International
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August 23, 2024
HMRC Can Be Liable For Damage To Biz Shut Over £7.4M Debt
The tax authority cannot lift a court order that requires it to repay a payroll business damages for losses suffered after it was put into provisional liquidation, as a court found on Friday that it had failed to pursue that action for law enforcement purposes.
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August 22, 2024
Switzerland Expects 3.2% Tax Receipt Increase In 2025
Switzerland expects to generate 85.7 billion Swiss francs ($100.6 billion) in tax receipts in 2025, an increase of 3.2% over the 2024 budget, with the biggest growth projected to come from personal income taxes, the country's Federal Finance Administration said Thursday.
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August 22, 2024
Kenya's Justices May Ax Part Of Tax Act That Set Off Unrest
The Supreme Court of Kenya agreed to stay a lower court's ruling declaring unconstitutional the government's entire 2023 tax package, which sparked deadly nationwide protests, but it looks likely to scrap at least part of the law next month, attorneys told Law360 on Thursday.
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August 22, 2024
Australian Legislators Advance Enactment Of Global Min. Tax
Australia would enact the Organization for Economic Cooperation and Development's 15% global corporate minimum tax on large multinational entities, known as Pillar Two, under three bills passed Thursday by the country's House of Representatives.
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August 22, 2024
EU Decision Keeps Tax Relief For UK Investment Schemes
The European Commission will allow U.K. government-backed programs that encourage private investment in small companies to continue offering favorable tax terms for investors, according to a decision published Thursday.
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August 22, 2024
Ryanair Threatens Service Cuts Over German Tax Increase
Irish discount airline Ryanair said it will cut 10% of its German capacity next summer if the country doesn't reverse a recent 24% increase in its aviation tax, calling on Germany to ultimately abolish the tax altogether.
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August 22, 2024
Over 3M UK Pensioners To Be Dragged Into Higher Tax Rates
Government data shows 3.1 million U.K. pensioners will be dragged into paying higher taxes in the next four years due to the freeze on income thresholds, financial firm Quilter PLC said Thursday.
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August 21, 2024
Ariz. Man Should Pay Full $2.7M FBAR Bill, Gov't Says
An Arizona man who failed to report his foreign bank accounts in Switzerland owes approximately $2.7 million in recalculated penalties and interest to the Internal Revenue Service, the U.S. told an Arizona federal court.
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August 21, 2024
UK Tax Collection Rises 5% To £829B
HM Revenue & Customs said Wednesday that the U.K. raised over £829 billion ($1.09 trillion) in taxes in fiscal year 2023-2024, up over 5% from the previous year.
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August 21, 2024
9th Circ. Upholds FBAR Penalty, Imposes Contested Interest
A woman who operates a New Zealand winery must pay $238,000 in penalties and an extra $105,000 in interest and fees for failing to report her New Zealand financial accounts to the U.S. government, the Ninth Circuit ruled Wednesday.
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August 21, 2024
3 Questions Raised By Harris' Support For 28% Corp. Tax Rate
Vice President Kamala Harris has proposed increasing the corporate tax rate to 28% to boost revenue if she's elected president, but the proposed hike raises questions about changes to the corporate tax base, the future of the OECD's global tax deal and the potential impact on workers.
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August 21, 2024
Pros Tell IRS To Ease Off Foreign Gift Reporting Penalties
The Internal Revenue Service should take a more lenient approach when considering penalty abatements for certain individuals who fail to report large foreign gifts under proposed disclosure regulations, practitioners told the agency Wednesday.
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August 21, 2024
New Zealand Seeks Feedback On Future Of Tax System
New Zealand's revenue agency is looking for feedback on plans for a potential broad restructuring of the country's tax system in order to address coming financial pressures, including possibly altering its income and consumption tax regimes, it said Wednesday.
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August 21, 2024
Swiss Council Approves Tax Treaty With Jordan
Switzerland's Federal Council approved a treaty Wednesday to avoid double taxation with Jordan that it says largely follows the Organization for Economic Cooperation and Development's model convention for such agreements.
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August 21, 2024
Swiss Extend Tax Exemptions For 'Too Big To Fail' Instruments
Switzerland's Federal Council decided Wednesday to extend temporary withholding tax exemptions on interest for what it calls too-big-to-fail instruments for banks, such as bail-in or write-off bonds.
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August 21, 2024
Germany Opens Consultation On Min. Tax Reporting Changes
Germany's Federal Ministry of Finance is seeking feedback on a proposal to incorporate updated guidance from the Organization for Economic Cooperation and Development regarding reporting requirements associated with the global corporate minimum tax.
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August 21, 2024
VAT Fraudster Loses Bid To Escape Repaying £1.4M
A man involved in a £40 million ($52 million) criminal tax fraud scheme has lost a bid to avoid repaying £1.4 million as a London court ruled on Wednesday that he had failed to prove he no longer had hidden assets.
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August 20, 2024
UN Dives Into Murky Waters Of Taxing Digital Services
The United Nations has its sights set on cross-border services in the digital economy as its framework convention on tax takes shape, but it remains unclear how countries will define that broad and hotly contested topic as they work toward a treaty.
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August 20, 2024
Temple Law Prof, Kostelanetz Atty To Lead ABA Tax Section
A longtime professor at the Temple University Beasley School of Law and a seasoned tax controversy partner at Kostelanetz LLP will together helm the American Bar Association Section of Taxation for the 2025-2026 term, the firm announced Tuesday.
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August 20, 2024
IRS Tax-Exempt Compliance Unit Work Too Slow, TIGTA Says
A decision to expand the scope of checks made by the Internal Revenue Service's Tax-Exempt Compliance Unit resulted in cases taking three times as long to close and a decrease in taxpayers reached by more than half, the Treasury Inspector General for Tax Administration said Tuesday.
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August 20, 2024
Allen Matkins Tax Group Leader Jumps To Covington In LA
Covington & Burling LLP has added to its Los Angeles office a partner with more than 20 years of experience who most recently led Allen Matkins Leck Gamble Mallory & Natsis LLP's tax group, describing the new hire as "one of the country's leading authorities on partnership tax."
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August 20, 2024
Trade Group Urges Consistency In Pillar 2 Reporting Standard
The Organization for Economic Cooperation and Development should focus on making sure there is a standardized approach to acquiring the cross-jurisdiction information required for Pillar Two global minimum tax returns while also minimizing the compliance burden, the National Foreign Trade Council said Tuesday.
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August 20, 2024
A Deep Dive Into Law360 Pulse's 2024 Women In Law Report
The legal industry continues to see incremental gains for female lawyers in private practice in the U.S., according to a Law360 Pulse analysis, with women now representing 40.6% of all attorneys and 51% of all associates.
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August 20, 2024
These Firms Have The Most Women In Equity Partnerships
The legal industry still has a long way to go before it can achieve gender parity at its upper levels. But these law firms are performing better than others in breaking the proverbial glass ceiling that prevents women from attaining leadership roles.
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August 20, 2024
Aussie Capital Gains Tax Edit May Hit Green Energy, Pros Say
An Australian proposal to generally broaden the scope of the country's foreign resident capital gains tax regime could end up restricting foreign investment in the renewable energy sector, a group representing accounting professionals in the country said Tuesday.
Expert Analysis
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What Microcaptive Reporting Ruling May Mean For The IRS
In CIC v. Internal Revenue Service, a Tennessee federal court’s decision to set aside an IRS requirement to disclose microcaptive insurance arrangements may be a step toward evidentiary standards to show that the potential for abuse in a lawful transaction is sufficient to support heightened disclosure requirements, says Samuel Lauricia at Weston Hurd.
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US Should Leverage Tax Rules To Deter Business With Russia
The U.S. should further restrict the flow of resources available for the Putin regime's war in Ukraine by denying U.S. businesses that operate in Russia or Belarus foreign tax credits and global intangible low-taxed income preferences, and by terminating its tax treaty with Russia, says Reuven Avi-Yonah at University of Michigan Law School.
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Justices Must Apply Law Evenly In Shadow Docket Rulings
In recent shadow docket decisions, the U.S. Supreme Court has inconsistently applied the requirement that parties demonstrate irreparable harm to obtain injunctive relief, which is problematic for two separate but related reasons, says David Hopkins at Benesch.
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US Investors Stand To Benefit From Brazil's New Forex Law
Brazil's New Foreign Exchange Law facilitates negotiations and reduces bureaucracy for foreign investments, making it a good time for U.S. investors looking for projects with a positive environmental, social and governance impact to allocate funds to Brazilian energy and infrastructure, say Jorge Kamine and Juliana Pimentel at Willkie.
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A Landmark UK Enforcement Case For Crypto-Assets
HM Revenue and Customs' recent seizure of nonfungible tokens from three people under investigation for value-added tax fraud promises to be the first of many such actions against crypto-assets, so investors should preemptively resolve potential tax matters with U.K. law enforcement agencies to avoid a rude awakening, says Andrew Park at Andersen.
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Simplifying Tax Issues For Nonresident Athletes In Canada
Tax compliance can be particularly challenging for nonresident professional athletes playing in Canada, but as NHL contract negotiations approach a close, it's worth looking at some ways the tax burden can be mitigated, say Marie-France Dompierre and Marc Pietro Allard at Davies Ward.
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Steps For Universities As DOJ Shifts Foreign Influence Policy
Notwithstanding Wednesday's U.S. Department of Justice announcement terminating the initiative targeting Chinese influence and raising the bar for criminal prosecutions, universities should ensure their compliance controls meet new disclosure standards and that they can efficiently respond to inquiries about employees' foreign connections, say attorneys at Covington.
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Why I'll Miss Arguing Before Justice Breyer
Carter Phillips at Sidley shares some of his fondest memories of retiring Justice Stephen Breyer both inside and out of the courtroom, and explains why he thinks the justice’s multipronged questions during U.S. Supreme Court oral arguments were everything an advocate could ask for.
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Corporate Reporting Considerations As Tax Meets ESG
With the U.S. Securities and Exchange Commission filing season upon us amid increasing pressure for greater transparency around effective tax rates and tax strategies, multinational companies must decide how they will approach voluntary tax reporting and prepare their responses if they want to control the narrative, say Michael Lebovitz and Jenny Austin at Mayer Brown.
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The Highs And Lows Of Tax Controversy In 2021
Lawrence Hill at Steptoe & Johnson reviews the ups and downs of tax controversy practice in 2021, including the continued effects of the pandemic, troubling decisions on attorney-client privilege and an IRS comeback on transfer pricing.
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Lessons From IRS For A New HMRC Whistleblowing Model
Andrew Park at Andersen considers whether the public interest would be better served in allowing the U.K.'s tax enforcers, HM Revenue & Customs, to offer larger and more certain cash incentives to people blowing the whistle on tax misdemeanors — similar to the IRS model for whistleblowers.
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The Benefits Of Competent Authority In Int'l Tax Disputes
Multinational enterprises seeking relief from double taxation in a changing international tax landscape should consider utilizing the competent authority process, which provides both taxpayers and domestic tax regulators an efficient and effective means of dispute resolution, say David Farhat and Eman Cuyler at Skadden.
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How OECD Transfer Tax Initiative Affects Smaller Businesses
Small and midsize enterprises with cross-border transactions need to consider redefining tax strategies and operational models in light of the Organization for Economic Cooperation and Development's base erosion and profit shifting initiative, even though the agency's new tax guidelines are aimed at large multinational enterprises, says Ganesh Ramaswamy at Kreston Rangamani.