International
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March 19, 2024
UN Experts Aim To Finalize Tool For Model Treaty Updates
The United Nations' tax committee is aiming this week to finalize a tool to facilitate faster adoption of updates to its model tax treaty within bilateral negotiations, although some members remain skeptical about its usefulness, according to discussions Tuesday.
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March 19, 2024
GILTI Figures Into CFC Applicability Project, Official Says
The U.S. global intangible low-taxed income system is factoring into continuing Internal Revenue Service work on whether a tax code provision limiting corporations from offsetting income with net operating or other tax losses after ownership changes applies to controlled foreign corporations, an agency official said Tuesday.
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March 19, 2024
Pakistan Enlists Nonprofit To Boost Digital Tax Administration
Pakistan's tax authority said it is partnering with a nonprofit focused on business financing to help the government better understand businesses' needs as it works to improve online tax administration tools.
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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.
Expert Analysis
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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.
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Employers Should Consider Tax Impact Of Virus Relief Checks
The relief checks provided by the Coronavirus Aid, Relief, and Economic Security Act will introduce additional tax complications for companies with U.S. employees stationed abroad and foreign employees working in the U.S., says Richard Tonge at Grant Thornton.
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How OECD Reconciles Int'l Tax Laws And Work During COVID
The Organization for Economic Cooperation and Development’s guidance this month clarifying international tax law principles, such as permanent establishment, in light of coronavirus-related work disruptions was an unusual — but welcome — first step toward preventing potential tax disputes, say attorneys at Bonelli Erede.
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Proactive Tax Planning And The Next Stimulus Package
Attorneys at Skadden discuss outstanding tax issues that should be addressed if Congress enacts a fourth coronavirus relief package and provide strategies for modeling the tax impact of future losses under current law, including the recently enacted CARES Act.
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Leveling Tax Playing Field For Non-UK Resident Landlords
Starting Monday, non-U.K. resident landlords are subject to broadly the same U.K. tax treatment as residents with respect to income derived from U.K. property, and landlords and lenders should be considering the impact on transaction cashflows and covenant compliance, say James Spencer and Sherry Scrivens at Alston & Bird.