International
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May 02, 2024
Canada Budget Seeks To Establish Corp. Min. Tax Standards
Budget proposals submitted to Canada's Parliament by the finance minister would implement the Organization for Economic Cooperation and Development's global corporate minimum tax standards as part of the country's overarching budget plans.
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May 02, 2024
OECD-Asia Group Helping Reform Agenda, OECD Head Says
A group that brings together countries from the mostly Western Organization for Economic Cooperation and Development and Southeast Asia to discuss issues, including tax, is helping countries make changes, the head of the OECD said Thursday.
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May 02, 2024
Airlines Slam Increase In German Air Passenger Tax
The increase in Germany's air passenger tax on May 1 will weaken the country's economy and damage the aviation industry's ability to cut down on its carbon use, an airline group said on Thursday.
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May 01, 2024
No Relief For Fla. Adviser Convicted In $80M Trading Scam
The Eleventh Circuit on Wednesday affirmed the conviction of a Florida investment adviser who bilked more than $80 million from the hundreds of people he persuaded to invest in a fraudulent company, after concluding he was not in custody when he made statements to the police.
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May 01, 2024
Middle East, North African Gov'ts Back UN For Corp. Tax Talks
Governments should make a high-level commitment to address corporate tax reform within the United Nations' framework convention on international tax cooperation, an intergovernmental group of Middle Eastern and North African countries said Wednesday.
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May 01, 2024
Think Tank Says 'Distortive' DSTs Not The Right Way Forward
As jurisdictions around the world continue to struggle with how to adequately tax the increasingly digital economy, they should look to expand their consumption taxes, not enact digital services taxes, the Tax Foundation said.
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May 01, 2024
Liberty Global Defends $109M Tax Refund Bid In 10th Circ.
Telecommunications giant Liberty Global urged the Tenth Circuit to revive the company's $109 million tax refund bid, arguing a lower court rejected the claim by wrongly disregarding intercompany transactions that are permitted under legislation involving the repatriation of foreign profits.
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May 01, 2024
UN Must Improve Corp. Tax Rules, Platforms, Some Gov'ts Say
Governments must commit to improving existing corporate tax rules and platforms created at the OECD within the terms of reference for a United Nations framework convention on global tax cooperation, two tax officials who participated in drafting those rules said Wednesday.
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May 01, 2024
HMRC Simplifies Late Filing Penalties For Digital Filers
U.K. taxpayers voluntarily filing their personal income tax returns using a program intended to modernize the country's tax system will receive more leniency and access to a simpler penalty structure in cases of late filing, HM Revenue & Customs said.
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May 01, 2024
Hong Kong Proposes Amended Automatic Info Exchange List
Hong Kong is considering adjusting the list of countries it automatically exchanges financial information with by subtracting nine jurisdictions and adding 11, which the country's tax authority said is in line with recommendations from the Organization for Economic Cooperation and Development.
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May 01, 2024
Swiss Sends Amendment To Serbian Tax Treaty To Parliament
Switzerland's executive body, the Federal Council, sent to the country's parliament Wednesday an amendment for the country's double-taxation treaty with Serbia that would bring it in line with the OECD's base erosion and profit shifting standards, the council said.
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April 30, 2024
India, Belgium, Others Support UN Taking On Wealth Taxation
Governments should make a high-level commitment to reach agreement on the taxation of wealthy individuals within the United Nations framework convention on international tax cooperation, representatives of India, Belgium, Austria, Nigeria and Kenya said Tuesday.
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April 30, 2024
Yellen Says US Pushing To Protect R&D Credit Under Pillar 2
U.S. Treasury Department negotiators are continuing to advocate for more favorable treatment of the country's research and development tax credit under the Pillar Two global minimum tax rules, Treasury Secretary Janet Yellen told the House Ways and Means Committee on Tuesday.
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April 30, 2024
German Banker Gets 3 Years For €93M Cum-Ex Tax Evasion
A German court on Tuesday sentenced a former bank board member to three years and two months in prison for his part in a €93.4 million ($100 million) so-called cum-ex dividend tax fraud.
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April 30, 2024
HMRC Proposes Special Economic Zone Tax Relief Extensions
HM Revenue & Customs proposed Tuesday to extend the time to claim tax relief measures available in special economic zones in the U.K. to 2031 in England and to 2034 in other parts of the country.
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April 30, 2024
The Tax Angle: TCJA Teams, Dear Colleague Letters
From a look at House GOP efforts to prepare for next year's expiration of their 2017 tax overhaul to ongoing attempts by lawmakers to draw attention and support for their own tax legislation, here's a peek into a reporter's notebook on a few of the week's developing tax stories.
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April 30, 2024
Global Climate Tax Could Fund Disaster Aid, Report Says
If OECD countries adopted a tax on the extraction of fossil fuels proposed by over 100 climate organizations, $900 billion could be generated cumulatively by 2030, a majority of which would be earmarked for those hit by climate disasters, some of those groups reported.
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April 30, 2024
EU Tax System Needs To Aid Climate Policy, Accountants Say
European Union lawmakers should design a tax system in their next five-year legislative term that supports the green transition and long-term employment, a European lobby for accountants said in a document posted Tuesday.
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April 29, 2024
Court Can Make Widow Pull $2.5M From Swiss Bank, US Says
A Colorado federal court can force a widow to send $2.5 million from a Swiss bank to the U.S. to repay her late husband's penalties and interest for failing to report his foreign accounts, the U.S. told the court.
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April 29, 2024
OECD Nations Steer UN Tax Talks Toward Decision-Making
The terms of reference for a United Nations global tax convention should guide the decision-making of a committee that will negotiate substantive provisions later even though some governments prefer to defer debate on the decision-making procedures to the General Assembly, several OECD government representatives said Monday.
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April 29, 2024
Canada Opens Second R&D Tax Credit Consultation
With an additional CA$600 million ($439 million) earmarked for its scientific research and experimental development tax incentive program, Canada is looking for more specific feedback on expanding and otherwise adjusting the regime.
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April 29, 2024
Poland Pushes Back Mandatory E-Filing After Finding Flaws
Polish businesses with sales totaling more than 200 million zloty ($50 million) won't have to use the country's electronic invoice system until 2025, with the full rollout delayed until 2026, due to multiple problems uncovered in the system, the country's tax authority said.
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April 29, 2024
OECD-UN Initiative Lands Developing Countries $2.3B In Tax
A joint initiative between the Organization for Economic Cooperation and Development and the United Nations to help developing countries boost tax revenues said Monday that it has generated $2.3 billion in additional revenues and $6.05 billion in additional tax assessments since its 2015 formation.
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April 29, 2024
Ex-Man City Player Benjamin Mendy Pays £710K Tax Debt
Former Manchester City footballer Benjamin Mendy avoided bankruptcy on Monday after paying a £710,000 ($892,000) tax bill minutes before a court hearing to determine whether an order should be made.
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April 29, 2024
US Expatriations Plummet In 1st Quarter, IRS Says
The number of people who expatriated from the U.S. fell nearly 70% during the first quarter of 2024 compared with the previous quarter, the Internal Revenue Service said in a notice published Monday.
Expert Analysis
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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.
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Mentorship Is Key To Fixing Drop-Off Of Women In Law
It falls to senior male attorneys to recognize the crisis female attorneys face as the pandemic amplifies an already unequal system and to offer their knowledge, experience and counsel to build a better future for women in law, says James Meadows at Culhane Meadows.
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5 Ways Firms Can Avoid Female Atty Exodus During Pandemic
The pandemic's disproportionate impact on women presents law firms with a unique opportunity to devise innovative policies that will address the increasing home life demands female lawyers face and help retain them long after COVID-19 is over, say Roberta Liebenberg at Fine Kaplan and Stephanie Scharf at Scharf Banks.
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IRS Real Estate Push Should Wake Up Foreign Investors
Two recently announced Internal Revenue Service audit campaigns targeting nonresident alien investment in U.S. real estate should prompt foreign investors to prepare for greater scrutiny as the agency works to improve tax compliance around such transactions, say attorneys at Holland & Knight.
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CFTC Climate Change Report Highlights Costs Of Inaction
The Commodity Futures Trading Commission's recent report on climate change and financial markets makes it clear that while government regulation of carbon dioxide pollution may have negative consequences, letting greenhouse gas emissions go unaddressed could harm investors, asset managers and financial institutions, says Nicholas Fox at Goldberg Segalla.
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Dems' Int'l Tax Policy Comes With Unintended Consequences
Former Vice President Joe Biden and Sen. Kamala Harris’ "Made in America" tax policy overstates the importance of revenue raising, which may encourage foreign ownership of global activity and disadvantage U.S.-based companies, says George Callas at Steptoe & Johnson.
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How Cos. Can Respond To Growing Crypto Tax Enforcement
As the U.S. Department of Justice and the Internal Revenue Service remain laser-focused on abusive cryptocurrency schemes, companies operating in this high-risk industry should review their compliance measures in areas such as data analysis, employee oversight and industry benchmarking, say attorneys at Norton Rose.