International
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March 19, 2024
OECD Deputy Tax Director To Leave Post In June
A deputy tax director for the Organization for Economic Cooperation and Development announced he is stepping down from his position at the end of June after nearly a decade there working on international tax policy.
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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.
Expert Analysis
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Mitigating IRS Cryptocurrency Enforcement Risk In 2021
The IRS seems poised to shift focus in 2021 from education to enforcement of virtual currency tax laws, and noncompliant taxpayers should consider whether they are eligible to file amended returns or voluntary disclosures to mitigate the risk of civil penalties, criminal investigation or prosecution, say Don Fort and Lawrence Sannicandro at Kostelanetz & Fink.
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2020's Key Tax Controversy Developments
Andrew Roberson and Kevin Spencer at McDermott highlight 2020's key tax controversy developments, offering their perspective on important tax decisions, the Internal Revenue Service’s cooperative audit program, informal tax return amendment procedures, Large Business & International Division campaigns, and handling virtual appeals conferences during the pandemic.
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Justices Likely To Shield Treasury From Preemptive Action
Recent U.S. Supreme Court oral arguments in CIC Services v. Internal Revenue Service suggest the court will resolve a circuit split by ruling the Anti-Injunction Act shields the U.S. Department of the Treasury from preemptive challenges — bad news for those hoping to challenge unfavorable regulations, says Monte Silver at Silver & Co.
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Response Options For Danish Cum-Ex Interview Targets
As the Danish tax authority prepares for the first of a three-part U.K. trial involving cum-ex fraud, U.K. recipients of interview requests from the Danish prosecutorial agency should neither automatically accept, nor ignore the invitations, despite that agency's seeming lack of power to compel their attendance, says David Corker at Corker Binning.
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Advancing The Democratic Tax Agenda In 2021
Even with a divided government starting next year, Democrats will have a major effect on tax policy, pursuing legislative compromises and regulatory changes in service of President-elect Joe Biden's tax plan, and potentially reversing many Trump administration initiatives, say Russell Sullivan and Radha Mohan at Brownstein Hyatt.
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M&A Poised For Growth In The Biden Era
The M&A market is well positioned for recovery and growth under a Biden administration and divided Congress, which will likely gain control over the coronavirus pandemic, pass a stimulus package, and provide greater transparency in antitrust enforcement, say attorneys at Debevoise.
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Final BEAT Regs Still Contain Pitfalls For Taxpayers
Recently finalized U.S. Department of the Treasury regulations retain a taxpayer-friendly election allowing corporations to waive deductions to avoid the base erosion and anti-abuse tax, but neglect to include recourse for companies that waive more deductions than necessary, say attorneys at Ropes & Gray.
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Post-Election Tax Policy Scenario 3: A Divided Government
Attorneys at Brownstein Hyatt consider whether Democrats and Republicans will find common ground on tax policies and legislation regarding COVID-19 relief, domestic research and manufacturing, pension and retirement savings, foreign taxation of U.S. companies, and infrastructure development if the upcoming election results in a divided government.
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Post-Election Tax Policy Scenario 2: A Democratic Sweep
Russell Sullivan and Radha Mohan at Brownstein Hyatt consider former Vice President Joe Biden’s perspective that a better economy addresses income inequality, and the likelihood of passing specific tax measures in the event of a Democratic sweep, despite varying party perspectives.
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Post-Election Tax Policy Scenario 1: A Republican Sweep
Attorneys at Brownstein Hyatt analyze tax policies implemented by the Trump administration, such as the Tax Cuts and Jobs Act, and consider what will be on the agenda if Republicans gain full control of both the legislative and executive branches in the election.
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Defensive Strategies For High-Net-Worth Individual Tax Audits
When representing high-net-worth individuals in a tax audit, defensive strategies that cooperate with the examiner and respond to government requests should reflect the overarching goal of preserving client objections, privileges, limitations periods and any other rights in case there is future litigation, says Patrick McCann at Chamberlain Hrdlicka.
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Canadian Tax Ruling Signals Cross-Border Structure Security
After the Tax Court of Canada's recent ruling in AgraCity v. The Queen that the company's arm's-length tax arrangements with a foreign subsidiary were legitimate, and a similar result in a different matter, Canadian taxpayers can have confidence that their cross-border related party transaction structures will be upheld, says Matt Billings at Duff & Phelps.
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Preparing The Next Generation Of Female Trial Lawyers
To build the ranks of female trial attorneys, law firms must integrate them into every aspect of a case — from witness preparation to courtroom arguments — instead of relegating them to small roles, says Kalpana Srinivasan, co-managing partner at Susman Godfrey.