International
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June 28, 2024
Australia Seeks Feedback On Renewable Energy Tax Credits
Australia's government is looking for public input on plans to offer tax breaks tied to renewable hydrogen and critical mineral production as part of the country's push to boost its green energy industry, the country's Treasury announced Friday.
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June 28, 2024
Jamaica, Turkey Taken Off Financial Crime Watch List
An intergovernmental task force on money laundering and other forms of financial crime said Friday that Jamaica and Turkey have been taken off the list of jurisdictions it monitors for compliance with international security standards.
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June 28, 2024
Estate Owes $4.9M For Son-Of-Boss Scheme, US Says
An estate owes $4.9 million in tax liabilities for a couple's scheme to artificially cancel out their capital gains, the federal government said in a complaint in Michigan federal court, arguing that the Son-of-Boss scheme constitutes fraud and its proceeds aren't entitled to bankruptcy protection.
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June 28, 2024
EU Leaders Nominate President Von Der Leyen For 2nd Term
European Union leaders nominated European Commission President Ursula von der Leyen for a second term and named their picks for two other top jobs in the bloc that will steer European policy for the next five years, including tax policy and economic sanctions.
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June 28, 2024
Supreme Court Strikes Down Chevron Deference
The U.S. Supreme Court on Friday overturned a decades-old precedent that instructed judges about when they could defer to federal agencies' interpretations of law in rulemaking, depriving courts of a commonly used analytic tool and leaving lots of questions about what comes next.
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June 27, 2024
Aussie Betting Site Can't Duck Taxes Tied To News Corp. Sale
Trustees associated with an Australia-based gambling website owe capital gains taxes on the AU$31 million ($20.6 million) sale of the business to News Corp., an Australian court ruled, finding the parties lacked an affiliated relationship that could warrant an exception.
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June 27, 2024
Congress Shouldn't Rush OECD Tax Package, Group Says
Congress should avoid "rubber-stamping" the two pillars of the Organization for Economic Cooperation and Development's plan to fight tax base erosion and profit shifting and instead gather more information on its impact on the U.S., a conservative advocacy group said Thursday.
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June 27, 2024
IRS Tells 10th Circ. To Deny Liberty Global's $110M Refund Bid
The U.S. government urged the Tenth Circuit on Thursday to reject telecommunication giant Liberty Global's push for a $110 million tax refund, arguing a lower court correctly deduced that the company's business restructurings were carried out solely to avoid tax.
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June 27, 2024
$2.1B Danish Tax Fraud Suspect Won't Testify, Court Says
A New York federal court denied dueling requests from U.S. pension plan investors accused of participating in a $2.1 billion Danish tax fraud scheme and from Denmark's tax agency to bring in the man that both sides say masterminded the scheme, or to bring in one of his employees.
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June 27, 2024
Ex-Skadden Tax Head And M&A Pro Joins Freshfields In NY
Freshfields Bruckhaus Deringer LLP has added the former head of the tax practice at Skadden Arps Slate Meagher & Flom LLP as a partner this week, who brings to the role experience in deals like 21st Century Fox's $71 billion acquisition by Disney and the merger of T-Mobile and Sprint.
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June 27, 2024
New FATCA Deal Requires US Banks To Share Info With Swiss
The United States and Switzerland signed a Foreign Account Tax Compliance Act agreement that will require U.S. banks to share financial account information on a bilateral basis, Switzerland's Federal Department of Finance announced Thursday.
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June 27, 2024
Algeria Commits To OECD Tax Treaty Standards
Algeria signed on to the Organization for Economic Cooperation and Development's multilateral convention Thursday, committing to implement the group's standards to fight base erosion and profit shifting in bilateral tax treaties, the OECD said.
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June 27, 2024
New EU Chair Wants VAT Deal Despite Calendar Omission
The incoming chair of meetings of European Union countries wants agreement on a proposal to require that platform companies such as Airbnb and Uber collect value-added tax for service providers despite leaving it off its work calendar, a spokesperson said.
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June 26, 2024
EU Court Tosses Spanish Shipping Cos. State Aid Appeal
A European court on Wednesday once again dismissed a 2014 challenge to the European Commission's move to block a Spanish tax scheme benefiting Spanish shipbuilders and their suppliers.
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June 26, 2024
Repatriation Tax Ruling May Sway State Wealth Tax Debates
The U.S. Supreme Court's upholding of the federal repatriation tax could indirectly affect state tax policy discussions, including by influencing consideration of wealth taxes and encouraging states to keep potential due process issues in mind when enacting tax legislation.
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June 26, 2024
Pepsi's Royalty Tax Liability Overturned By Australian Panel
A Federal Court of Australia judge incorrectly ruled that payments for beverage concentrate between Pepsi subsidiaries in Australia and Singapore included the license to use Pepsi's trademark and so triggered royalty taxes, a panel of the court ruled Wednesday.
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June 26, 2024
Fed. Circ. Denies Contractor's $37M Tax Reimbursement Bid
A U.S. State Department armed security contractor is not entitled to $37 million in reimbursement tied to tax payments to the Afghan government because the contractor's parent company, not the company itself, incurred the costs associated with the payments, the Federal Circuit said Wednesday.
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June 26, 2024
Medical Device Co. To Pay $935K Atty Fees In Tax Fraud Suit
A medical equipment company's leaders will pay $935,000 in attorney fees to investors' counsel after mediating a settlement in a proposed class action alleging the company breached fiduciary duty in failing to disclose its former CEO's involvement in a tax fraud dispute with Denmark.
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June 26, 2024
Kenya President Backs Off Finance Bill After Fatal Protests
Kenyan President William Ruto said Wednesday that he will withdraw a controversial finance bill that included tax hikes that inspired mass protests, including storming the country's Parliament building leaving multiple people dead, according to local news reports.
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June 26, 2024
EU Justice Head Loses Bid To Lead Human Rights Group
The European Union's justice commissioner failed in his bid to lead a European human rights organization and returned Wednesday from his leave of absence for the remaining four months of his term as commissioner.
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June 26, 2024
EU State Auditors Must Respect Tax Incentives, Lawyer Says
European Union countries need to make sure that their tax authorities are supporting incentive programs, such as those related to research and development, rather than interpreting laws in inconsistent ways, a tax lawyer said Wednesday.
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June 26, 2024
Irish Pick New Finance Minister After Former Heads To EU
Ireland picked a current junior minister as its new finance minister, the ministry confirmed to Law360 on Wednesday, one day after the government nominated the outgoing finance minister to serve on the next European Commission.
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June 25, 2024
US Needs To Broaden Tax Base, Increase Rates, OECD Says
The United States' debt-to-gross-domestic-product ratio is the highest it's been since World War II, necessitating a wide range of tax changes to both expand the tax base and increase rates to alleviate fiscal pressures, the OECD said Tuesday.
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June 25, 2024
Pharma Co. Teva To Pay Israel $750M In Tax Debt Settlement
Israel-based multinational Teva Pharmaceutical Industries Ltd. reached an agreement with the Israel Tax Authority to settle 12 years' worth of pending tax litigation by paying $750 million over the course of five years, the company said Tuesday.
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June 25, 2024
Asia, Pacific Tax-To-GDP Ratio Returns To Pre-COVID Level
Tax revenue in Asia and the Pacific rebounded to pre-pandemic levels in 2022 thanks to boosts in tourism and commodity prices, but the region's average tax-to-gross domestic product ratio is still lagging behind the average OECD ratio, the group said Tuesday.
Expert Analysis
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What Crypto Holders Can Learn From Early-2000s Tax Scandal
The Internal Revenue Service’s recent push to gather information about cryptocurrency accounts is similar to its Swiss bank account investigations of the early 2000s, which should prompt taxpayers to consider voluntarily disclosing transactions before they are individually targeted for enforcement, say Timothy Wagner and Thomas Barnard at Baker Donelson.
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International Tax Reform's Implications For Transfer Pricing
As the Organization for Economic Cooperation and Development overhauls the global tax rules on base erosion and profit shifting, and the Biden administration rolls out new U.S. tax proposals, multinational enterprises need to prepare for the effects of these tax changes on their transfer pricing structures, say Mandy Li and Shuang Feng at MGO.
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Justices' Preemptive Tax Challenge Ruling Shows Divisions
The U.S. Supreme Court's recent decision in CIC Services v. Internal Revenue Service reveals divisions among the justices about when potentially burdensome tax regulations can be challenged, making the holding less clear and less valuable, say George Isaacson and David Swetnam-Burland at Brann & Isaacson.
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Takeaways From 2 New FBAR Rulings
In light of two recent California federal court decisions, capping penalties for nonwillful violations of foreign bank account reporting but broadening the willfulness standard, U.S. taxpayers must be vigilant about understanding their reporting obligations, and prepare for the Internal Revenue Service to target willful conduct, which yields much higher penalties, say Friedemann Thomma and Marianna Felshtiner at Venable.
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El Salvador's Use Of Bitcoin Complicates US Commercial Law
El Salvador recently became the first country to recognize Bitcoin as currency, presenting significant implications for U.S. commercial law as the development will likely trigger the cryptocurrency to now fall within the definition of "money" under the Uniform Commercial Code, say Joe Carlasare and Eric Fogel at SmithAmundsen.
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Justices' Nod To Preemptive Tax Challenges May Caution IRS
The U.S. Supreme Court's recent decision in CIC Services v. Internal Revenue Service, allowing pre-enforcement challenges of tax reporting rules despite the Anti-Injunction Act, is likely to make the U.S. Department of the Treasury more careful about its own compliance obligations under the Administrative Procedure Act, says Robert Carney at Caplin & Drysdale.
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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.