot At Pillar 2
A bill recently introduced in the House of Representatives to reciprocally tax countries deemed to have imposed discriminatory taxes on U.S. citizens and businesses takes aim at countries implementing the global minimum tax treaty known as Pillar Two, with which the U.S. has not complied, says Alan Cole at the Tax Foundation.
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What Tax-Exempt Orgs. Need From Energy Credit Guidance
Guidance clarifying the Inflation Reduction Act’s credit regime, expected from the U.S. Department of the Treasury this summer, should help tax-exempt organizations determine the benefits of clean energy projects and integrate alternative energy investments into their activities, say attorneys at Morgan Lewis.
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How Foreign Info Return Penalty Case May Benefit Taxpayers
The U.S. Tax Court's recent decision that the Internal Revenue Service cannot penalize taxpayers for failing to file foreign corporation information returns may give similarly situated taxpayers an opportunity to also avoid penalties, provided they protect their rights before the decision is overturned or mooted by legislation, say attorneys at Arnold & Porter.
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The Nuts And Bolts Of IRS Domestic Content Tax Credit
Recent IRS guidance provides specifics on how renewable energy projects can qualify for bonus tax credits by meeting U.S. domestic content rules, but also creates a qualification framework that will be complicated for project developers to navigate, say Scott Cockerham and Wolfram Pohl at Orrick.
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Taxing The Digital Economy: The Good, The Bad And The Ugly
U.S. tech companies should watch for important developments in international taxation, including the resolution of Apple's decade-old state aid case, growing frustration with the Organization for Economic Cooperation and Development's global tax plan and adoption of the digital services tax instead, says Joyce Beebe at Rice University's Baker Institute for Public Policy.
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Big Tax Changes For Multinational Cos. In Budget Proposal
The Biden administration’s fiscal year 2024 budget proposes changes that would materially alter decades-old Internal Revenue Code provisions, requiring a shift in multinational corporations' tax planning strategies comparable to that required after enactment of the Tax Cuts and Jobs Act, say Xenia Garofalo and Kyle Colonna at Eversheds Sutherland.
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Senate Credit Suisse Report Puts Attention On Banks, Trusts
The Senate Finance Committee's recent finding that Credit Suisse violated a plea agreement struck over its role in enabling offshore tax evasion has important ramifications for banks and trusts, including how they onboard, document and report on transactions relevant to U.S. reporting requirements, say Will Barry and Ian Herbert at Miller & Chevalier.
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Seeking IRS Accountability For Faulty Microcaptive Notice
Like the taxpayers in Standard Insurances v. U.S. seeking to expand earlier wins in microcaptive insurance cases that limit IRS use of improperly obtained information, others should consider ways to hold the agency accountable and provide incentive for it to follow the law going forward, says Joshua Smeltzer at Gray Reed.
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Biden Admin. Proposals Both Encourage And Thwart EV Adoption
While the Biden administration has been aggressively focused on promoting electric vehicles from the start, its recently issued guidance on EV tax credits and its restrictive new auto emissions proposal create a sense of implementation whiplash that may frustrate manufacturers and consumers, says Levi McAllister at Morgan Lewis.
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The Key Issues Keeping Transfer Pricing A Top Tax Concern
Several challenges preventing a global economic reemergence from the pandemic era are making practitioners reevaluate commonly used transfer pricing models, and embrace new technologies and ways of doing business, say Farnaz Amini and Sophia Castro Jurado at Marcum.
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Curtailing Offshore Tax-Advantaged Investment In China
The U.S. government's plans to establish a new outbound investment regime hold the potential to arrest Chinese companies' increasing use of offshore, tax-advantaged locations to raise capital, says David Plotinsky at Morgan Lewis.