International
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March 26, 2024
Ex-Glencore Exec Owes Income Tax On £150M In Dispersals
Glencore's former head of oil is liable for income tax on nearly £150 million ($189 million) in distributions he received as a profit participation shareholder in the Jersey company because they're considered dividends under U.K. law, according to an Upper Tribunal decision.
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March 26, 2024
US EV Subsidies Discriminatory, China Tells WTO
Domestic production rules for U.S. electric vehicles to qualify for subsidies under the Inflation Reduction Act are discriminatory, the Chinese Ministry of Commerce said Tuesday, announcing it had filed a complaint with the World Trade Organization.
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March 26, 2024
Decision Postponed On EU Withholding Tax Proposal
An attempt by European Union finance ministers to agree on a new withholding tax refund law has been postponed from their meeting on April 12, an agenda published Tuesday showed.
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March 25, 2024
Philippines Plastic Bag Tax Would Generate $560M, Gov't Says
A proposed weight-based tax on single-use plastic bags would catch the Philippines up with major economies and generate an estimated 31.52 billion Philippine pesos ($560 million) in its first three years, the country's Department of Finance said Monday.
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March 25, 2024
Nigeria Charges Binance With Tax Evasion, Says Exec Fled
Nigeria's tax authority filed criminal tax evasion charges against Binance, one of the world's largest cryptocurrency exchanges, and two of its executives, one of whom escaped custody Monday, according to state-owned media.
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March 25, 2024
€92M Cross-Border Fuel VAT Fraud Case Under Investigation
Authorities are investigating three Italian citizens based around the world for their roles in a value-added tax fraud scheme involving oil sales that led to an estimated €92 million ($99.7 million) in damages, the European Public Prosecutor's Office said Monday.
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March 25, 2024
Offshore Payments Aren't Taxable Services, UK Court Rules
Two U.K. residents aren't liable for taxes tied to certain payments from an affiliated offshore company to a third-party foreign corporation, a British appeals court ruled Monday, finding the underlying transactions didn't amount to services that would trigger taxation.
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March 25, 2024
EU Court Asked To Rule On VAT On Transfer Pricing Payment
A Romanian appellate court asked the European Union's Court of Justice to rule on whether payments to a Belgian parent company from a Romanian associated company to align profits under OECD transfer pricing guidelines fall within the scope of value-added tax, a document published Monday showed.
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March 25, 2024
PwC Australia Hires New Chief People Officer Amid Scandal
PwC Australia hired a new chief people officer as part of the firm's plan to rebuild trust following its scandal involving the leak of Australian government documents, the firm announced Monday.
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March 25, 2024
EU Report Praises Dutch Efforts To Stop Tax Avoidance
Recent efforts in the Netherlands to tackle corporate tax avoidance are working, according to a report from the European Commission published Monday, which added that a new measure taking effect this year would help make the Netherlands less attractive for tax avoidance practices.
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March 22, 2024
Businessman Indicted Over Hiding Of $20M In Swiss Accounts
A Brazilian-American businessman accused by the government in a criminal complaint of hiding $20 million from the Internal Revenue Service over 35 years by using Swiss bank accounts was indicted by a federal grand jury in Miami and charged with tax evasion, according to a Florida federal court.
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March 22, 2024
UN Needs To Clarify Path For Tax Framework, Dutch Say
The United Nations' ad hoc committee tasked with determining a global tax framework must clarify the goals of its project "as soon as possible," the Netherlands' government said in a letter that included suggestions on how the body could proceed.
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March 22, 2024
Holland & Knight Hires Caplin & Drysdale Member In DC
Holland & Knight LLP has boosted its Washington-based tax team, hiring a Caplin & Drysdale Chtd. member who first joined his former firm 25 years ago from the U.S. Department of the Treasury.
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March 22, 2024
EU Leaders OK Sending Russian Assets' Revenue To Ukraine
European Union leaders expressed support for a proposal to transfer the net income from frozen and immobilized Russian state assets to EU funds for rebuilding Ukraine and buying arms for that country, according to a statement issued Friday.
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March 22, 2024
UK Tax Avoidance Scheme Promoter Fined £900K
A Liverpool-based company that promoted a tax avoidance scheme to medical professionals must pay a £900,000 ($1.1 million) penalty, according to a tribunal ruling published by HM Revenue and Customs on Friday.
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March 22, 2024
US Unlikely To Move On Hungary Tax Treaty, Official Says
Hungary's low corporate tax rate and other policies will likely prevent the U.S. government from resuming negotiations on a stalled 2010 tax treaty after terminating its existing Hungarian treaty in early 2023, an IRS official said Friday.
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March 22, 2024
UK Seeking Feedback On 2027 Carbon Border Tax Plan
HM Revenue & Customs and HM Treasury are seeking feedback on the U.K.'s plan to introduce a carbon border tax on certain carbon-intensive imports by 2027.
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March 22, 2024
EU Leaders Seek Limited Tax Revamp To Boost Capital Market
European Union leaders urged all bloc policymakers Friday to pursue a plan to improve business financing, including a targeted makeover of the tax systems in the member countries regarding corporate taxes, capital gains and tax breaks for interest payments.
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March 21, 2024
Treasury Hoping Pillar 2 Guidance Favors R&D Tax Credits
The U.S. Treasury Department is looking for future administrative guidance on the international minimum tax agreement known as Pillar Two to give favorable treatment to U.S. research and development tax credits, but it will likely come with guardrails, a Treasury official said Thursday.
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March 21, 2024
GoDaddy Can't Block Transfer Of $4 Million Set Aside For VAT
A consortium that sold shares of an internet company to GoDaddy.com can receive a $4 million transfer of escrow funds that GoDaddy claimed were instead needed to pay value-added tax on the share sale, a Dutch court ruled.
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March 21, 2024
UN Could Enhance Global Tax Agenda Setting, Officials Say
The United Nations could play an important role in shaping the agenda for global tax negotiations so it better reflects the priorities and concerns of developing countries, a variety of tax officials said Thursday during a conference.
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March 21, 2024
IRS Proposes Exceptions For 3rd-Party Summons Notices
The IRS proposed rules Thursday that would allow some exceptions to a requirement that the agency notify taxpayers within 45 days before issuing summonses to third parties in tax assessment and collection cases, including for certain time-sensitive examinations.
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March 21, 2024
EU Countries Bash Deal On Duty-Free Imports From Ukraine
Several European Union countries objected to the agreement among EU lawmakers to extend the suspension of the bloc's custom duties and quotas on Ukrainian imports, criticizing a lack of caps on agricultural products.
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March 21, 2024
Australia Seeking Input On Global Minimum Tax Bills
Australia's Treasury is seeking public feedback on three draft bills published Thursday that would implement the Organization for Economic Cooperation and Development's global corporate minimum tax.
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March 21, 2024
Wyden Probes Swiss Bank's Ties To Billionaire Under Scrutiny
The Senate Finance Committee's Democratic majority launched an inquiry into Swiss bank Pictet Group's involvement with a U.S. billionaire under criminal investigation, raising questions about the bank's deferred prosecution agreement and $123 million fine by the U.S. Justice Department, committee Chairman Ron Wyden announced Thursday.
Expert Analysis
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2008 Recession Offers Lessons For COVID-19 Transfer Pricing
Tax directors at multinational companies can look to a post-Great Recession profitability analysis of distributors, manufacturers and service companies for guidance on transfer pricing in the current economic environment, says Alan Alford at Bates White.
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Multinationals Should Review Their Transfer Pricing Methods
Tax directors should review their transfer pricing methods for 2020 as the relatively simple way that traditional models allocate risk and profit for tax purposes may exacerbate the financial effects of the pandemic on multinational corporations, say managing directors at Duff & Phelps.
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NOL Carryback Rule Changes Bring Benefits For M&A Parties
New federal tax rules in the CARES Act, allowing the use of net operating loss carrybacks, bring previously unavailable tax benefits and negotiation opportunities for parties to mergers and acquisitions, say attorneys at Polsinelli.
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Pandemic Elevates Cos.' Compliance Risks In Latin America
While Latin American governments respond to pandemic-related financial needs, multinational companies face elevated compliance risks from increased interaction with government officials, and new enforcement policies related to the misappropriation of funds, expedited government contracting, increased transparency and monitoring, and international cooperation, say attorneys at K&L Gates.
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Distressed Debt Tax Opportunities For Foreign Investors
Foreign investors can earn tax-free interest income on distressed debt issued by U.S. companies, as long as they steer clear of income classification pitfalls, says Seth Entin at Holland & Knight.
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Pandemic Complicates OECD Digital Tax Overhaul
The Organization for Economic Cooperation and Development's decision last week to extend the deadline for a digital economy tax rewrite highlights novel pandemic-prompted issues that will need to be resolved, including the treatment of losses and an ideological debate between pro-growth and revenue-focused policies, says Joyce Beebe at Rice University.
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Tips For Non-US Entities Facing Tax ID Processing Delays
Non-U.S. entities applying for taxpayer identification numbers during the pandemic, while IRS phone and fax lines are inoperative and mail processing is on hold, may need to employ alternative strategies to open bank accounts and meet tax filing requirements, say David Shapiro and Shane Hoffmann at Fried Frank.
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Adapting 2020 Tax Expectations To COVID-19 Developments
Attorneys at Steptoe & Johnson consider unexpected international, federal and state tax developments that have occurred in response to the global pandemic, how they may impact individuals and corporations, and what measures may follow.
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Key Tax Considerations For Secondary Sales Of Private Funds
Investors considering selling fund interests in the secondary market to create liquidity during the pandemic-related economic crisis should consider several tax and structuring issues that can impact the buyer, seller and the underlying fund, say attorneys at Mayer Brown.
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Safeguarding Foreign Investments During A Pandemic
Investment agreements can protect foreign holdings when governmental measures in response to COVID-19 are overly restrictive, unnecessarily protracted or discriminatory, say attorneys at Ropes & Gray.
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Calculating Credit Spreads During A Pandemic
Given the coronavirus-induced spike in credit spreads and the heightened regulatory scrutiny of intercompany financing, multinationals with significant debt should carefully review the arm's-length interest rates in their loan agreements to avoid double taxation, says economist Harold McClure.
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10 Insights Into IRS Audits And Appeals Amid COVID-19
Crowell & Moring attorneys David Fischer and Teresa Abney consider the top 10 things taxpayers and practitioners need to know about a series of recently issued Internal Revenue Service notices and employee memos addressing audit and appeals procedure during the pandemic.
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Allocating Loss When COVID-19 Disrupts Your Supply Chain
Multinational enterprises experiencing coronavirus-related supply chain disruptions should take a few immediate steps to determine which entities should bear the losses of these disruptions for tax purposes, say Richard Slowinski and Stefanie Kavanagh at Alston & Bird.