International
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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.
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April 05, 2024
UK Urges Delay In Claiming Pensions Until Rules Change
The U.K. tax authority has warned people to delay claiming their pensions until after Saturday, when the lifetime allowance is abolished, while the government clarifies technical changes to the legislation.
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April 05, 2024
EU Executive To Probe Complaint About Hungarian Retail Tax
The European Commission will look into a complaint it received about a Hungarian tax on the retail sector, the European Union's executive branch confirmed Friday.
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April 05, 2024
18 Crime Gangs Specialize In VAT Fraud, Europol Says
Eighteen major criminal gangs in the European Union specialize in value-added tax fraud, having end-to-end control over the entire criminal process, the EU's law enforcement agency said Friday.
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April 05, 2024
Taxation With Representation: Latham, Simpson Thacher
In this week's Taxation with Representation, Endeavor and Nuvei each go private, SLB purchases ChampionX and Liberty Media Corp. buys Dorna Sports SL.
Expert Analysis
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El Salvador's Use Of Bitcoin Complicates US Commercial Law
El Salvador recently became the first country to recognize Bitcoin as currency, presenting significant implications for U.S. commercial law as the development will likely trigger the cryptocurrency to now fall within the definition of "money" under the Uniform Commercial Code, say Joe Carlasare and Eric Fogel at SmithAmundsen.
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Justices' Nod To Preemptive Tax Challenges May Caution IRS
The U.S. Supreme Court's recent decision in CIC Services v. Internal Revenue Service, allowing pre-enforcement challenges of tax reporting rules despite the Anti-Injunction Act, is likely to make the U.S. Department of the Treasury more careful about its own compliance obligations under the Administrative Procedure Act, says Robert Carney at Caplin & Drysdale.
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Let's End The Offshoring Of US Patents
Congress should work toward removing the loophole that allows companies to avoid U.S. taxes by moving their patents offshore, and ensure profits are taxed where the sales take place, says Sen. Patrick Leahy, D-Vt.
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Long Road Ahead For Biden's Individual Tax Hike Proposal
Dustin Stamper at Grant Thornton provides insight into President Joe Biden's recently proposed individual tax increases to pay for his American Families Plan, and explains how competing interests among congressional Democrats and Republicans may shape the final provisions and prolong their implementation.
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What Value-Added Tax Might Look Like In The US
Christiaan Van Der Valk and Charles Maniace at Sovos consider the value-added tax, a primary source of revenue for many countries, and what it might mean for the U.S. were it implemented to raise funds for large-scale federal initiatives such as President Joe Biden's infrastructure plan.
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US Needs Better, Nonpunitive Approach To Greening Trade
Instead of imposing tariffs on goods produced where foreign governments have assisted in cleaning up the environment, the U.S. should make trade policy green by helping industries reduce their environmental impact and encouraging every foreign government to do the same, say Elliot Feldman and Michael Snarr at BakerHostetler.
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What OECD Scrutiny Means For Anti-Corruption In Brazil
Attorneys at Paul Hastings examine how an unprecedented standing subgroup recently created by the Organization for Economic Cooperation and Development to monitor Brazil's anti-corruption efforts reflects significant uncertainty regarding the country's commitment to enforcement, and what companies can do to address foreign bribery risk and strengthen compliance programs.
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The International Outlook For US Border Carbon Adjustments
The Biden administration may see enacting a border carbon adjustment system as a good way to advance climate goals and protect domestic industries and jobs, but any such plan must take into account the need to respect existing international trade agreements, say attorneys at Akin Gump.
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The Domestic Landscape For US Border Carbon Adjustments
With the Biden administration possibly eyeing border carbon adjustments on imported goods as a means to mitigate climate change, attorneys at Akin Gump discuss such policies' potential benefits to domestic businesses, and the political and technical challenges to their enactment in the U.S.
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Prepare For Global Collaboration In Crypto Tax Enforcement
Recent Internal Revenue Service victories involving John Doe summonses served on cryptocurrency exchanges — and statements by the Joint Chiefs of Global Tax Enforcement about global collaboration in cryptocurrency-related tax investigations — should prompt assessment of prior virtual currency transactions and remediation before an enforcement agency shows up at the door, say attorneys at McDermott.
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10 Things to Know About US Competent Authority Assistance
Taxpayers should consider seeking U.S. competent authority assistance to help eliminate double taxation from a transfer pricing adjustment, especially now that the competent authorities are resolving cases virtually and more quickly, say attorneys at Thompson & Knight.
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US Advance Pricing Agreements, Amid COVID And Before
Steptoe & Johnson's Matthew Frank, former director of the U.S. Advance Pricing Agreement Program, shares insights from an Internal Revenue Service report revealing an uptick in APA completions amid the pandemic, discusses trends over the program's 30-year history, and suggests ways taxpayers and the IRS could bolster program participation.
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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.