International
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May 15, 2024
Taxpayers Let Down By HMRC Digital Service, Says Watchdog
HM Revenue and Customs has let down taxpayers by failing to deliver better online services, according to a report published on Wednesday by the public spending watchdog.
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May 15, 2024
Swiss Seek Feedback On Crypto Information Exchange
Switzerland's executive body, the Federal Council, is seeking feedback from the public on its plan to adopt two Organization for Economic Cooperation and Development standards that will update the country's automatic exchanges of information to account for crypto-assets, it said Wednesday.
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May 15, 2024
11 Arrested In €25M Italian VAT Fraud Case
Italian police arrested 11 suspects in a value-added tax fraud ring involving electronic products that resulted in losses of over €25 million ($27.2 million), the European Public Prosecutor's Office said Wednesday.
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May 15, 2024
Gentiloni Warns EU States Not To Be Too Harsh With Budgets
European Union tax commissioner Paolo Gentiloni warned EU countries Wednesday not to be too aggressive with budget cuts, even as some may have to take a more restrictive fiscal stance this year and next than had been planned.
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May 15, 2024
German Finance Minister Wants Lower Tax Burden
Germany's finance minister said he would like to see the tax burden lowered as part of a broader push to make life less burdensome for industry as the country tries to stimulate economic growth.
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May 15, 2024
EU Finance Ministers Plan Road To Tax Revamp
European Union finance ministers agreed on a work program to implement about 40 measures to improve business financing, including a targeted makeover of tax systems in member countries covering corporate taxes, capital gains and tax breaks for interest payments.
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May 14, 2024
A Fifth Of Big Cos. Use Tax Transparency Standard, Org. Says
About a fifth of the largest 1,000 public companies worldwide have voluntarily used a public country-by-country reporting standard created by an international independent standards organization, the nonprofit said Tuesday.
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May 14, 2024
Law Prof Comes To Treasury's Aid In 3M Transfer Pricing Fight
The U.S. Department of the Treasury did not act arbitrarily when it wrote transfer pricing regulations that allowed the government to disregard foreign legal restrictions on royalty payments when allocating income to 3M from an affiliate, a law professor told the Eighth Circuit on Tuesday.
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May 14, 2024
Solarium Sunbaths Not Tax-Free Wellness, Sweden Says
After receiving multiple questions about whether paying to sunbathe in a solarium is eligible for Sweden's tax-free wellness allowance, the country's tax agency said Tuesday that such activity is not eligible.
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May 14, 2024
Microsemi Calls IRS' Penalty Approval 'Woefully Inadequate'
An Internal Revenue Service supervisor's sign-off on a transfer pricing penalty for Microsemi was "woefully inadequate" to meet statutory requirements for penalty approval, the semiconductor manufacturer told the U.S. Tax Court.
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May 14, 2024
Aussie Budget Proposes Green Credits, Capital Gains Change
Australia would offer tax credits for hydrogen production and critical mineral mining and update its foreign resident capital gains tax rules as part of a proposed 2024-25 budget released Tuesday.
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May 14, 2024
British Industry Group Calls For Green Energy Tax Breaks
The U.K. needs to "outsmart rather than outspend" other countries to grow in the green energy sector, a British business advocacy group said, calling for the government to create a 40% so-called green innovation tax credit, among other tax breaks.
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May 14, 2024
Ex-Whiteford Taylor Business Co-Chair Joins Baker Donelson
Baker Donelson Bearman Caldwell & Berkowitz PC has welcomed a new shareholder who spent more than a decade with the Internal Revenue Service and previously co-chaired Whiteford Taylor & Preston LLP's business department, the firm announced on Monday.
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May 14, 2024
EU Finance Ministers Strike Deal On Withholding Tax Refunds
European Union finance ministers agreed Tuesday to a withholding tax refund law, as previous holdouts Poland and the Czech Republic withdrew their objections.
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May 14, 2024
EU Chair To Fight On For VAT Deal After Estonia's Rejection
The chair of the European Union's council of finance ministers said he will fight to get unanimous support for a wide-ranging reform of value-added tax rules after Estonia blocked agreement to the law Tuesday.
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May 14, 2024
Aussie Senate Faces Separation Of Promoter Penalty, Gas Tax
The Australian government is poised to double the penalty for corporate promoters of tax avoidance schemes, but it may first have to compromise by separating its bill from another one dealing with a tax on offshore gas exports, according to a legislative report.
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May 13, 2024
Corp. Transparency Act An Overbroad Dragnet, 11th Circ. Told
Congress exceeded its authority in passing the Corporate Transparency Act, which prompted the U.S. Treasury Department to solicit personal information for law enforcement purposes from those that registered and owned state-registered entities, a small-business group told the Eleventh Circuit on Monday.
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May 13, 2024
House GOP Bills Target Foreign Funding To Tax-Exempt Orgs
The House Ways and Means Committee will vote Wednesday on a package of bills that would increase scrutiny of foreign donations to tax-exempt organizations, including legislation that would require those organizations to publicly report the donations, the Joint Committee on Taxation announced Monday.
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May 13, 2024
Income Nixes Exxon's 'Final Loss' Deduction, Court Says
Exxon's Norwegian operation cannot deduct 900 million krone ($83.2 million) from its fiscal year 2012 taxable income that it spent liquidating an Exxon subsidiary in Denmark, a European court ruled Monday.
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May 13, 2024
2nd Circ. Won't Revive UBS Suit Over Disclosed Account Info
The Second Circuit declined Monday to revive a couple's suit accusing UBS of fraudulently flagging an account to the Internal Revenue Service, finding that any alleged harm resulting from an audit would have been caused by the agency itself.
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May 13, 2024
Int'l Authorities Want Increased Anti-Money Laundering Efforts
Countries need to do more to tackle the "huge illicit profits" being generated by international crime organizations and used for harmful practices such as funding terrorism, the heads of the Financial Action Task Force, Interpol and a United Nations group said Monday.
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May 13, 2024
Estonia Needs To Improve Property, Health Taxes, OECD Says
While Estonia has the lowest ratio of government debt to gross domestic product of any OECD country, it has numerous areas where it could improve its tax system, from broadening its tax base to increasing healthcare funding, the OECD said Monday.
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May 13, 2024
EU Initiative Pushes Bloc To Strengthen Carbon Taxing
The European Commission on Monday officially registered a citizen initiative to focus on accelerating the taxing of greenhouse gas emissions as well as making it more equitable, giving the group behind it a year to meet certain criteria that would force the European Union's executive arm to act.
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May 13, 2024
Houston Truck Co. Doesn't Owe $2M Excise Tax, 5th Circ. Told
A Houston truck company that sells tires made by a Chinese manufacturer doesn't owe $2 million in import taxes because it's not legally the tire importer, the company told the Fifth Circuit in asking it to affirm a ruling that could split circuits.
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May 13, 2024
Estonia Objecting To VAT Proposal On 'Neutrality' Grounds
Estonia is objecting to a proposed overhaul of European Union value-added tax rules because the proposal doesn't respect the principle of "neutrality," the country's finance minister said Monday, casting doubt on the fate of the proposal, which needs agreement by all 27 EU countries to pass.
Expert Analysis
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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.
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Inside The OECD Transfer Pricing Documentation Guidance
Excerpt from Practical Guidance
The Organization for Economic Cooperation and Development's recently modified documentation guidelines can assist tax administrations in developing requirements for transfer pricing risk assessments and evaluations, and help multinational entity taxpayers demonstrate satisfaction of the arm's-length principle, says Neil Aragones at Lexis Tax.
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A Close Look At The Decentralized Effort To Tax Digital Assets
Clarity on taxation is one of the biggest hurdles to mass adoption of cryptocurrency, and although digital asset innovation has consistently outpaced worldwide government regulation, recent efforts in the U.S. and elsewhere hint at an emerging standard, says Joshua Smeltzer at Gray Reed.
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Key Takeaways From IRS Reversal On FDII Stance
The Internal Revenue Service's recent memo regarding allocation of deferred compensation expenses for purposes of foreign-derived intangible income is a departure from the agency's previous position and may have implications beyond the context of deferred compensation, say attorneys at Miller & Chevalier.
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New Tax Decree Suggests Expansion In Dutch Transfer Pricing
A July 1 decree from Dutch tax authorities updating transfer pricing guidance heralds a major change in how intercompany financial transactions are considered for transfer pricing purposes and forebodes significant audit activity, say Monique van Herksen and Clive Jie-A-Joen at Simmons and Simmons.
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Is NJ's Voluntary Transfer Pricing Initiative Really Voluntary?
The New Jersey Division of Taxation's voluntary transfer pricing audit initiative promises penalty abatement to taxpayers that elect to participate and agree to the division's proposed adjustments, but the effective penalties associated with nonparticipation raise questions about the program's voluntary nature, say attorneys at McDermott.
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Global Tax Chiefs Should Look To US Whistleblower Programs
As the Joint Chiefs of Global Tax Enforcement develops its international whistleblower program to address tax evasion and money laundering schemes in new areas like cryptocurrency, it should take lessons from highly successful U.S. programs on which features to include and pitfalls to avoid, say Neil Getnick and Nico Gurian at Getnick & Getnick.
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What Microcaptive Reporting Ruling May Mean For The IRS
In CIC v. Internal Revenue Service, a Tennessee federal court’s decision to set aside an IRS requirement to disclose microcaptive insurance arrangements may be a step toward evidentiary standards to show that the potential for abuse in a lawful transaction is sufficient to support heightened disclosure requirements, says Samuel Lauricia at Weston Hurd.
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US Should Leverage Tax Rules To Deter Business With Russia
The U.S. should further restrict the flow of resources available for the Putin regime's war in Ukraine by denying U.S. businesses that operate in Russia or Belarus foreign tax credits and global intangible low-taxed income preferences, and by terminating its tax treaty with Russia, says Reuven Avi-Yonah at University of Michigan Law School.
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Justices Must Apply Law Evenly In Shadow Docket Rulings
In recent shadow docket decisions, the U.S. Supreme Court has inconsistently applied the requirement that parties demonstrate irreparable harm to obtain injunctive relief, which is problematic for two separate but related reasons, says David Hopkins at Benesch.
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US Investors Stand To Benefit From Brazil's New Forex Law
Brazil's New Foreign Exchange Law facilitates negotiations and reduces bureaucracy for foreign investments, making it a good time for U.S. investors looking for projects with a positive environmental, social and governance impact to allocate funds to Brazilian energy and infrastructure, say Jorge Kamine and Juliana Pimentel at Willkie.
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A Landmark UK Enforcement Case For Crypto-Assets
HM Revenue and Customs' recent seizure of nonfungible tokens from three people under investigation for value-added tax fraud promises to be the first of many such actions against crypto-assets, so investors should preemptively resolve potential tax matters with U.K. law enforcement agencies to avoid a rude awakening, says Andrew Park at Andersen.
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Simplifying Tax Issues For Nonresident Athletes In Canada
Tax compliance can be particularly challenging for nonresident professional athletes playing in Canada, but as NHL contract negotiations approach a close, it's worth looking at some ways the tax burden can be mitigated, say Marie-France Dompierre and Marc Pietro Allard at Davies Ward.