International
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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.
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April 04, 2024
Snell & Wilmer Adds Former McDermott Partner In Dallas
A former McDermott Will & Emery partner and tax specialist has joined Snell & Wilmer's Dallas office to advise clients on cross-border transactions, particularly in Latin America and Mexico.
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April 04, 2024
Companies In Limbo As IRS Mulls Waiver For 15% Book Tax
Corporations preparing for their quarterly estimated taxes are uncertain about paying a 15% alternative minimum tax due on April 15, since the Internal Revenue Service granted waivers last year and has yet to release proposed regulations that officials have promised since October.
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April 04, 2024
IRS Penalties Proper In $11B Amgen Dispute, Tax Court Says
The Internal Revenue Service properly authorized penalties included in a tax bill of nearly $11 billion that drugmaker Amgen is challenging, the U.S. Tax Court said Thursday.
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April 04, 2024
Ireland Would Need Big Tax Hike For Unification, Study Says
The costs of a theoretical reunification of Northern Ireland with the rest of Ireland would be between 5% and 10% of the country's gross national income, which would likely need to be made up with a "dramatic" increase in taxes, a study released Thursday said.
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April 04, 2024
Attys Awarded $1.5M In Fees On Tax Disclosure Suit
Attorneys who won a $4.5 million settlement for a class of investors claiming a Chinese startup misrepresented its tax liability will receive their requested $1.5 million in attorney fees, a New York federal judge ruled.
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April 04, 2024
Mayer Brown Adds Former KPMG Tax Specialist In London
Mayer Brown has added a former KPMG tax professional to its London office to advise clients on asset management and fund matters in the U.S., Europe and the Middle East, the firm announced.
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April 04, 2024
Singapore Co.'s Properties Transfer Ruled Capital Transaction
The transfer of properties between a Singapore company and a related company as part of a corporate restructuring would constitute a capital transaction, the country's Inland Revenue Authority said, making the swap tax-exempt.
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April 04, 2024
Parliament Committee Delaying Vote On EU Energy Tax Law
A European Parliament committee will delay a vote on a landmark energy taxation law, as it is unclear if a majority will back the measure, a European Union source familiar with the matter told Law360 on Thursday.
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April 04, 2024
Next EU Parliament Must Eye Tax Fairness, Lawmaker Says
The new European Parliament that is elected in June must continue to work on fairness in taxation, removing tax barriers to economic growth and scrutiny of international tax policies, the outgoing chair of the parliamentary tax subcommittee said Thursday.
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April 03, 2024
IRS Says $28M In Fines Against Microsemi Adhered To Rules
The Internal Revenue Service is again pressing the U.S. Tax Court to rule that it followed supervisory approval requirements when it imposed nearly $28 million in penalties against semiconductor manufacturer Microsemi in a transfer pricing dispute.
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April 03, 2024
McDermott Adds Ex-Baker McKenzie Tax Pro In Chicago
The former chair of Baker McKenzie's Chicago tax practice group has joined McDermott Will & Emery LLP and will work as a partner in the firm's Chicago office, McDermott said Wednesday.
Expert Analysis
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How Foreign Info Return Penalty Case May Benefit Taxpayers
The U.S. Tax Court's recent decision that the Internal Revenue Service cannot penalize taxpayers for failing to file foreign corporation information returns may give similarly situated taxpayers an opportunity to also avoid penalties, provided they protect their rights before the decision is overturned or mooted by legislation, say attorneys at Arnold & Porter.
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The Nuts And Bolts Of IRS Domestic Content Tax Credit
Recent IRS guidance provides specifics on how renewable energy projects can qualify for bonus tax credits by meeting U.S. domestic content rules, but also creates a qualification framework that will be complicated for project developers to navigate, say Scott Cockerham and Wolfram Pohl at Orrick.
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Taxing The Digital Economy: The Good, The Bad And The Ugly
U.S. tech companies should watch for important developments in international taxation, including the resolution of Apple's decade-old state aid case, growing frustration with the Organization for Economic Cooperation and Development's global tax plan and adoption of the digital services tax instead, says Joyce Beebe at Rice University's Baker Institute for Public Policy.
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Big Tax Changes For Multinational Cos. In Budget Proposal
The Biden administration’s fiscal year 2024 budget proposes changes that would materially alter decades-old Internal Revenue Code provisions, requiring a shift in multinational corporations' tax planning strategies comparable to that required after enactment of the Tax Cuts and Jobs Act, say Xenia Garofalo and Kyle Colonna at Eversheds Sutherland.
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Senate Credit Suisse Report Puts Attention On Banks, Trusts
The Senate Finance Committee's recent finding that Credit Suisse violated a plea agreement struck over its role in enabling offshore tax evasion has important ramifications for banks and trusts, including how they onboard, document and report on transactions relevant to U.S. reporting requirements, say Will Barry and Ian Herbert at Miller & Chevalier.
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Seeking IRS Accountability For Faulty Microcaptive Notice
Like the taxpayers in Standard Insurances v. U.S. seeking to expand earlier wins in microcaptive insurance cases that limit IRS use of improperly obtained information, others should consider ways to hold the agency accountable and provide incentive for it to follow the law going forward, says Joshua Smeltzer at Gray Reed.
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Biden Admin. Proposals Both Encourage And Thwart EV Adoption
While the Biden administration has been aggressively focused on promoting electric vehicles from the start, its recently issued guidance on EV tax credits and its restrictive new auto emissions proposal create a sense of implementation whiplash that may frustrate manufacturers and consumers, says Levi McAllister at Morgan Lewis.
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The Key Issues Keeping Transfer Pricing A Top Tax Concern
Several challenges preventing a global economic reemergence from the pandemic era are making practitioners reevaluate commonly used transfer pricing models, and embrace new technologies and ways of doing business, say Farnaz Amini and Sophia Castro Jurado at Marcum.
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Curtailing Offshore Tax-Advantaged Investment In China
The U.S. government's plans to establish a new outbound investment regime hold the potential to arrest Chinese companies' increasing use of offshore, tax-advantaged locations to raise capital, says David Plotinsky at Morgan Lewis.
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Cos. May Want To Wait Out US-EU Green Incentives Fight
As the European Union considers measures to compete with the Inflation Reduction Act's incentives for U.S. production of clean tech, and EU and U.S. officials discuss a possible compromise, companies in the green sector should consider taking a wait-and-see approach to investment decisions, says Todd Thacker at Goldberg Segalla.
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India's Budget Proposals May Ease Entry For Certain Sectors
India’s recently released budget includes proposals to facilitate doing business in Gujarat International Finance Tec-City and moderate thousands of compliance requirements, opening up new opportunities for foreign businesses in the digital infrastructure, manufacturing and renewable energy sectors, say Mukesh Butani and Seema Kejriwal at BMR Legal.
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High Court Ax Of Atty-Client Privilege Case Deepens Split
The U.S. Supreme Court's recent dismissal of In re: Grand Jury as improvidently granted maintains a three-way circuit split on the application of attorney-client privilege to multipurpose communications, although the justices have at least shown a desire to address it, say Trey Bourn and Thomas DiStanislao at Butler Snow.
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US-India Advance Pricing Resolutions Should Reassure Cos.
The United States' and India's tax authorities' recent resolution of a significant number of pending advance pricing agreements should reduce taxpayer uncertainty, reassure companies of the nations' good working relationship and improve India's investment environment, say Miller Williams and Caroline Setliffe at Eversheds Sutherland.