International
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September 30, 2024
Feds Seek Prison In Tax Case Linked To 'China Initiative'
Prosecutors have asked a Texas federal judge for an 18- to 24-month prison sentence for a Chinese-born engineer who pled guilty to tax crimes after being charged with export violations and fraud in a case the defense claims began as an espionage investigation under the U.S. Department of Justice's now-disbanded "China Initiative."
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September 30, 2024
IRS Appeals Office Tests Group Mailbox For Large Cos.
The Internal Revenue Service's Independent Office of Appeals announced Monday that it will test out a program intended to help enhance secure messaging for large businesses with multiple representatives by allowing them to request a group mailbox to communicate with their assigned Appeals employee.
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September 30, 2024
Aussie 2023-24 Budget Delivered Surplus Despite Tax Dip
Australia ended the 2023-24 fiscal year with an AU$15.8 billion ($11 billion) surplus, larger than what the government had projected and primarily due to spending cuts, not higher taxes, according to the country's annual report, published Monday.
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September 27, 2024
Ex-Citizens' Renunciation Fee Suit Shipped To Claims Court
A D.C. federal judge ruled that a lawsuit brought by former U.S. citizens seeking a refund on their $2,350 citizenship renunciation fee belongs in the Court of Federal Claims.
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September 27, 2024
Constitution Permits Blocked Anti-Laundering Law, Panel Told
The U.S. government urged the Eleventh Circuit on Friday to reinstate the Corporate Transparency Act passed in 2021, arguing that the anti-money laundering law is within Congress' powers to regulate economic activity and necessary to have businesses report beneficial ownership to combat crimes like tax evasion and terrorist financing.
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September 27, 2024
IRS Plans Transition Rules In Basis-Shifting Regs, Atty Says
The IRS plans to include transition rules in forthcoming proposed regulations that aim to clamp down on abusive tax avoidance practices through complex partnership transactions known as basis shifting, an agency attorney said Friday.
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September 27, 2024
Corp. AMT Rules Could Wrap In Smaller Partnerships
Recently proposed rules on the U.S. corporate alternative minimum tax create new concerns for partnerships of various sizes that could be forced to comply with complex reporting requirements unless the government introduces carveouts, tax observers said.
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September 27, 2024
Ireland Seeks Input On Business Interest Tax Regime
Ireland has asked for comments on its business interest taxation and deduction regime, as well as whether the country should introduce a commercial business purposes test for deductions, its government said Friday.
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September 27, 2024
Taxation With Representation: Kirkland, Skadden, Cleary
In this week's Taxation With Representation, Blackstone and Vista Equity Partners acquire Smartsheet Inc., Macquarie Asset Management takes a stake in D.E. Shaw Renewables Investment Group, and Apogee Enterprises Inc. buys UW Interco LLC from Heartwood Partners.
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September 27, 2024
US Trade Group Pushes OECD On Compliance Burden
The Organization for Economic Cooperation and Development needs to do more work on the safe harbor provisions of its Pillar Two 15% global corporate minimum tax plan — including potentially making it permanent — among other compliance burden concerns, the National Foreign Trade Council said Friday.
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September 27, 2024
Gov't Could Target Pension Contributions In Tax Raid
The U.K. government could introduce a new levy on employer pension contributions as a means of plugging a £22 billion ($29.5 billion) black hole in public finances, experts said Friday.
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September 26, 2024
Belgian Co. Can't Keep Using Ad Space Rent-Free, ECJ Says
The European Court of Justice on Thursday upheld a 2019 European Commission ruling that a street furniture company's owed rent for Brussels bus shelter advertising space, agreeing with the commission that allowing the company to continue using the ad displays without paying rent or taxes constituted unlawful state aid.
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September 26, 2024
Tribunal Halts $52.8M German Tax Collection Against Oil Cos.
German tax authorities shouldn't collect a windfall profits tax totaling at least €47.2 million ($52.8 million) from two oil refineries before the dispute has been litigated, a tribunal of the International Centre for Settlement of Investment Disputes said.
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September 26, 2024
Montreal Exchange Is A Qualified Exchange, IRS Says
The Montreal Exchange is a qualified board or exchange for purposes of mark-to-market contracts under Internal Revenue Code Section 1256(g)(7)(C), the Internal Revenue Service said Thursday.
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September 26, 2024
Amazon Reports Paying £932M In UK Taxes In 2023
Amazon said Thursday that it paid a total of £932 million ($1.25 billion) in U.K. taxes last year, which the company said puts it among the 10 largest taxpayers in the country.
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September 26, 2024
Tariff Tax Base Too Small To Replace Income Tax, Report Says
Higher tariffs can't replace income tax revenue, as former President Donald Trump has suggested, since U.S. imports total $3 trillion annually while incomes top $20 trillion, but they would lower incomes by raising prices for U.S. consumers, a think tank reported Thursday.
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September 26, 2024
Irish Dividend Exemption Too Restrictive, Big 4 Say
The Big Four accounting firms raised concerns about wording in Ireland's planned tax exemption for foreign-sourced dividends, claiming in comments released Thursday that it would be overly restrictive to require dividends to come solely out of an offshore affiliate's profits.
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September 26, 2024
Harris' And Trump's Tax Plans Each Add To Deficit, Study Says
The U.S. federal deficit would grow by at least $2 trillion over the next decade from the tax policy plans of both major parties' candidates, former President Donald Trump and Vice President Kamala Harris, researchers said Thursday.
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September 26, 2024
UK Cos. Claimed Nearly £1.5B In Patent Box Relief In 2022-23
While there was a slight dip in the number of U.K. companies that elected to use the country's patent box tax regime in the 2022-23 tax year compared with the prior year, the estimated value of relief claimed jumped to nearly £1.47 billion ($1.97 billion) compared with around £1.33 billion, HM Revenue & Customs said Thursday.
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September 26, 2024
UK R&D Tax Credit Claims Down, But Total Relief Up £100M
While there was an over 20% dip in research and development tax credit claims in the U.K. in the 2022-23 tax year, the total relief claimed rose to £7.5 billion ($10.1 billion), a £100 million increase, HM Revenue & Customs said Thursday.
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September 26, 2024
UK Corp. Tax Receipts Up 10% To £93.3B, HMRC Says
The U.K. generated £93.3 billion ($125 billion) in corporate tax receipts in the 2023-24 tax year, a 10% increase over the prior year, HM Revenue & Customs said Thursday, pointing mainly to the increase in the country's corporation tax rate to 25% as the reason behind the bump.
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September 26, 2024
ECJ Backs Strong Protection For Lawyer-Client Discussions
Confidentiality of lawyer-client communications has enhanced protection under European Union law, including in cross-border tax disclosures, the European Court of Justice ruled Thursday.
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September 26, 2024
OECD Publishes Streamlined Amount B Model Agreement
The Organization for Economic Cooperation and Development published a model agreement Thursday for a simplified and streamlined approach to the Amount B portion of Pillar One, a transfer pricing plan for certain baseline marketing and distribution activities.
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September 25, 2024
IBM Urges Justices To Review NY Tax On Foreign Royalties
New York's system for taxing royalty payments would be unconstitutional if every other jurisdiction adopted it, violating an internal consistency test reaffirmed by a 2015 precedent, IBM told the U.S. Supreme Court in asking it to review and overturn New York's high court ruling that allowed the tax regime.
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September 25, 2024
Boosting Indirect Tax Revenues Can Tackle Debt, OECD Says
A number of countries should look to eliminate distortive tax expenses as well as increase their revenue from certain taxes to help manage debt sustainability and make their economies more supportive of growth, the Organization for Economic Cooperation and Development said Wednesday.
Expert Analysis
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How High Court Could Change FBAR Penalty Landscape
On Wednesday, the U.S. Supreme Court will hear Bittner v. U.S., a case that will affect many people penalized for failing to file a Report of Foreign Bank and Financial Accounts, and there are important procedural implications should the government's position be reversed, say Reuben Muller and Andreas Apostolides at Cole Schotz.
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IRS Memo May Change IP Royalty Tax Prepayment Planning
A recent Internal Revenue Service advice memorandum finding a taxpayer was not permitted to prepay tax on contingent royalties after contributing intellectual property offshore is a noteworthy departure from earlier guidance that highlights potential differences between actual and deemed licenses, says William Skinner at Fenwick.
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What IRS Funding Increase Means For Taxpayers
The Internal Revenue Service will first use the influx of funding from the Inflation Reduction Act to address customer support and personnel issues, but with over half the money allocated to enforcement, corporations and high-net-worth individuals will face increased scrutiny, say Patrick McCann Jr. and Jasen Hanson at Chamberlain Hrdlicka.
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6 Tax Considerations For Life Sciences Collaboration Deals
Given recent IRS guidance and changes to certain tax rates and deductions, biotech and life sciences companies entering into collaboration agreements should assess several unique taxation issues affecting matters ranging from research and development expenditures to profit-sharing terms, say attorneys at Orrick and Andersen Tax.
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Rushed Multilateral Negotiations Caused Two-Pillar Tax Mess
Cracks appearing in the two pillars of the 2021 global tax plan stem from a multilateral tax policy process that rushed to issue rules without first resolving fundamental differences between countries or ensuring that the U.S., a key player, could implement them, says Jefferson VanderWolk at Squire Patton.
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Key Considerations For Seeking Relief From Double Taxation
Caroline Setliffe and E. Miller Williams at Eversheds Sutherland lay out the Organization for International Cooperation and Development’s mutual agreement procedure for settling double-taxation disputes, and discuss six factors U.S. taxpayers doing business in multiple countries should consider when determining the most advantageous form of relief.
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2 Tax Decisions Hold Key Transfer Pricing Takeaways
Richard Slowinski and Stefanie Kavanagh at Alston & Bird discuss two recent decisions in cases against the IRS — Eaton Corp. from the Sixth Circuit and Medtronic from the Tax Court — that may help clarify when the agency can cancel an advance pricing agreement, but leave unanswered questions about which pricing method applies to high-value intercompany licensing transactions.
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Digital Taxation Is Necessary, But Tough To Manage
The U.S. government has started to tackle complex new tax laws as the digital economy continues to grow, but this demands guidelines that will facilitate the growth while protecting investors and the government's finances, say attorneys at Cadwalader.
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Company Considerations For Cash Award Incentives: Part 2
Excerpt from Practical Guidance
Cash awards can help companies address some issues associated with equity awards to compensate employees, but due to potential downsides, they should be treated as a tool in a long-term incentive program rather than a panacea, say Denise Glagau and Kela Shang at Baker McKenzie.
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Company Considerations For Cash Award Incentives: Part 1
Excerpt from Practical Guidance
Denise Glagau and Kela Shang at Baker McKenzie discuss what companies must consider when offering cash awards outside of U.S. jurisdictions, and explain how some challenges associated with equity awards may be addressed with cash awards.
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What AML Bill Could Mean For Firms, Funds And FinCEN
If passed, an amendment within Congress’ annual defense bill would expand the list of institutions subject to anti-money laundering regulations, from law firms to investment funds, creating potential rulemaking and enforcement challenges for the Financial Crimes Enforcement Network, say attorneys at Arnold & Porter.
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Unpacking The New Stock Buyback Tax And Its Exceptions
Xenia Garofalo and Kyle Colonna at Eversheds Sutherland discuss provisions of the recently enacted tax on corporate stock repurchases, how its exceptions may be applied and what companies should consider when evaluating the cost of new or existing programs.
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Inside The OECD Transfer Pricing Documentation Guidance
Excerpt from Practical Guidance
The Organization for Economic Cooperation and Development's recently modified documentation guidelines can assist tax administrations in developing requirements for transfer pricing risk assessments and evaluations, and help multinational entity taxpayers demonstrate satisfaction of the arm's-length principle, says Neil Aragones at Lexis Tax.