International
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March 19, 2024
Exxon Wants Closed Court In $1.8B Tax Trial
Exxon Mobil plans to seek courtroom closures for parts of an upcoming trial in its $1.8 billion suit challenging denied tax deductions for payments it made to Qatar, telling a Texas federal court that certain testimony, if made public, would damage its relationship with the foreign partner.
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March 19, 2024
HMRC Under Fire For Sharply Cutting Back Helpline Service
The U.K. tax authority has moved too quickly to phase out helpline services for taxpayers filing self-assessment returns this year, members of Parliament said Tuesday.
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March 19, 2024
EU Parliament Committees Approve AML Laws
Two European Parliament committees approved new anti-money laundering legislation Tuesday for the European Union to create a single rule book for all 27 EU countries and to establish a common enforcement authority.
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March 19, 2024
Compliance Costs Call For Border Fee, France's Le Maire Says
The cost of compliance with European environmental rules justifies the European Union's recently launched carbon border tax, which is designed to raise the price of imports with lower environmental standards, French Finance Minister Bruno Le Maire said Tuesday.
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March 19, 2024
UK Energy Co. Fights To Deduct £2.5M Deal Advice Fees
An investment holding company told the Supreme Court on Tuesday that £2.5 million ($3.2 million) it paid to Deutsche Bank and others for deals advice is tax-deductible because they were the "type of services procured all the time."
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March 18, 2024
HMRC Defends Response To Tax Avoidance Ploy
The U.K. tax authority has rejected claims that it has been "heavy-handed" by applying the loan charge to users of disguised remuneration schemes, according to a letter released on Tuesday by the Treasury Committee.
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March 18, 2024
Australia Seeks Input On Revised Energy Tax Regulations
Australia's Department of the Treasury is seeking responses from the public to a draft of updated regulations for determining petroleum resource rent tax, the department announced Monday.
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March 18, 2024
Justices Won't Review Dead Film Exec's IRS Summons
The U.S. Supreme Court on Monday denied a request from the daughter of a dead film executive to consider invalidating an IRS summons for her father's financial records, letting stand a Ninth Circuit decision that found the agency sought the records in good faith.
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March 18, 2024
Treasury Mulling Whether To Keep Foreign Tax Credit Regime
The U.S. Treasury Department is considering whether the best way to provide administrable foreign tax credit rules and address related policy concerns is to retain the framework from paused final regulations or develop a new one, a Treasury official said Monday.
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March 18, 2024
Gov'ts Widely Back Building Capacity Of Tax Authorities
Building the skills and capacities of tax authorities to implement international tax standards should be a central focus of global tax cooperation at the United Nations for governments to gain revenue, officials from the U.S., the African Group and many others said Monday.
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March 18, 2024
Axed HMRC Staffer Wins £16K Disability Discrimination Case
HM Revenue and Customs must pay a disabled former employee £15,900 ($20,200) after it unfairly sacked him for gross misconduct and wrote off his claim that his sleep apnea was to blame, a Scottish tribunal has ruled.
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March 18, 2024
Wyden, Whitehouse Scrutinize DOJ's Caterpillar Investigation
Two top Democratic senators asked the U.S. Justice Department about its handling of a criminal inquiry into Caterpillar for potential financial crimes and corporate tax fraud after receiving evidence corroborating a report that former DOJ officials may have suppressed the investigation, according to a letter released Monday.
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March 18, 2024
FCA Levies £5.95M Fine In Fake Dividend Tax Reclaim Case
The Financial Conduct Authority said Monday it had decided to fine the former chief executive of Indigo Global Partners Ltd. £5.95 million ($7.57 million) and ban him from the industry for participating in a Danish tax scam that falsely reclaimed dividend taxes on shares.
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March 18, 2024
Serving Claims To HMRC By Email Made Permanent
Claimants pursuing legal action against the U.K. tax authority in England and Wales will continue to be able to serve documents by email, HM Revenue and Customs said Monday, making the process it introduced during the COVID-19 pandemic permanent.
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March 18, 2024
Polish Senate Committee Objects To EU BEFIT Proposal
A Polish Senate committee has objected to a new legislative proposal for corporate taxation in the European Union because it said it may lead to a loss of tax income and weaken the country's investment support programs.
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March 15, 2024
UAE Seeks Public Input On Global Minimum Tax
The United Arab Emirates is seeking public comments on implementing the global minimum tax under the OECD's tax reform plan, along with other tax issues, the country's Ministry of Finance announced Friday.
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March 15, 2024
France's Green Energy Investment Tax Credit Now In Effect
Companies operating in France's wind power sector and other clean energy industries will now be able to use the country's new green investment tax credit, the French finance ministry said Friday.
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March 15, 2024
Bechtel's Appeal Tossed In $8.5M Australian Tax Case
Bechtel Corp. must pay taxes of AU$13 million ($8.5 million) on costs of transporting employees to a worksite because the travel did not occur in the course of producing income, a Federal Court of Australia panel said Friday.
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March 15, 2024
The Tax Angle: House GOP Plots TCJA Renewal Strategy
House Republicans left Washington this week for their annual two-day legislative issues conference, hoping to expand their control of the chamber in the upcoming November elections and planning their strategy for renewal of their historic 2017 tax overhaul law.
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March 15, 2024
Tax Foundation Says UN Should Avoid Duplicating Tax Efforts
The United Nations should only create global tax rules in areas where it can effectively reduce uncertainty and should avoid duplicating negotiations underway elsewhere, the Tax Foundation said Friday in a response to the organization.
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March 15, 2024
Netherlands Enters Tax Treaty Talks With 3 More Countries
The Netherlands government announced plans to negotiate 13 tax treaties this year, including work on agreements with three new countries.
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March 15, 2024
Direct Hit On Tax Regs Unlikely If Justices Ditch Chevron
A decision from the U.S. Supreme Court later this year on two cases challenging the so-called Chevron doctrine, which gives federal agencies wide latitude to interpret ambiguous laws, isn't likely to immediately affect tax regulations.
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March 15, 2024
Colombia, Norway Aim To Harmonize UN And OECD Tax Work
Colombia and Norway are aiming to bring the best aspects of the OECD's tax work into negotiations at the United Nations while drafting a framework convention on global tax cooperation, officials said Friday during a conference in Paris.
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March 15, 2024
Taxation With Representation: Freshfields, Kirkland
In this week's Taxation with Representation, AstraZeneca acquires Amolyt Pharma, XCF Global Capital goes public and EQT Corp. merges with Equitrans Midstream Corp.
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March 15, 2024
Swiss Senate Votes Not To Consider Tonnage Tax
The upper house of the Swiss legislature has decided not to consider a tonnage tax proposal, choosing instead to follow the recommendation of a committee that last month recommended not taking up the measure.
Expert Analysis
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What The New OECD Double-Tax Procedure Statistics Tell Us
Monique van Herksen and Clive Jie-A-Joen at Simmons & Simmons consider the Organization for Economic Cooperation and Development’s recent report on double taxation cases resolved in 2020 under the mutual agreement procedure process, and examine whether the process has improved dispute resolution mechanisms since its implementation five years ago.
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Navigating FCPA Risks Of Minority-Owned Joint Ventures
The U.S. Department of Justice and U.S. Securities and Exchange Commission will likely continue to focus on third-party risks under the Foreign Corrupt Practices Act, so companies with minority-owned joint ventures should take several steps to mitigate related compliance challenges, say Ben Kimberley at The Clorox Company and Addison Thompson at Covington.
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Questions To Ask If Doing Business In A Corruption Hot Spot
Businesses facing new scrutiny after the U.S. Department of Justice's recently announced task force for combating human trafficking in Central America, the release of the Pandora Papers and continuing fallout from 2019's Panama Papers, should address compliance risks by having employees ask three questions about every transaction, say attorneys at White & Case.
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How The Global Tax Agreement Could Backfire For Biden
If the $3.5 trillion spending package fails, the federal tax code will not conform to the recent 15% global minimum tax agreement spearheaded by the U.S., which would embarrass the Biden administration and could lead to retaliatory tax measures by other nations, says Alex Parker at Capitol Counsel.
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Pandora Papers Reveal Need For Greater Tax Enforcement
The recent Pandora Papers leak is a reminder of the importance of transparency laws and proper funding for enforcement efforts against tax evasion as bad actors increasingly operate in the shadows, says Daren Firestone and Kevin Crenny at Levy Firestone.
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Parsing New Int'l Tax Reporting Rules For Pass-Throughs
Attorneys at Grant Thornton unpack the Internal Revenue Service’s new pass-through entity reporting requirements for international tax matters and the accompanying guidance for penalty relief, and suggest how companies should prepare for what may be the most significant change to the partnership compliance function in decades.
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A Look At Global Tax Enforcement Developments: Part 2
Excerpt from Practical Guidance
Sean Craig at LexisNexis examines recent investigations by the Joint Chiefs of Global Tax Enforcement and their impact on U.S. taxpayers, as well as the growing significance of transfer pricing disputes and policies for future enforcement.
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A Look At Global Tax Enforcement Developments: Part 1
Excerpt from Practical Guidance
Sean Craig at LexisNexis looks at how international initiatives, such as the Joint Chiefs of Global Tax Enforcement, are addressing cryptocurrency-related tax evasion, and how the COVID-19 pandemic and increasing demands for governmental welfare programs are driving global tax policy.
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EU Climate Plan Should Involve Taxing Pollution, Not Borders
In order to crack down on greenhouse gas emissions, the European Union proposes to levy carbon emissions at its borders and to overhaul its long-standing energy tax framework, but the latter would hold polluters directly accountable, giving it the better chance for success, says Rebecca Christie at Bruegel.
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Prepare For Global Tax Regime's New Biz Dispute Risks
Companies should take steps to mitigate the business dispute risks of the new international tax framework, which over a hundred countries agreed to in July, as implementing the new regime will be expensive and require substantial organizational restructuring efforts, says Tim McCarthy at Dykema.
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Prepare For More Audits Of Tax Info And Withholding Filings
Financial institutions and other corporate taxpayers should focus compliance efforts on tax information reporting and withholding, given recent indications from the Biden administration that the IRS will increase enforcement, and the administration's need to fund its infrastructure plan and other costly initiatives, say attorneys at Mayer Brown.
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Anti-Boycott Compliance Still Key In UAE Business Dealings
Notwithstanding recent amendments to U.S. anti-boycott laws that reflect the United Arab Emirates' withdrawal from the Arab boycott of Israel, companies doing business in the UAE and elsewhere still need to maintain effective anti-boycott compliance programs to avoid reporting violations or penalties, says Howard Weissman at Miller Canfield.
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9th Circ. Adds Pressure To Reject Substance Over Form
The Ninth Circuit’s recent decision rejecting taxes on a family's Roth IRA payments that were made through a foreign sales corporation represents a refreshing trend among federal appeals courts to reject substance-over-form principles and instead look to congressional intent, say Lawrence Hill and Caitlin Tharp at Steptoe & Johnson.