International
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July 31, 2024
Large UK Cos. Expect Major Pillar 2 Administrative Burden
While businesses largely reported they expect the U.K.'s implementation of the OECD's corporate global minimum tax to have little to no impact on the amount of tax they pay, they also are concerned about the law's administrative burden, HM Revenue & Customs said.
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July 31, 2024
Australia Seeking Members For Pillar 2 Working Group
The Australian Taxation Office said it is seeking members to join a working group focused on the country's implementation of the Organization for Economic Cooperation and Development's Pillar Two global minimum tax.
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July 31, 2024
EU Seeks Feedback On Effectiveness Of Anti-Avoidance Law
The European Commission said Wednesday that it is looking for feedback on how the European Union's anti-tax avoidance directive has fared since going into force in 2020, in particular concerning the bloc-wide implementation of the OECD's global minimum corporate tax standards.
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July 31, 2024
French Politician Wants VAT Cut For Repairs To Churches
A French politician is asking the European Commission to consider expanding the scope of rate reductions for value-added taxes to include the renovation of historic monuments, including churches, according to a letter released Wednesday.
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July 30, 2024
IRS Spinoff Guidance Raises Practical Concerns, NY Attys Say
Recent IRS guidance narrowing the corporate spinoff transactions that revenue officials will approve as tax-free ahead of time doesn't adequately consider the practical and commercial factors involved in these transactions, the New York State Bar Association's Tax Section said Tuesday.
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July 30, 2024
Israeli Man Seeks To Avoid Discovery In $3.6M FBAR Case
A federal court should not order the Israeli founder of a pet toy company to show cause for defying its discovery orders in the U.S. government's $3.6 million case over his failure to report foreign bank accounts because he is ending his defense, his attorneys said Tuesday.
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July 30, 2024
Kyocera Chides Gov't Attack On Jurisdiction In $7M Tax Case
The government's attempt to defeat a South Carolina federal court's jurisdiction is improper because it relies on a roughly $44 million assessment lodged months after electronics maker Kyocera filed an amended complaint for a $7 million federal tax refund, according to the company.
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July 30, 2024
Ropes & Gray Adds Partner To Int'l Tax Practice
Ropes & Gray LLP recently added a tax adviser with a wealth of experience navigating transactions, funds and investments for clients as a partner in its New York office, the firm said.
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July 30, 2024
Chubb Says It Would Be Harmed By US-Swiss Treaty
Chubb and its shareholders would be significantly harmed by the terms of a proposed new bilateral tax treaty between the U.S. and Switzerland because it would be denied tax relief despite having been domiciled in Switzerland for over 15 years, the global insurer said in a letter released Tuesday.
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July 30, 2024
Husch Blackwell Hires UB Greensfelder Partner In St. Louis
Several years after Husch Blackwell LLP's newest partner, Garrett Reuter Jr., graduated from law school, he joined Greensfelder Hemker & Gale PC to work alongside his late father. Now, he's bringing clients he grew up watching his father work with, to a new platform.
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July 30, 2024
UK Healthcare Ex-Directors Banned For £30M In Unpaid Taxes
Two former directors of a defunct U.K. healthcare company are banned from holding executive positions at any business after failing to pay more than £30 million ($38.5 million) in taxes, the government's insolvency agency said Tuesday.
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July 30, 2024
Israel Moving To Adopt Portion Of Global Minimum Tax
Israel's Ministry of Finance said it is working to adopt a portion of the Organization for Economic Cooperation and Development's 15% global minimum tax on large multinational entities starting in 2026 while delaying consideration of two other portions.
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July 30, 2024
Tax Pros Vent Displeasure At EU Disclosure Law
Tax professionals commenting on a European Union disclosure law by the deadline Tuesday vented long-held displeasure at the measure, which requires tax preparers to reveal cross-border strategies.
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July 30, 2024
Pension Tax Reform Could Unlock £100B For UK Growth
Changing how pensions are taxed in the U.K. could potentially unlock more than £100 billion ($128 billion) for domestic investment over the next five years, according to a recent analysis by a pensions consultancy.
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July 29, 2024
Utah Biz Groups Latest To Challenge Corp. Disclosure Law
Several small-business associations in Utah became the latest group to challenge the Corporate Transparency Act's disclosure requirements, telling a federal court Monday the statute violates several constitutional provisions, including the guarantee of due process.
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July 29, 2024
Immigrants Paid $96.7B In Taxes In 2022, ITEP Study Says
Unauthorized immigrants paid $96.7 billion in federal, state, and local taxes in 2022 but received few benefits in return, according to a new study released Monday, whose authors said granting such taxpayers work authorization would boost tax revenue and economic activity.
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July 29, 2024
Sites Should Pay Sport Fishing, Archery Import Tax, GAO Says
Congress should make U.S. online marketplaces responsible for any sport fishing and archery excise taxes owed on consumer import sales they're involved with, the Government Accountability Office said in a report released Monday.
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July 29, 2024
UK Seeks Input On Rule Targeting Min. Tax's Safe Harbor
HM Revenue & Customs opened a consultation Monday seeking comments on an anti-arbitrage rule to help prevent large multinational companies from exploiting the safe harbor provision in the Organization for Economic Cooperation and Development's global minimum tax.
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July 29, 2024
ECJ Nixes Swedish Dividends Tax On Foreign Pension Funds
Sweden can't collect a withholding tax on dividends distributed by Swedish companies to public pension funds abroad while exempting its own public funds because that is inconsistent with European Union law requiring the free movement of capital, the European Court of Justice said Monday.
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July 29, 2024
France Restricts Access To Beneficial Ownership Registry
France is dialing back access to its beneficial ownership information registry by introducing what it is calling a filtering system that limits the previously entirely public database starting Wednesday, the French Finance Ministry said Monday.
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July 29, 2024
Gov't Consults On Tax Hikes For Fund Managers, Non-Doms
Chancellor Rachel Reeves said Monday that an autumn Budget planned for Oct. 30 will include feature selected tax rises, a warning accompanied by strong hints from HM Treasury that fund managers and non-domicile taxpayers could take a bigger hit.
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July 29, 2024
EU's Highest Court Upholds Disclosure Law
The European Union's highest court on Monday upheld the bloc's law requiring tax advisers to report potentially aggressive cross-border tax arrangements, rejecting a challenge from Belgian tax attorneys who said their country's implementation of the EU's DAC6 law violated European law.
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July 26, 2024
G20 Declines To Back Brazil's Plan For A Minimum Wealth Tax
Finance ministers from the Group of 20 nations declined to back Brazil's proposal for an agreement on individual wealth taxation similar to the global corporate minimum tax, instead issuing a statement Friday that opted for softer language about cooperation.
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July 26, 2024
Biz Groups Call Corp. Transparency Act Unconstitutional
The U.S. government has failed to show how the Corporate Transparency Act meets narrow exceptions to the Fourth Amendment's search warrant requirements, a group of small businesses told a Michigan federal court Friday in contending that the statute is unconstitutional.
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July 26, 2024
Denmark's Tax Losses From Evasion Fell 70%, Study Says
Denmark's tax losses from offshore evasion by individuals dropped 70% following the implementation of the automatic exchange of banking information between tax authorities, researchers found in a study of the Danish Tax Agency's data.
Expert Analysis
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What To Make Of IRS' New Advance Pricing Guidance
Recent guidance on the IRS' goals for its advance pricing agreement system provides helpful insight into review and decision-making procedures for advance pricing agreement requests, but it also raises questions about the IRS' objectives, say Richard Slowinski and Stefanie Kavanagh at Alston & Bird.
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Reserved Investor Fund Would Plug Gap In UK Finance Market
The reserved investor fund recently proposed by HM Treasury has the potential to be a welcome tax-efficient addition to the U.K.’s canon of products for real estate investments, with attractive features for companies and, in particular, large asset managers, say lawyers at Herbert Smith.
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The Reciprocal Tax Bill Is A Warning Shot At Pillar 2
A bill recently introduced in the House of Representatives to reciprocally tax countries deemed to have imposed discriminatory taxes on U.S. citizens and businesses takes aim at countries implementing the global minimum tax treaty known as Pillar Two, with which the U.S. has not complied, says Alan Cole at the Tax Foundation.
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What Tax-Exempt Orgs. Need From Energy Credit Guidance
Guidance clarifying the Inflation Reduction Act’s credit regime, expected from the U.S. Department of the Treasury this summer, should help tax-exempt organizations determine the benefits of clean energy projects and integrate alternative energy investments into their activities, say attorneys at Morgan Lewis.
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How Foreign Info Return Penalty Case May Benefit Taxpayers
The U.S. Tax Court's recent decision that the Internal Revenue Service cannot penalize taxpayers for failing to file foreign corporation information returns may give similarly situated taxpayers an opportunity to also avoid penalties, provided they protect their rights before the decision is overturned or mooted by legislation, say attorneys at Arnold & Porter.
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The Nuts And Bolts Of IRS Domestic Content Tax Credit
Recent IRS guidance provides specifics on how renewable energy projects can qualify for bonus tax credits by meeting U.S. domestic content rules, but also creates a qualification framework that will be complicated for project developers to navigate, say Scott Cockerham and Wolfram Pohl at Orrick.
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Taxing The Digital Economy: The Good, The Bad And The Ugly
U.S. tech companies should watch for important developments in international taxation, including the resolution of Apple's decade-old state aid case, growing frustration with the Organization for Economic Cooperation and Development's global tax plan and adoption of the digital services tax instead, says Joyce Beebe at Rice University's Baker Institute for Public Policy.
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Big Tax Changes For Multinational Cos. In Budget Proposal
The Biden administration’s fiscal year 2024 budget proposes changes that would materially alter decades-old Internal Revenue Code provisions, requiring a shift in multinational corporations' tax planning strategies comparable to that required after enactment of the Tax Cuts and Jobs Act, say Xenia Garofalo and Kyle Colonna at Eversheds Sutherland.
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Senate Credit Suisse Report Puts Attention On Banks, Trusts
The Senate Finance Committee's recent finding that Credit Suisse violated a plea agreement struck over its role in enabling offshore tax evasion has important ramifications for banks and trusts, including how they onboard, document and report on transactions relevant to U.S. reporting requirements, say Will Barry and Ian Herbert at Miller & Chevalier.
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Seeking IRS Accountability For Faulty Microcaptive Notice
Like the taxpayers in Standard Insurances v. U.S. seeking to expand earlier wins in microcaptive insurance cases that limit IRS use of improperly obtained information, others should consider ways to hold the agency accountable and provide incentive for it to follow the law going forward, says Joshua Smeltzer at Gray Reed.
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Biden Admin. Proposals Both Encourage And Thwart EV Adoption
While the Biden administration has been aggressively focused on promoting electric vehicles from the start, its recently issued guidance on EV tax credits and its restrictive new auto emissions proposal create a sense of implementation whiplash that may frustrate manufacturers and consumers, says Levi McAllister at Morgan Lewis.
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The Key Issues Keeping Transfer Pricing A Top Tax Concern
Several challenges preventing a global economic reemergence from the pandemic era are making practitioners reevaluate commonly used transfer pricing models, and embrace new technologies and ways of doing business, say Farnaz Amini and Sophia Castro Jurado at Marcum.
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Curtailing Offshore Tax-Advantaged Investment In China
The U.S. government's plans to establish a new outbound investment regime hold the potential to arrest Chinese companies' increasing use of offshore, tax-advantaged locations to raise capital, says David Plotinsky at Morgan Lewis.