International
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June 21, 2024
Fed. Circ. Backs Subsidy Duties For Canadian Wind Towers
A Canadian wind tower manufacturer can't get a break on countervailing duties despite being upfront about errors in its sales data, with the Federal Circuit ruling Friday that the errors raise the possibility of additional mistakes.
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June 21, 2024
US Formally Suspends Part Of Tax Treaty With Russia
The U.S. government has provided formal notice to Russia suspending, via mutual agreement, parts of the countries' double-taxation treaty.
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June 21, 2024
Big 4 Continue Push For Broader Irish Dividend Exemption
The Big Four accounting firms reiterated support for Ireland's plans to implement a corporate tax exemption for foreign-sourced dividends and foreign branch profits, but they found the latest proposal still too narrow and complicated to qualify for, according to comments released Friday.
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June 21, 2024
Norway Seeking Feedback On Undertaxed Profits Rule
Norway is looking for feedback on a proposal that would implement the undertaxed profits rule, one component of the Organization for Economic Cooperation and Development's 15% corporate global minimum tax plan, the country's Finance Ministry said.
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June 21, 2024
OECD Official Sees Amount B Deal Helping With Amount A
The Organization for Economic Cooperation and Development is close to a final deal on a key part of its efforts to establish new international taxing rights under Amounts A and B of its Pillar One plans, according to the organization's tax chief.
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June 21, 2024
Taxation With Representation: Travers Smith, Potamitis Vekris
In this week's Taxation With Representation, RSK Group Ltd. gets a £500 million ($632 million) investment, Boston Scientific Corp. acquires Silk Road Medical Inc., Masdar takes a part of Terna Energy SA, and Tate & Lyle PLC buys CP Kelco from JM Huber Corp.
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June 21, 2024
EU Digital Tax Is Backup If Pillar 1 Stalls, French Official Says
Finalizing the Pillar One agreement to reallocate corporate taxing rights globally should remain a paramount goal, but if the effort stalls, the European Union should revive its plan for a digital tax of mostly U.S.-based tech giants, French Finance Minister Bruno Le Maire said Friday.
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June 21, 2024
Estonia Again Blocks Agreement On VAT Deal
For the second straight month, Estonia blocked agreement Friday on a European Union proposal for platform companies such as Airbnb, Uber and Estonia-based Bolt to collect value-added tax on behalf of service providers.
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June 21, 2024
Next UK Gov't Urged To Ease Private Healthcare Insurance Tax
Whoever wins the U.K. election on July 4 should introduce tax breaks on private medical insurance to relieve pressure on the National Health Service, a consultancy warned Friday.
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June 20, 2024
German Court Convicts 5 In €52M VAT Fraud In Cars, Masks
Five people who played roles in a value-added tax fraud scheme involving the trade of luxury cars and medical face masks that caused over €52 million ($55.7 million) in losses were convicted by a Berlin court, the European Public Prosecutor's Office announced Thursday.
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June 20, 2024
EU Court Rejects Co.'s Portuguese Tax Breaks Appeal
An appeal contesting a European Commission decision against a Portuguese tax exemption scheme was rejected by the European General Court, which found a Panama-based food company unable to prove why recovering the illegal state aid should be prohibited.
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June 20, 2024
China Denies Tax Crackdown As 2 Cos. Report $80M In Bills
China's tax authority denied a nationwide crackdown on companies' old tax returns Thursday, less than a week after a chemical firm facing 500 million yuan ($69 million) in additional liabilities halted production and a beverage maker reported owing 85 million yuan.
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June 20, 2024
UK Tax Pros Largely Support 2027 Carbon Border Tax Plan
Two groups representing tax professionals welcomed the U.K. government's plan to introduce a carbon border tax on certain carbon-intensive imports by 2027, but specifics regarding both default embedded emissions values and carveouts for smaller businesses must be ironed out, they said.
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June 20, 2024
Norway's $95M Yearly Dividend Tax Losses Spur Joint Audit
Norway's tax agency announced a joint audit with other Nordic tax agencies, saying it loses an estimated 1 billion kroner ($95 million) a year in withholding taxes that should be paid by foreign shareholders on dividends but aren't due to aggressive tax planning.
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June 20, 2024
Canada Lawmakers OK Digital Tax, Advance Min. Tax
Canada's Senate passed a 3% digital services tax that would target the revenue of large technology companies, following through on a plan that has drawn criticism from the U.S. and groups representing American tech giants.
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June 20, 2024
UK Tax Gap Continues Downward Trend, HMRC Says
The U.K. has continued to shrink its estimated tax gap, reaching a new low of 4.8% in the 2022-2023 tax year, following a trend of decreases over the past almost two decades, HM Revenue & Customs said Thursday.
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June 20, 2024
G20 Should Not Give Up On Pillar 1, Gentiloni Says
The Group of 20 rich and developing countries should not give up on the Pillar One agreement to reallocate corporate taxing rights globally, European Union tax commissioner Paolo Gentiloni said Thursday, pointing to a G20 summit in November as crucial.
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June 20, 2024
EU Adopts Sanctions On Russian LNG, Oil Tanker Fleet
The European Union agreed in principle Thursday on the 14th economic sanctions package against Russia since its war against Ukraine began, targeting liquefied natural gas, dual-use goods and technologies, and a fleet of oil tankers from non-EU countries.
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June 20, 2024
Repatriation Tax Doesn't Violate Constitution, Justices Rule
The U.S. Supreme Court upheld the 2017 federal tax overhaul's mandatory repatriation levy on Thursday, finding the measure applies to the earnings of foreign corporations with U.S. shareholders and therefore does not raise constitutional questions about taxing unrealized income.
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June 20, 2024
German Casino Tax Regime Is Illegal State Aid, EU Says
Germany's special tax system for public casino operators violates the European Union's law on state aid law, the bloc's executive branch and treaty regulator said on Thursday.
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June 19, 2024
EU Commission Tells France, Italy To Lower Budget Deficits
The European Commission told France, Italy and six other European Union countries to rein in their big budget deficits on Wednesday, although their governments can decide themselves on the details of spending cuts and tax hikes.
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June 19, 2024
Problems With VAT Law Still Not Resolved, Estonia Says
Estonia said Wednesday that it continues to have concerns about a proposed change to the European Union's value added tax law, which the small northeastern European country said would hurt small businesses.
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June 18, 2024
IRS Guidance Doesn't Perceive Spinoff Abuse, Official Says
Recent IRS guidance limiting the corporate spinoffs that revenue officials will approve as tax-free ahead of time was designed to reflect the drafters' current views, rather than suggest perceived abuse of these transactions, a U.S. Treasury Department official said Tuesday.
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June 18, 2024
AbbVie Says IRS Can't Treat $1.6B Break Fee As Capital Loss
The Internal Revenue Service cannot reclassify as a capital loss a $1.6 billion payment AbbVie made to an Irish biotechnology company after their failed merger and thereby raise the pharmaceutical giant's tax bill by $572 million, the company's attorneys told the U.S. Tax Court.
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June 18, 2024
Lithuania Legislature Approves Bank Windfall Tax Extension
The Lithuanian legislature voted to extend a temporary "solidarity tax" on bank profits through 2025, expecting to generate between €50 million ($53.7 million) and €70 million, it said Tuesday.
Expert Analysis
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Choosing A Branch Or Subsidiary For Overseas Expansion
Samuel Pollack and Naoko Watanabe at Baker McKenzie examine the corporate and U.S. tax law considerations involved in deciding whether a branch or subsidiary is the most efficient way to expand operations overseas, now that recent Treasury regulations clarified the complicated international tax regime created by the Tax Cuts and Jobs Act.
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Key Tax Concerns For Foreign Investors In US Private Equity
Paul D'Alessandro at Bilzin Sumberg examines important tax questions foreigners interested in U.S. private equity investments should ask in advance, including whether the investment will produce active or passive income, be subject to gains tax, and have U.S. estate tax consequences.
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Surveying Global Tax Updates For Sovereign Wealth Investors
As the market transitions to a post-pandemic phase, sovereign wealth fund and other foreign institutional investors must evaluate how recent U.S., EU and U.K. tax changes may affect their private fund investments, say attorneys at Morgan Lewis.
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Coke, 3M Tax Cases May Not Settle Blocked Income Debate
Even if the challenged U.S. Department of the Treasury regulation on blocked income is struck down by the U.S. Tax Court in the pending Coca-Cola and 3M cases, the obligations of a taxpayer that had, but failed to avail itself of, alternative means to secure payment will remain an open question, say Matthew Frank and Amanda Varma at Steptoe & Johnson.
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IRS Should Level The Field For R&D Tax Credits
A recent increase in denials of research and development tax credits to small businesses in the architectural, engineering and construction community shows the Internal Revenue Service should issue new guidance to ensure a fair playing field and an opportunity to continue innovating in the U.S., says Julio Gonzalez at Engineered Tax Services.
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Applying OECD Guidance On COVID-19 Transfer Pricing
In light of the recently released Organization for Economic Cooperation and Development's guidance on the transfer pricing implications of the pandemic, taxpayers should be prepared to explain and defend their transfer pricing decisions for fiscal year 2020 for contemporaneous documentation and in future tax audits, say Susan Fickling and TJ Michaelson at Duff & Phelps.
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Mitigate Key FCPA Risks With Tailor-Made Compliance
Multinational companies should take a pragmatic approach to Foreign Corrupt Practices Act compliance by being aware of key risk areas — such as inappropriate gift-giving, liability for third-party actions, and countries with recurring corruption issues — and implementing custom-designed procedures that evolve with their operations, says Howard Weissman at Miller Canfield.
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Tax Takeaways From India's Proposed Budget
Consultants at Deloitte discuss the tax implications of India's latest budget proposals, including the potential benefits for foreign portfolio investors and offshore funds migrating to India's new international financial services center, and the possible rise of M&A costs.
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A Tough Road Ahead for Democrats' Ambitious Policy Agenda
While Democrats in Congress are well on their way to enacting an initial COVID-19 relief bill, they will face challenges when pivoting to President Joe Biden's Build Back Better goals for job creation and economic revitalization, say Russell Sullivan and Radha Mohan at Brownstein Hyatt.
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Coca-Cola Tax Ruling Offers 5 Lessons For Multinationals
The U.S. Tax Court's decision that Coca-Cola owes more than $3.3 billion in taxes is instructive on important transfer pricing concepts, including those regarding intercompany agreements, the arm's-length standard and tax certainty, says Justin Radziewicz at Duff & Phelps.
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Start Preparing For Germany's Corporate Sanctions Act
Germany’s soon-to-be-adopted Corporate Sanctions Act carries a presumption of mandatory prosecution but also a defense in cases where reasonable precautions fail to prevent nonmanagers from committing crimes, so companies should start putting such compliance programs into place now, say attorneys at Arnold & Porter.
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Analyzing Illegality Defense Trend In Investor-State Arbitration
Cairn Energy v. India, a recent Permanent Court of Arbitration case, highlights the growing trend of states alleging illegal investor conduct to challenge tribunal jurisdiction or investor claim admissibility, say Caline Mouawad at Chaffetz Lindsey and Jessica Beess und Chrostin at Covington.
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Small Biz Should Self-Advocate For Tax Relief Under Biden
Small and medium-sized businesses have significant potential for achieving regulatory relief from the U.S. Department of the Treasury and other federal agencies during the Biden administration, but to do so they must define their priorities, leverage two federal statutes that require the Treasury to protect them and make their voices heard through communal e-advocacy, says Monte Silver at Silver & Co.