International
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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.
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March 21, 2024
Quintairos Prieto Taps Atlanta Atty To Lead New Tax Group
Quintairos Prieto Wood & Boyer PA said it had created a tax division that will be led by an Atlanta-based partner who has guided clients on civil and criminal tax law, reinforcing its national expertise in litigation, regulatory and corporate law matters.
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March 21, 2024
€58M VAT Toner Fraud Case Lands Four Convictions In Italy
Four people were convicted in Italy for their roles in a value-added tax fraud scheme involving printer toner and other office supplies that resulted in €58 million ($63 million) in illicit profits, the European Public Prosecutor's Office said.
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March 21, 2024
PwC Still Withholding Names Of Aussie Leak Recipients
PwC is continuing to refuse to name the six recipients of confidential drafts of Australian tax laws despite repeated requests from the country's government, the firm said in documents published Thursday.
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March 21, 2024
HSBC Settles Investors' £240M Claim Over Disney Tax Scheme
HSBC has settled a £240 million ($304 million) claim brought by more than 100 investors alleging that the bank misled them to finance a Disney film tax relief scheme it developed which turned out to be worthless.
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March 21, 2024
UK Insurance Tax Bill Rises To £8.1B Amid Soaring Premiums
The Insurance Premium Tax raised more than £8.1 billion ($10.3 billion) so far this financial year, according to official figures Thursday, while premiums continue to rise.
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March 21, 2024
ECJ Adviser Rejects Taxing Foreign Pension Funds Differently
Taxing dividends paid to foreign public pension funds while exempting dividends paid to the source country's general retirement savings funds contravenes European Union law, an adviser to the bloc's highest court said Thursday, backing Finnish pension funds' challenge of a Swedish law.
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March 20, 2024
IRS Releases Foreign Housing Expense Limits For 2024
The Internal Revenue Service released adjustments to the limitation on foreign housing expense deductions and exclusions for 2024 on Wednesday.
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March 20, 2024
EU Proposes Sending Russian Assets' Revenue To Ukraine
The European Commission proposed on Wednesday transferring the net income from frozen and immobilized Russian state assets to European Union funds for rebuilding Ukraine and buying arms for that country.
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March 20, 2024
How The Supreme Court Could Narrow Chevron
After hours of oral argument in a closely watched administrative law case, it appeared that some U.S. Supreme Court justices could be open to limiting the opportunities for lower courts to defer to federal agencies' legal interpretations in disputes over rulemaking — and legal experts said there are a number of ways they could do it.
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March 20, 2024
OECD Reports More Compliance With Tax Treaty Standards
The Organization for Economic Cooperation and Development reported Wednesday that members of the group's inclusive framework — countries that have agreed to adopt minimum standards of an international anti-base erosion plan — have increased their compliance with the standard intended to prevent treaty shopping.
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March 20, 2024
IRS Withholding Docs On Partnership Audits, Baker Atty Says
The Internal Revenue Service has not responded to a request for documents pertaining to the agency's scrutiny of large partnerships and should be forced to disclose them, an attorney with Baker McKenzie told a D.C. federal court.
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March 20, 2024
EU Floats Alternative To Unanimity As Bloc Eyes Growth
The European Commission floated an alternative Wednesday to unanimity voting on matters such as tax as it seeks to streamline the way the bloc reaches decisions amid talk of expanding the number of EU countries.
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March 20, 2024
IRS Grants Income Exclusion To Those Fleeing 6 Countries
Individuals who fled conditions in Ukraine, Belarus, Sudan, Haiti, Niger and Iraq after specific dates in 2023 can exclude foreign earned income, and can exclude or deduct housing costs, from gross income that year because of adverse conditions in the countries, the IRS said.
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March 20, 2024
Law360 Announces The Members Of Its 2024 Editorial Boards
Law360 is pleased to announce the formation of its 2024 Editorial Advisory Boards.
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March 20, 2024
King & Spalding Adds Ex-PwC Tax Pro As Partner In NY
An experienced tax attorney has joined King & Spalding LLP in New York after working at PricewaterhouseCoopers LLP for six years.
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March 20, 2024
HMRC Makes U-Turn On Helpline Cuts After Backlash
The U.K. tax authority backtracked Wednesday on plans to close down several helplines for taxpayers from April through September after facing criticism from politicians and industry groups.
Expert Analysis
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HSBC Suit Shows Challenge Of Designing Tax Relief Laws
Investors' recent lawsuit against HSBC over film-related tax avoidance schemes spotlights the difficult balancing act of crafting practical tax relief legislation while safeguarding against abuse, says Andrew Parkes at Andersen Tax.
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Regulatory Concerns For US Cos.' Offshore Service Centers
As more U.S. companies open and use offshore service-delivery centers amid the pandemic, assessment of important tax, intellectual property, cybersecurity and employment considerations can help mitigate regulatory risk and maximize the company's return on investment, says Sonia Baldia at Baker McKenzie.
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5 Biz Tax Reforms To Aid Long-Term Pandemic Recovery
As Congress negotiates another COVID-19 relief package, it should consider business tax measures that provide liquidity and encourage economic recovery by focusing budgetary resources on activities and circumstances connected to the pandemic and associated economic slowdown, says George Callas at Steptoe & Johnson.
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Altera Could Bolster State Transfer Pricing Scrutiny
The reasoning of the Ninth Circuit's Altera v. Commissioner decision — which the U.S. Supreme Court recently declined to review — could provide state tax authorities with an argument for additional discretion when challenging transfer pricing arrangements between affiliated entities, say attorneys at Eversheds Sutherland.
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10 Tips For A Successful Remote Arbitration Hearing
As I learned after completing a recent international arbitration remotely, with advance planning a video hearing can replicate the in-person experience surprisingly well, and may actually be superior in certain respects, says Kate Shih at Quinn Emanuel.
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VAT Cuts Won't Save Economies, Will Burden Businesses
Although value-added tax cuts may seem attractive for governments looking to stimulate economies in the wake of the pandemic, their implementation costs and inefficiencies can cause significant trouble for businesses, says Richard Asquith of Avalara.
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COVID-19 May Make Incomplete Contracts Renegotiable
Intercompany agreements on transfer pricing that do not include a pandemic eventuality might be argued to be incomplete from an economics perspective, providing justification for controlled parties to negotiate a remediation, say Robin Hart and Steven Schwartz at Charles River Associates.
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How To Handle Congressional Queries On COVID-19 Relief
Despite their informal nature, congressional inquiries regarding CARES Act implementation should not be taken lightly as these requests may be precursors to more formal and invasive investigations, say attorneys at Baker Donelson.
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Congress Must Create More Private Rights Of Action
In light of the Trump administration's efforts to limit the enforcement of regulations during the pandemic and beyond, and the U.S. Supreme Court's severe limitations on private rights of action, Congress must take swift action, says attorney Todd Phillips.
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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.