International
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May 29, 2024
Belgium Opens Pillar 2 Mandatory Reporting Form
Belgium's finance ministry opened Wednesday its mandatory notification system for entities in scope of its implementation of the Organization for Economic Cooperation and Development's global corporate minimum tax known as Pillar Two, starting a 45-day clock for such companies to register.
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May 29, 2024
Next UK Gov't Should Invest In Tax System, Pros Say
Improving the administration of the U.K. tax system should be a focus of the country's next government if it hopes to improve economic growth, a group representing tax professionals said, laying out issues that need to be addressed.
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May 29, 2024
IMF Report Suggests Germany Should Increase Taxes
Germany could consider increasing taxes to help pay for needed expenditures, an International Monetary Fund report said, adding that this would be a necessary complement to a more generous fiscal policy.
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May 29, 2024
Three EU Countries Urge Tax Reform To Boost Investment
Three smaller European Union countries, Austria, Croatia and Slovenia, are backing tax reforms in the 27-country bloc to support investment in capital markets, including exemptions from capital gains tax for long-term retail investment products, according to a joint declaration.
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May 28, 2024
Lithuania Seeks CJEU Ruling On Gaming Co.'s $1.1M Tax Bill
Lithuanian tax authorities have asked the Court of Justice of the European Union whether the past economic justification for a video game company's structure allows it to avoid €1 million ($1.1 million) in tax payments, according to court documents.
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May 28, 2024
Mich. Doctor Denied Release From Contempt In FBAR Fight
A Michigan doctor will stay jailed for civil contempt after a federal judge found Tuesday that he failed to back up claims that he cannot pay his more than $1 million in foreign bank account reporting penalties due to a bank's bankruptcy and his criminal history.
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May 28, 2024
Global Tax Body Provides Crypto Risk Assessment Red Flags
The Internal Revenue Service and four international tax authorities issued an advisory to financial institutions on the dangers of cryptocurrency in relation to tax evasion, money laundering and other illicit activities, identifying certain risk factors worth their attention.
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May 28, 2024
Tax Lawyer Rejoins Mayer Brown In DC From Latham
Mayer Brown LLP has rehired a tax partner from Latham & Watkins LLP, who joins the firm in Washington, D.C., to continue working with clients to best utilize renewable energy tax credits, the firm announced Tuesday.
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May 28, 2024
OECD Issues Voluntary Disclosure Program Guidance
The Organization for Economic Cooperation and Development issued guidance for tax administrations that are considering implementing voluntary disclosure programs before adopting the group's automatic information exchange standards.
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May 28, 2024
Moldova Joins OECD Fight Against Tax Avoidance
Moldova has joined the more than 140 jurisdictions looking to rein in tax base erosion and has committed to instituting changes in line with the Organization for Economic Cooperation and Development's anti-tax avoidance standards, the organization said in a news release Tuesday.
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May 28, 2024
9th Circ. Won't Touch IRS Bid For Tax Liability On Bookie
A bookie who pled guilty to helping run an illegal sports gambling ring out of Peru can't escape his ensuing $100,000 tax liability under a Ninth Circuit ruling that declined to expunge his conviction after he argued the taxes are disproportionately punishing.
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May 28, 2024
EU Needs Boost From New Incomes, Say Macron, Scholz
France and Germany want the European Union to find new revenue sources for the common EU budget, possibly from new taxes, to finance investments in joint projects, leaders of both countries said Tuesday.
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May 28, 2024
Greenberg Traurig Adds Tax Pro From MoFo In London
Greenberg Traurig LLP added to its deep bench of legal talent by recruiting a tax partner from Morrison & Foerster to join the firm's London office and co-chair its tax practice, the firm said.
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May 28, 2024
Labour Party Rules Out Any Additional Tax Rises
The Labour Party on Tuesday ruled out introducing any more tax rises in addition to measures it has already announced in the event it wins the July 4 general election.
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May 28, 2024
Lithuania Says Pillar 2 To Take Effect In July
Lithuania's law implementing the global minimum corporate tax known as Pillar Two, which aims to ensure large multinationals pay at least 15% tax, is expected to take effect in July, the country's Finance Ministry said Tuesday.
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May 27, 2024
G7 Moves Toward Using Frozen Russian Assets For Ukraine
Finance ministers from the Group of Seven countries made progress over the weekend on agreeing how to use profits from frozen and immobilized Russian state assets to support Ukraine's war against Russia, although European members had doubts about the arrangement.
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May 27, 2024
EU Flags 6 Countries For Failures On Transparency Law
The European Commission flagged six countries for deficiencies in its implementation of an EU law requiring some companies to publish their tax data, the EU's executive said in a news release.
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May 27, 2024
Fiji Joins International Framework Against Tax Avoidance
Fiji joined an international group of jurisdictions aiming to stop tax avoidance, the Organization for Economic Cooperation and Development said Monday, adding that the country would participate in the two-pillar solution to change tax rules for large multinational companies.
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May 24, 2024
Court Upholds Limit To Award In Ecopetrol, Texas Co. Dispute
An arbitration tribunal was within its authority to limit the number of years and the amount that a Houston-based oil company had to reimburse Colombia's state-owned entity, Ecopetrol, for the value-added tax liability of a subsidiary while owned by the company, a New York federal judge determined.
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May 24, 2024
CohnReznick Adds Tax Planning Partner From Mazars
CohnReznick LLP added a top accountant and tax partner from Mazars USA LLP to its roster of tax professionals, the firm announced.
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May 24, 2024
Global Minimum Tax Should Be Tied To Inflation, Report Says
The €750 million ($814 million) annual revenue threshold for businesses to be considered in scope of the OECD's global corporate minimum tax should be indexed to inflation to protect businesses from being wrongly forced to comply, a think tank report said.
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May 24, 2024
UK Calls On Belarus To Undo Suspension Of Tax Agreement
The U.K. is demanding that Belarus reverse a council resolution that suspends provisions of the double-taxation agreement between the two countries starting June 1, according to a statement released by HM Revenue & Customs.
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May 24, 2024
IRS Corrects Notice On Bonus Energy Tax Credit Safe Harbors
The Internal Revenue Service and U.S. Department of the Treasury issued a correction Friday to a notice providing additional safe harbors that clean energy project developers can use to qualify for bonus tax credits for domestically sourcing their steel and aluminum parts.
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May 24, 2024
€14M VAT Fraud Scheme In Belgium, Netherlands Busted
Seven people were arrested in the Netherlands in connection to a value-added tax fraud scheme involving the Belgian subsidiary of a Dutch company fraudulently claiming a €13.7 million ($14.9 million) refund on trades of goods that never happened, the European Public Prosecutor's Office said Friday.
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May 24, 2024
EU Withholding Tax Deal Lacks Ambition, Investors Say
A recently agreed-to streamlining of how cross-border withholding taxes are refunded in the European Union lacks ambition and may not do much to help smaller investors, investor advocates said.
Expert Analysis
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Let's End The Offshoring Of US Patents
Congress should work toward removing the loophole that allows companies to avoid U.S. taxes by moving their patents offshore, and ensure profits are taxed where the sales take place, says Sen. Patrick Leahy, D-Vt.
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Long Road Ahead For Biden's Individual Tax Hike Proposal
Dustin Stamper at Grant Thornton provides insight into President Joe Biden's recently proposed individual tax increases to pay for his American Families Plan, and explains how competing interests among congressional Democrats and Republicans may shape the final provisions and prolong their implementation.
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What Value-Added Tax Might Look Like In The US
Christiaan Van Der Valk and Charles Maniace at Sovos consider the value-added tax, a primary source of revenue for many countries, and what it might mean for the U.S. were it implemented to raise funds for large-scale federal initiatives such as President Joe Biden's infrastructure plan.
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US Needs Better, Nonpunitive Approach To Greening Trade
Instead of imposing tariffs on goods produced where foreign governments have assisted in cleaning up the environment, the U.S. should make trade policy green by helping industries reduce their environmental impact and encouraging every foreign government to do the same, say Elliot Feldman and Michael Snarr at BakerHostetler.
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What OECD Scrutiny Means For Anti-Corruption In Brazil
Attorneys at Paul Hastings examine how an unprecedented standing subgroup recently created by the Organization for Economic Cooperation and Development to monitor Brazil's anti-corruption efforts reflects significant uncertainty regarding the country's commitment to enforcement, and what companies can do to address foreign bribery risk and strengthen compliance programs.
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The International Outlook For US Border Carbon Adjustments
The Biden administration may see enacting a border carbon adjustment system as a good way to advance climate goals and protect domestic industries and jobs, but any such plan must take into account the need to respect existing international trade agreements, say attorneys at Akin Gump.
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The Domestic Landscape For US Border Carbon Adjustments
With the Biden administration possibly eyeing border carbon adjustments on imported goods as a means to mitigate climate change, attorneys at Akin Gump discuss such policies' potential benefits to domestic businesses, and the political and technical challenges to their enactment in the U.S.
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Prepare For Global Collaboration In Crypto Tax Enforcement
Recent Internal Revenue Service victories involving John Doe summonses served on cryptocurrency exchanges — and statements by the Joint Chiefs of Global Tax Enforcement about global collaboration in cryptocurrency-related tax investigations — should prompt assessment of prior virtual currency transactions and remediation before an enforcement agency shows up at the door, say attorneys at McDermott.
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10 Things to Know About US Competent Authority Assistance
Taxpayers should consider seeking U.S. competent authority assistance to help eliminate double taxation from a transfer pricing adjustment, especially now that the competent authorities are resolving cases virtually and more quickly, say attorneys at Thompson & Knight.
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US Advance Pricing Agreements, Amid COVID And Before
Steptoe & Johnson's Matthew Frank, former director of the U.S. Advance Pricing Agreement Program, shares insights from an Internal Revenue Service report revealing an uptick in APA completions amid the pandemic, discusses trends over the program's 30-year history, and suggests ways taxpayers and the IRS could bolster program participation.
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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.