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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How Taxpayers Can Prep As Justices Weigh Repatriation Tax
The U.S. Supreme Court might strike down the 2017 federal tax overhaul's corporate repatriation tax in Moore v. U.S., so taxpayers should file protective tax refund claims before the case is decided and repatriate previously taxed earnings that could become entangled in dubious potential Section 965 refunds, say Jenny Austin and Gary Wilcox at Mayer Brown.
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OFAC Designation Prosecutions Are Constitutionally Suspect
Criminal prosecutions based on the Office of Foreign Assets Control’s sanctions-related listing decisions — made with nearly unfettered discretion through an opaque process — present several constitutional issues, so it is imperative that courts recognize additional rights of review, say Solomon Shinerock and Annika Conrad at Lewis Baach.
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How The OECD Global Tax Proposal Could Affect M&A
Following agreement on the Organization for Economic Cooperation and Development’s Pillar Two proposal to introduce a global minimum tax, domestic implementation is expected to have a significant impact on international M&A transactions, with financial modeling, deal structuring, risk allocation and joint venture arrangements likely to be affected, say lawyers at Freshfields.
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UK Shares-Tax Proposals Offer Long-Awaited Modernization
The U.K. government's recent consultation on the introduction of a new tax on transactions in securities raises detailed legal and practical issues, but the prospect of a single digital stamp tax offering both streamlined legislation and administration will be welcomed, say Zoë Arnautov and Mark Sheiham at Simmons & Simmons.
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IRS Foreign Tax Credit Pause Is Welcome Course Correction
A recent IRS notice temporarily suspending application of 2022 foreign tax credit regulations provides wanted relief for the many U.S. multinational companies and other taxpayers that otherwise face the risk of significant double taxation in their international operations, say attorneys at Mayer Brown.
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IRS Criminal Probe Spells Uncertainty For Malta Pension Plans
The IRS’ recent scrutiny of Malta pension plan arrangements — and its unusual issuance of criminal administrative summonses — confirms that it views many of these plans as illegal tax evasion schemes, and the road ahead will not be smooth and steady for anyone involved, say attorneys at Kostelanetz.
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IRS Announcement Will Aid Cos. In Buyback Tax Planning
Recent IRS transitional guidance regarding current requirements for reporting and payment of the stock repurchase excise tax will help corporate taxpayers make decisions about records retention and establishing reserves for future tax payments, say Xenia Garofalo and Kyle Colonna at Eversheds Sutherland.
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Flawed Analysis Supports Common Law Tax Deficiency Ruling
The Colorado federal district court’s recent decision in Liberty Global, holding that the U.S. Department of Justice may assert a common law tax claim without the notice of tax deficiency required by the Internal Revenue Code, relies on a contorted reading of the statute and irrelevant case law, say Loren Opper and Christie Galinski at Miller Canfield.
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Review Of Repatriation Tax Sets Justices On Slippery Slope
The U.S. Supreme Court’s recent decision to review the constitutionality of the repatriation tax in Moore v. U.S. has implications for many tax rules involving unrealized amounts and could leave the court on the brink of invalidating large swaths of the Internal Revenue Code, say attorneys at Eversheds Sutherland.
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What To Make Of IRS' New Advance Pricing Guidance
Recent guidance on the IRS' goals for its advance pricing agreement system provides helpful insight into review and decision-making procedures for advance pricing agreement requests, but it also raises questions about the IRS' objectives, say Richard Slowinski and Stefanie Kavanagh at Alston & Bird.
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Reserved Investor Fund Would Plug Gap In UK Finance Market
The reserved investor fund recently proposed by HM Treasury has the potential to be a welcome tax-efficient addition to the U.K.’s canon of products for real estate investments, with attractive features for companies and, in particular, large asset managers, say lawyers at Herbert Smith.
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The Reciprocal Tax Bill Is A Warning Shot At Pillar 2
A bill recently introduced in the House of Representatives to reciprocally tax countries deemed to have imposed discriminatory taxes on U.S. citizens and businesses takes aim at countries implementing the global minimum tax treaty known as Pillar Two, with which the U.S. has not complied, says Alan Cole at the Tax Foundation.
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What Tax-Exempt Orgs. Need From Energy Credit Guidance
Guidance clarifying the Inflation Reduction Act’s credit regime, expected from the U.S. Department of the Treasury this summer, should help tax-exempt organizations determine the benefits of clean energy projects and integrate alternative energy investments into their activities, say attorneys at Morgan Lewis.