International
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April 10, 2024
Plastic Surgeon Owes $7.7M From Offshore Scheme, US Says
A now-retired plastic surgeon owes the Internal Revenue Service more than $7.7 million after he ran an offshore employee leasing scheme and he and his wife transferred nearly all their assets to their then-11-year-old daughter, who is now a lawyer, the government told an Ohio federal court.
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April 10, 2024
Australia's Tax Office Seeks Input On Risk-Weighted Assets
The Australian Taxation Office is seeking comments on a paper about how it measures the risk-weighted assets of a foreign bank's Australian branch when applying thin capitalization rules, the ATO announced.
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April 10, 2024
EU Parliament Wants Transfer Pricing Rules To Apply Sooner
The European Parliament voted Wednesday to adopt new transfer pricing rules that would take effect one year earlier than previously planned, sending the proposal to the European Union's council of member countries for consideration.
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April 10, 2024
IRS' DOJ Referral Rules 'A Disaster,' Sen. Whitehouse Says
The IRS protocols for referring cases to the U.S. Department of Justice are "a disaster" for enforcing laws against bankers and other actors who help U.S. taxpayers evade taxes, Sen. Sheldon Whitehouse said Wednesday during a hearing on offshore tax evasion before the Senate Budget Committee.
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April 10, 2024
Belgium's Anticipated Green Tax Break Carries Some Doubts
A proposal working its way through the Belgian Parliament would create opportunities for investors in green and sustainable technologies, but questions about the long-term durability of the measure, which would offer an expanded deduction for such investments, could weigh on its popularity and effectiveness.
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April 10, 2024
EU Gave €46B In State Aid As Tax Breaks In 2022
European Union countries gave their companies tax breaks worth about €46 billion ($49.4 billion) in state aid in 2022, some to weather the fallout from the Ukraine war and the COVID-19 pandemic and other aid to promote infrastructure projects or environmental protection, a European Commission report said.
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April 09, 2024
Treasury Proposes Long-Awaited Stock Buyback Tax Rules
The U.S. Treasury Department proposed a pair of long-awaited rules Tuesday that detail the calculation and reporting of a new excise tax assessed to publicly traded corporations that recently bought back their own shares of stock on the open market.
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April 09, 2024
Healthcare Co. Can't Sue Ex-Exec For Causing Canada Tax Hit
A Colorado federal judge shot down a pharmacy automation company's suit alleging its former chief commercial officer cost it nearly CA$1.2 million ($907,000) in Canadian taxes by not telling his employer he had moved out of the country, saying the company hasn't shown it suffered any damage as a result.
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April 09, 2024
Poland Adopts Digital Platform Reporting Rules
Poland's Council of Ministers approved a measure Tuesday implementing the European Union's tax information reporting procedures for digital platform operators, known as DAC7, the country's tax authority said.
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April 09, 2024
UK Court Affirms Sweet VAT Ruling For Jumbo Marshmallows
Jumbo-size marshmallows are not candy like regular marshmallows because they're meant to be roasted, so they qualify for a value-added tax exemption for food, the U.K. Upper Tribunal ruled in upholding a lower court's findings.
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April 09, 2024
BCLP Says It Had No Obligation To Man's Family In Tax Fight
Global law firm Bryan Cave Leighton Paisner was under contract to represent only a family's patriarch and thus shouldn't be liable for taxes resulting from advising him to transfer £242 million ($307 million) in assets to his wife, then to his sons, the firm told a London court.
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April 09, 2024
France, Luxembourg Extend Old Tax System To 2023 Income
French residents working in Luxembourg don't yet have to account for a new system for avoiding double taxation included in an updated treaty between the two countries, but there will a final extension for the previous system, the French finance ministry said Tuesday.
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April 09, 2024
Greece Adopts Global Minimum Tax Directive After Pressure
Greece has officially implemented the global corporate minimum tax spearheaded by the Organization for Economic Cooperation and Development, after being reprimanded this year by the European Commission.
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April 09, 2024
EU Lawmakers OK Revised Deal On Imports From Ukraine
European Union lawmakers agreed on a revised deal to extend the suspension of the bloc's customs duties and quotas on Ukrainian imports until June 2025 after some EU countries had rejected a previous deal.
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April 09, 2024
Adviser Group Wants Limitations Added To EU Disclosure Law
A group that represents tax advisers in Europe said Tuesday that it wants the European Union's executive branch to add limitations to a major disclosure law designed to combat cross-border tax evasion, saying the law puts too high a burden on them.
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April 09, 2024
Labour Party Pledges £5.1B Tax Crackdown If Elected
Britain's opposition Labour Party pledged Tuesday to raise £5.1 billion ($6.5 billion) by closing tax loopholes and cracking down on tax avoidance schemes if it wins the next election, expected later this year.
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April 08, 2024
Tax Court Upholds $11M In Foreign Reporting Penalties
The U.S. Tax Court on Monday mostly upheld $11 million in foreign reporting penalties against a man who admitted he hid money overseas, but the court declined to overturn its ruling that the IRS lacks authority to assess certain foreign reporting penalties.
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April 08, 2024
CPAs Want Treasury To Delay Beneficial Ownership Registry
The U.S. Department of the Treasury should delay enforcement of beneficial ownership information reporting requirements while courts hear cases challenging the Corporate Transparency Act, the American Institute of Certified Public Accountants and 54 state CPA societies said.
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April 08, 2024
Siblings Sentenced Over £1M UK Film Tax Fraud
Two brothers who fraudulently filed for more than £1 million ($1.3 million) in U.K. film and value-added tax refunds for movies actually made in the U.S. — and in one case, never existed — were each sentenced Monday to seven years in prison, HM Revenue & Customs said.
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April 08, 2024
EU Tax Single Filing Would Aid Small-Biz Trade, Official Says
A proposal allowing small businesses in the European Union to file a single tax return with the administration of the business' head office as opposed to with every member country where the entity does business would cut compliance costs and encourage trade, an EU official said.
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April 08, 2024
EU Expansion Question Shines Light On Tax Voting Procedure
The question of whether the European Union should expand beyond its current 27 member countries is putting the spotlight on the bloc's voting practices, raising concerns that the current unanimity requirement for tax policy changes would become unmanageable with a larger group.
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April 05, 2024
Monopolies Will Raise Prices Under Minimum Tax, Expert Says
The 15% global minimum tax will worsen the problems that monopolistic companies impose on economies because raising taxes on a company that lacks competition will lead it to raise prices, an academic expert on tax havens said Friday during a conference.
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April 05, 2024
Ireland Issues Example Of Dividend Exemption Proposal
The Ireland Department of Finance released a hypothetical example Friday to help guide further discussions on the country's planned implementation of a participation exemption from Irish corporation tax for foreign dividends.
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April 05, 2024
Irish Finance Dept. Seeks 2 Sovereign Funds For Tax Surplus
The Irish Department of Finance introduced a bill that would establish two sovereign wealth funds in Ireland as a way to take advantage of the country's surplus generated in part by corporate windfall taxes.
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April 05, 2024
Contrasts Emerge Between Taiwan Tax Bill, Regular Treaties
A bill pending in the Senate would lay the groundwork for double-tax relief and other treaty-like arrangements with Taiwan, but the unique legislative process and relatively reduced content could cast uncertainty over the unofficial accord's ultimate fate.
Expert Analysis
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Choosing A Branch Or Subsidiary For Overseas Expansion
Samuel Pollack and Naoko Watanabe at Baker McKenzie examine the corporate and U.S. tax law considerations involved in deciding whether a branch or subsidiary is the most efficient way to expand operations overseas, now that recent Treasury regulations clarified the complicated international tax regime created by the Tax Cuts and Jobs Act.
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Key Tax Concerns For Foreign Investors In US Private Equity
Paul D'Alessandro at Bilzin Sumberg examines important tax questions foreigners interested in U.S. private equity investments should ask in advance, including whether the investment will produce active or passive income, be subject to gains tax, and have U.S. estate tax consequences.
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Surveying Global Tax Updates For Sovereign Wealth Investors
As the market transitions to a post-pandemic phase, sovereign wealth fund and other foreign institutional investors must evaluate how recent U.S., EU and U.K. tax changes may affect their private fund investments, say attorneys at Morgan Lewis.
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Coke, 3M Tax Cases May Not Settle Blocked Income Debate
Even if the challenged U.S. Department of the Treasury regulation on blocked income is struck down by the U.S. Tax Court in the pending Coca-Cola and 3M cases, the obligations of a taxpayer that had, but failed to avail itself of, alternative means to secure payment will remain an open question, say Matthew Frank and Amanda Varma at Steptoe & Johnson.
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IRS Should Level The Field For R&D Tax Credits
A recent increase in denials of research and development tax credits to small businesses in the architectural, engineering and construction community shows the Internal Revenue Service should issue new guidance to ensure a fair playing field and an opportunity to continue innovating in the U.S., says Julio Gonzalez at Engineered Tax Services.
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Applying OECD Guidance On COVID-19 Transfer Pricing
In light of the recently released Organization for Economic Cooperation and Development's guidance on the transfer pricing implications of the pandemic, taxpayers should be prepared to explain and defend their transfer pricing decisions for fiscal year 2020 for contemporaneous documentation and in future tax audits, say Susan Fickling and TJ Michaelson at Duff & Phelps.
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Mitigate Key FCPA Risks With Tailor-Made Compliance
Multinational companies should take a pragmatic approach to Foreign Corrupt Practices Act compliance by being aware of key risk areas — such as inappropriate gift-giving, liability for third-party actions, and countries with recurring corruption issues — and implementing custom-designed procedures that evolve with their operations, says Howard Weissman at Miller Canfield.
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Tax Takeaways From India's Proposed Budget
Consultants at Deloitte discuss the tax implications of India's latest budget proposals, including the potential benefits for foreign portfolio investors and offshore funds migrating to India's new international financial services center, and the possible rise of M&A costs.
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A Tough Road Ahead for Democrats' Ambitious Policy Agenda
While Democrats in Congress are well on their way to enacting an initial COVID-19 relief bill, they will face challenges when pivoting to President Joe Biden's Build Back Better goals for job creation and economic revitalization, say Russell Sullivan and Radha Mohan at Brownstein Hyatt.
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Coca-Cola Tax Ruling Offers 5 Lessons For Multinationals
The U.S. Tax Court's decision that Coca-Cola owes more than $3.3 billion in taxes is instructive on important transfer pricing concepts, including those regarding intercompany agreements, the arm's-length standard and tax certainty, says Justin Radziewicz at Duff & Phelps.
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Start Preparing For Germany's Corporate Sanctions Act
Germany’s soon-to-be-adopted Corporate Sanctions Act carries a presumption of mandatory prosecution but also a defense in cases where reasonable precautions fail to prevent nonmanagers from committing crimes, so companies should start putting such compliance programs into place now, say attorneys at Arnold & Porter.
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Analyzing Illegality Defense Trend In Investor-State Arbitration
Cairn Energy v. India, a recent Permanent Court of Arbitration case, highlights the growing trend of states alleging illegal investor conduct to challenge tribunal jurisdiction or investor claim admissibility, say Caline Mouawad at Chaffetz Lindsey and Jessica Beess und Chrostin at Covington.
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Small Biz Should Self-Advocate For Tax Relief Under Biden
Small and medium-sized businesses have significant potential for achieving regulatory relief from the U.S. Department of the Treasury and other federal agencies during the Biden administration, but to do so they must define their priorities, leverage two federal statutes that require the Treasury to protect them and make their voices heard through communal e-advocacy, says Monte Silver at Silver & Co.