International
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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.
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April 30, 2024
The Tax Angle: TCJA Teams, Dear Colleague Letters
From a look at House GOP efforts to prepare for next year's expiration of their 2017 tax overhaul to ongoing attempts by lawmakers to draw attention and support for their own tax legislation, here's a peek into a reporter's notebook on a few of the week's developing tax stories.
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April 30, 2024
Global Climate Tax Could Fund Disaster Aid, Report Says
If OECD countries adopted a tax on the extraction of fossil fuels proposed by over 100 climate organizations, $900 billion could be generated cumulatively by 2030, a majority of which would be earmarked for those hit by climate disasters, some of those groups reported.
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April 30, 2024
EU Tax System Needs To Aid Climate Policy, Accountants Say
European Union lawmakers should design a tax system in their next five-year legislative term that supports the green transition and long-term employment, a European lobby for accountants said in a document posted Tuesday.
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April 29, 2024
Court Can Make Widow Pull $2.5M From Swiss Bank, US Says
A Colorado federal court can force a widow to send $2.5 million from a Swiss bank to the U.S. to repay her late husband's penalties and interest for failing to report his foreign accounts, the U.S. told the court.
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April 29, 2024
OECD Nations Steer UN Tax Talks Toward Decision-Making
The terms of reference for a United Nations global tax convention should guide the decision-making of a committee that will negotiate substantive provisions later even though some governments prefer to defer debate on the decision-making procedures to the General Assembly, several OECD government representatives said Monday.
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April 29, 2024
Canada Opens Second R&D Tax Credit Consultation
With an additional CA$600 million ($439 million) earmarked for its scientific research and experimental development tax incentive program, Canada is looking for more specific feedback on expanding and otherwise adjusting the regime.
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April 29, 2024
Poland Pushes Back Mandatory E-Filing After Finding Flaws
Polish businesses with sales totaling more than 200 million zloty ($50 million) won't have to use the country's electronic invoice system until 2025, with the full rollout delayed until 2026, due to multiple problems uncovered in the system, the country's tax authority said.
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April 29, 2024
OECD-UN Initiative Lands Developing Countries $2.3B In Tax
A joint initiative between the Organization for Economic Cooperation and Development and the United Nations to help developing countries boost tax revenues said Monday that it has generated $2.3 billion in additional revenues and $6.05 billion in additional tax assessments since its 2015 formation.
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April 29, 2024
Ex-Man City Player Benjamin Mendy Pays £710K Tax Debt
Former Manchester City footballer Benjamin Mendy avoided bankruptcy on Monday after paying a £710,000 ($892,000) tax bill minutes before a court hearing to determine whether an order should be made.
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April 29, 2024
US Expatriations Plummet In 1st Quarter, IRS Says
The number of people who expatriated from the U.S. fell nearly 70% during the first quarter of 2024 compared with the previous quarter, the Internal Revenue Service said in a notice published Monday.
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April 29, 2024
EU Official Wants Progress On New Revenue Streams
The budget commissioner of the European Union said Monday that the bloc must make progress toward agreeing on new revenue streams that would give it more diversified sources of income.
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April 26, 2024
4 Goals For Gov'ts To Pursue In The UN Tax Convention
The United Nations' framework convention on international tax cooperation should resolve digital taxation, incorporate tax transparency conventions, seek consensus on tax allocation issues but adopt best practices by simple majority, and help fund development goals, officials and experts told Law360 as governments began negotiations Friday.
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April 26, 2024
FedEx Calls Gov't Arguments On Tax Credits Contradictory
The federal government advanced contradictory arguments in FedEx's $84.6 million foreign tax credits dispute with the Internal Revenue Service, the package delivery giant said in a filing in Tennessee federal court.
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April 26, 2024
Ireland Received Nearly €24B In Corp. Taxes In 2023
Corporations paid Ireland €23.8 billion ($25.5 billion) in taxes in 2023, a 5.3% increase over 2022, making corporate tax receipts the second-largest tax revenue generator in the country, according to the Irish revenue department.
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April 26, 2024
PwC Australia Appoints 6 Partners To Guide Scandal Rebound
PwC Australia announced that it has elected six partners to its governance board as the firm continues to attempt to rebound in the wake of its scandal involving the leak of Australian government documents.
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April 26, 2024
HMRC Says Tax Digitalization Plan Will Generate £6.4B
HM Revenue & Customs said its program to modernize U.K. tax filing is expected to generate £6.38 billion ($7.97 billion) in additional revenue through 2034 after projections last year put it at £3.9 billion.
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April 26, 2024
Poland Seeks Input On Bill To Enact Minimum Tax
Poland, one of a handful of European Union countries that have delayed implementing the Organization for Economic Cooperation and Development's Pillar Two global minimum tax plan, introduced a proposal for public comment that would enact the regime.
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April 26, 2024
Abbott Labs' $417M IRS Bill Isn't Wrong, Tax Court Told
The Internal Revenue Service denied allegations by Abbott Laboratories that it incorrectly increased the global healthcare giant's income, resulting in a $417 million tax bill, in answering Abbott's lawsuit filed with the U.S. Tax Court.
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April 26, 2024
Top EU Judge Sees Lower Court Becoming Like Tax Court
The lower court of the European Union, the General Court, will over time become a venue that specializes in some tax matters after a reform is put into place, the EU's top judge has said.
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April 26, 2024
HSBC Beats Investors' £1.3B Disney Film Scheme Fraud Case
HSBC fended off on Friday a £1.3 billion ($1.6 billion) fraud claim brought by hundreds of investors who alleged the bank misled them into financing a Disney movie tax relief scheme it developed which turned out to be worthless.
Expert Analysis
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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.
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VAT Cuts Won't Save Economies, Will Burden Businesses
Although value-added tax cuts may seem attractive for governments looking to stimulate economies in the wake of the pandemic, their implementation costs and inefficiencies can cause significant trouble for businesses, says Richard Asquith of Avalara.
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COVID-19 May Make Incomplete Contracts Renegotiable
Intercompany agreements on transfer pricing that do not include a pandemic eventuality might be argued to be incomplete from an economics perspective, providing justification for controlled parties to negotiate a remediation, say Robin Hart and Steven Schwartz at Charles River Associates.