International
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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.
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June 17, 2024
$2.1B Danish Tax Fraud Defendant Pushes For Separate Trials
An attorney facing trial alongside his clients on allegations of filing $2.1 billion in fraudulent tax refund claims in Denmark urged a New York federal court to hear his case separately, saying disparate legal arguments could confuse a jury if only one trial is held.
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June 17, 2024
OECD Tax Plan Is Developing Nations' Best Choice, Prof Says
Developing countries could gain more revenue from the OECD's multilateral plan to tax the digital economy than the U.N. Tax Committee's bilateral alternative because they have small treaty networks, many customers and few large companies, an academic argued Monday during an Oxford University panel.
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June 17, 2024
Saudi Arabia Should Boost Non-Oil Tax Revenue, IMF Says
Saudi Arabia has had an "unprecedented economic transformation" in recent years, but maintaining such growth will require further tax efforts, particularly when it comes to non-oil revenue generation, the International Monetary Fund said.
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June 17, 2024
OECD Clarifies Rules For Global Minimum Tax
The OECD-led international negotiating body working on fundamental changes to corporate tax law clarified rules under the global minimum tax on deferred tax and securitization, the organization said Monday.
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June 17, 2024
EU Approves Italian Fee Cut For Boats Using Cleaner Energy
The European Commission approved an Italian plan Monday which, by waiving a fee, incentivizes boats to use a cleaner way of obtaining electricity.
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June 14, 2024
US Urges 5th Circ. To Back $2M Tax Bill For Tire Imports
The Fifth Circuit should overturn a lower court's ruling that a Houston truck company was not an importer responsible for nearly $2 million in excise taxes on tires it bought from a Chinese manufacturer, the U.S. told the Fifth Circuit on Friday.
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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.
Expert Analysis
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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.
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6 Tax Considerations For Life Sciences Collaboration Deals
Given recent IRS guidance and changes to certain tax rates and deductions, biotech and life sciences companies entering into collaboration agreements should assess several unique taxation issues affecting matters ranging from research and development expenditures to profit-sharing terms, say attorneys at Orrick and Andersen Tax.
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Rushed Multilateral Negotiations Caused Two-Pillar Tax Mess
Cracks appearing in the two pillars of the 2021 global tax plan stem from a multilateral tax policy process that rushed to issue rules without first resolving fundamental differences between countries or ensuring that the U.S., a key player, could implement them, says Jefferson VanderWolk at Squire Patton.
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Key Considerations For Seeking Relief From Double Taxation
Caroline Setliffe and E. Miller Williams at Eversheds Sutherland lay out the Organization for International Cooperation and Development’s mutual agreement procedure for settling double-taxation disputes, and discuss six factors U.S. taxpayers doing business in multiple countries should consider when determining the most advantageous form of relief.
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2 Tax Decisions Hold Key Transfer Pricing Takeaways
Richard Slowinski and Stefanie Kavanagh at Alston & Bird discuss two recent decisions in cases against the IRS — Eaton Corp. from the Sixth Circuit and Medtronic from the Tax Court — that may help clarify when the agency can cancel an advance pricing agreement, but leave unanswered questions about which pricing method applies to high-value intercompany licensing transactions.
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Digital Taxation Is Necessary, But Tough To Manage
The U.S. government has started to tackle complex new tax laws as the digital economy continues to grow, but this demands guidelines that will facilitate the growth while protecting investors and the government's finances, say attorneys at Cadwalader.
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Company Considerations For Cash Award Incentives: Part 2
Excerpt from Practical Guidance
Cash awards can help companies address some issues associated with equity awards to compensate employees, but due to potential downsides, they should be treated as a tool in a long-term incentive program rather than a panacea, say Denise Glagau and Kela Shang at Baker McKenzie.
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Company Considerations For Cash Award Incentives: Part 1
Excerpt from Practical Guidance
Denise Glagau and Kela Shang at Baker McKenzie discuss what companies must consider when offering cash awards outside of U.S. jurisdictions, and explain how some challenges associated with equity awards may be addressed with cash awards.
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What AML Bill Could Mean For Firms, Funds And FinCEN
If passed, an amendment within Congress’ annual defense bill would expand the list of institutions subject to anti-money laundering regulations, from law firms to investment funds, creating potential rulemaking and enforcement challenges for the Financial Crimes Enforcement Network, say attorneys at Arnold & Porter.
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Unpacking The New Stock Buyback Tax And Its Exceptions
Xenia Garofalo and Kyle Colonna at Eversheds Sutherland discuss provisions of the recently enacted tax on corporate stock repurchases, how its exceptions may be applied and what companies should consider when evaluating the cost of new or existing programs.