International
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July 11, 2024
House GOP Urges USTR To Probe Canada Digital Services Tax
The U.S. trade representative should immediately launch an investigation into Canada's recently enacted digital services tax and determine if trade actions are necessary to protect American interests, U.S. House Ways and Means Republicans said in a letter Thursday.
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July 11, 2024
ABA Attys Seek To Avoid Reporting Foreign Trust Loans
The American Bar Association's tax, real estate and trust attorneys are seeking to prevent the U.S. Treasury Department from tightening reporting requirements for the exemption of loans from foreign trusts, which are often used by wealthy families and in succession planning, according to a consultation response.
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July 11, 2024
Brazilian Tax Agency Probes Refund Fraud Scheme
Brazilian federal tax authorities and police said Thursday they had conducted a search-and-seizure operation related to the investigation of an income tax refund fraud scheme.
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July 11, 2024
Ex-Leaders Ask Biden For Int'l Coordination On Billionaire Tax
President Joe Biden should get behind Brazil's proposal for the Group of 20 nations to coordinate a minimum tax on billionaires, nearly 20 former presidents and prime ministers from countries such as Canada, France and South Korea said in an open letter.
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July 11, 2024
IRS Proposes 'Basket Contracts' As Listed Transactions
The Internal Revenue Service proposed rules Thursday that would flag so-called basket option contracts as potentially abusive listed transactions, imposing additional reporting requirements under the threat of penalty for individuals and businesses involved in such arrangements.
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July 11, 2024
IRS, OECD Officials Detail Expansion Of AI In Tax Work
The Internal Revenue Service and Organization for Economic Cooperation and Development are making great progress in adopting artificial intelligence in tax administration, representatives of both organizations said Thursday.
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July 11, 2024
Israel Says Resident Hid $5.5M In Offshore Bank Accounts
An Israeli resident was released under restrictive conditions Thursday after the government alleged he failed to report foreign bank accounts that held more than 20 million shekels ($5.5 million), according to a statement from the Israel Tax Authority.
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July 11, 2024
Tax Haven Biz Revenues Per Worker Still Far Outpace Norm
Companies recorded median revenues per employee of $1.6 million in low-tax jurisdictions like Ireland, the Cayman Islands and Hong Kong and around $300,000 in all other jurisdictions in 2021, a difference that has narrowed since 2017, the OECD said Thursday.
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July 11, 2024
Biz Officials Call For Simpler Tax Rules In Light Of Pillar 2
Business representatives said Thursday that tax compliance rules need to be simplified as new minimum tax rules, known as Pillar Two, are added to the existing regime.
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July 11, 2024
Failure Of Pillar 1 Would Yield Worse Alternatives, Panel Says
A failure of the Pillar One agreement to reallocate corporate taxing rights would lead to alternatives that are worse, with the return of national digital services taxes worldwide, tax officials and academics said Thursday.
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July 10, 2024
Engineer Who Faced Export Charges Cops To Tax Counts
A Chinese-born engineer has pled guilty to two counts of filing a false tax return related to allegations that he and his wife omitted gross income from their tax returns between 2015 and 2019, after Texas federal prosecutors initially charged the couple with export violations and fraud.
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July 10, 2024
Portugal Enacts Pillar 2 As Part Of Economic, Tax Package
Portugal's Council of Ministers approved the minimum tax provision known as Pillar Two in a package of economic and tax measures designed to boost the country's economic growth, the council announced.
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July 10, 2024
OECD Publishes Pillar 2 Technical Reporting Language Draft
The Organization for Economic Cooperation and Development published a draft of technical details required to digitally input and disseminate information required for Pillar Two global minimum tax returns Wednesday.
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July 10, 2024
Americans Overseas Ask for Clarity In Foreign Trust Regs
An advocacy group representing U.S. citizens living abroad urged the U.S. Treasury Department to clarify proposed rules for reporting transactions with foreign trusts, contending that guidance should explain which common pension arrangements are exempt from disclosure obligations.
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July 10, 2024
Curtis Mallet-Prevost To Open Law Office In Saudi Arabia
Curtis Mallet-Prevost Colt & Mosle LLP has obtained a license to practice law in the Kingdom of Saudi Arabia, the firm announced this week.
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July 10, 2024
HMRC, CPS Beat Financier's Claim Over Botched Prosecution
HM Revenue and Customs and the Crown Prosecution Service have beaten claims of malicious prosecution and misfeasance in public office by a corporate financier following a failed criminal fraud case, with a judge finding that they had enough evidence to pursue him.
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July 10, 2024
French Left's Tax Pledges May Go Unfulfilled
The tax policy pledges put forward by the leftist bloc of parties that won the most seats in France's legislative election may not be fulfilled given the bloc's failure to win an outright majority.
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July 10, 2024
India's High Court Nixes Challenge To Taxing Of Tour Vehicles
The Indian Supreme Court dismissed a group of petitions challenging border taxes imposed by state governments on tour company vehicles because it said the litigation should have begun in a different court.
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July 10, 2024
Attempts To Scrap EU Tax Veto Are Useless, Hungary Says
Attempts by European Union countries to try to remove the requirement of unanimity for delicate policy decisions such as tax law and adding new EU member states are futile, Hungary's minister for European affairs said Wednesday.
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July 09, 2024
House Panel OKs Tax Breaks For More Education Expenses
The House Ways and Means Committee sent several education-related tax bills to the full House of Representatives on Tuesday, including legislation that would make additional elementary and secondary school expenses eligible for tax-advantaged education savings accounts.
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July 09, 2024
Irish Budget To Allocate €1.4B To Fund Tax Measures in 2025
The Irish government on Tuesday published the details of its €8.3 billion ($9 billion) budget for 2025, including €1.4 billion set aside to fund tax measures.
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July 09, 2024
India High Court Says Rights To Sell Liquor Aren't Taxed
The rights to sell the alcoholic beverage arrack are not taxed because the liquor vendors who purchase them do not fit into the definition of "buyer" under Indian tax law, the Supreme Court of India ruled.
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July 09, 2024
Finnish Tax Take Drops Amid Slowing Real Estate Market
The Finnish government's tax revenue declined 0.4% last year to €42.3 billion ($45.7 billion) as collections from levies on real estate purchases and car registrations each declined by more than 20%, the country's tax authority said Tuesday in a news release.
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July 09, 2024
EU, India Wary Of Overlap From UN's Global Tax Work
Indian and European Union officials agreed during a meeting that the negotiations around a framework convention on international tax cooperation at the United Nations shouldn't overlap efforts of the ongoing OECD-led global tax overhaul, an EU executive department said.
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July 09, 2024
UK's Non-Dom Taxpayer Count Increased 7%
A growing number of taxpayers in the United Kingdom claimed last year that their permanent home is outside the country, qualifying them for a non-domiciled tax exemption in the crosshairs of lawmakers, HM Revenue & Customs said Tuesday.
Expert Analysis
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Consider Mutual Agreement Procedures For Double Tax Relief
Taxpayers wary of using mutual agreement procedures for double taxation relief should revisit the process, which is more straightforward than many believe, lest they miss out on tax savings, says Monique van Herksen of Simmons & Simmons.
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A Road Map For US Involvement In Europe's Cum-Ex Probe
The dividend arbitrage trading strategy known as cum-ex continues to face regulatory scrutiny in Europe, and stateside regulators may soon follow suit with the U.S. Securities and Exchange Commission’s recent American depositary receipt probe as a guide for enforcement, says Joshua Ray at Rahman Ravelli.
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Congress Should Make TCJA Income Definition Permanent
Congress should not allow the Tax Cuts and Jobs Act's definition of adjusted taxable income, which includes depreciation and amortization, to expire in 2022 because it would discourage debt-free investment, running counter to the law's intent, says George Callas at Steptoe & Johnson.
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OECD Delays Are Imperiling Digital Tax Deal
As the Organization for Economic Cooperation and Development continues to push back its deadline for a digital tax overhaul, countries are beginning to pursue unilateral solutions and the negotiations are turning political, decreasing the likelihood of an agreement, says Joyce Beebe at Rice University.
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Mitigating IRS Cryptocurrency Enforcement Risk In 2021
The IRS seems poised to shift focus in 2021 from education to enforcement of virtual currency tax laws, and noncompliant taxpayers should consider whether they are eligible to file amended returns or voluntary disclosures to mitigate the risk of civil penalties, criminal investigation or prosecution, say Don Fort and Lawrence Sannicandro at Kostelanetz & Fink.
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2020's Key Tax Controversy Developments
Andrew Roberson and Kevin Spencer at McDermott highlight 2020's key tax controversy developments, offering their perspective on important tax decisions, the Internal Revenue Service’s cooperative audit program, informal tax return amendment procedures, Large Business & International Division campaigns, and handling virtual appeals conferences during the pandemic.
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Justices Likely To Shield Treasury From Preemptive Action
Recent U.S. Supreme Court oral arguments in CIC Services v. Internal Revenue Service suggest the court will resolve a circuit split by ruling the Anti-Injunction Act shields the U.S. Department of the Treasury from preemptive challenges — bad news for those hoping to challenge unfavorable regulations, says Monte Silver at Silver & Co.
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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.