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Int'l Tax News

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Biden Pushes Strict Climate-Subsidy Rules Despite Energy Producers’ Warnings

  • By Amrith Ramkumar and Richard Rubin

Proposed criteria that would determine who gets generous tax credits for producing hydrogen are too strict and could stifle the industry, energy companies say.

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Canada’s Digital Services Tax Plan Likely to Meet Many Obstacles

  • By Patrick Marley and Kaitlin Gray

Osler’s Patrick Marley and Kaitlin Gray say Canada’s latest move to implement a digital services tax is likely to encounter political and practical challenges related to the tax itself and the OECD’s Pillar One. 

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Colombia’s New Digital Tax Rules Face Implementation Challenges

  • By Juan David Velasco and Juan Diego Fernandez

Baker McKenzie’s Juan David Velasco and Juan Diego Fernandez analyze fiscal challenges arising from economic digitization and Colombia’s recent tax reform. New regulations taking effect on Jan. 1, 2024, consider nonresidents ‘significant economic presence’ as an alternative to the OECD’s proposed guidelines for its two-pillar approach.  

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U.N. Shouldn’t Tinker With Two-Pillar Plan, EU Official Says

  • By Elodie Lamer

Discussions on a plan for international tax cooperation under U.N. auspices is feasible, but rethinking the OECD’s two-pillar global tax reform plan would be “a giant waste of time,” a top European Commission official said.

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The World’s Most Complicated Tax System Just Got Easier

  • By Samantha Pearson

Brazil signed into law an overhaul to simplify a patchwork of tax codes from its states and thousands of municipalities.

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Expectations for 2024: Pillar 1 Finds an Off-Ramp

  • By Robert Goulder

Robert Goulder considers Canada’s refusal to extend the global DST moratorium beyond 2023.

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Leveling the Pillar 2 Playing Field for the Asset Management Industry

  • By Kevin Brogan, Alistair Pepper, and Daren J. Gottlieb

Kevin Brogan, Alistair Pepper, and Daren J. Gottlieb consider the implementation of the pillar 2 global anti-base-erosion rules and ways in which revisions to them may create more consistency with policy objectives.

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2023: The Judiciary Takes Center Stage

  • By Mindy Herzfeld

Mindy Herzfeld looks back at key tax litigation from 2023, including Christensen v. United States.

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Plowgian Hints at Extension of Pillar 1 Negotiation Deadline

  • By Michael Smith

The United States expects an extension of the pillar 1 negotiation deadline into 2024 and is working to extend the digital services tax moratorium as well, Treasury’s outgoing OECD negotiator said.

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Corporate AMT Notice Tackles Double Counting

  • By Chandra Wallace and Andrew Velarde

The IRS and Treasury issued further interim guidance for the corporate alternative minimum tax, addressing potential double counting of income from controlled foreign corporations and modifying prior guidance for tax consolidated groups.

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UK to Tax Climate-Damaging Imports From 2027

  • By Charlie Cooper

The U.K. will impose a tax on imports with a big overseas carbon footprint, the government announced, in a major new commitment that aligns the country with the EU in efforts to use the global trade system to tackle climate change.

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EU Carbon Tax Could Cost Africa $25 Billion, AfDB Chief Says

  • By Ana Monteiro

Africa could lose as much as $25 billion annually due to the European Union’s new carbon border tax, hurting the continent’s trade by penalizing valued-added exports such as iron and fertilizers, African Development Bank Group President Akinwumi Adesina said.

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Tax Havens Race to Lure Companies as 15% Global Levy Looms

  • By Danish Mehboob and Lauren Vella

The 15% global minimum tax, part of the 2021 global tax pact agreed to by more than 140 countries, seeks to end the “race to the bottom” that has nations competing to offer the lowest corporate tax rates to draw big business investment to their shores.

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Australia Asks Digital Service Providers About Minimum Tax Plans

  • By Danish Mehboob

Australia started consultations with digital service providers to inform them on global minimum tax implementation plans, data requirements, and potential solutions for future compliance.

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Supreme Court Wary of Remaking Income Tax

  • By Jess Bravin and Richard Rubin

Justices hearing arguments over whether unrealized income could be taxed appear to shy away from a broad ruling.

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Pillar 2 Makes Some Tax Measures Redundant, EU Stakeholders Say

  • By Elodie Lamer

Several stakeholders have told the European Commission that some anti-tax-avoidance measures, including country-by-country reporting, will not be needed with the implementation of pillar 2 of the global tax reform plan.

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EU Commission Urges Cooperation Between U.N. and OECD on Tax Work

  • By Sarah Paez

The European Commission said the U.N. and the OECD should join forces to avoid any overlaps of their tax work, following a U.N. resolution to move international tax negotiations to the U.N.

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UN Eyes Two Components of Tax Framework, Aims For August Meeting

  • By Shefali Anand

The United Nations’ framework for international tax cooperation is likely to initially include tackling illicit financial flows and cross-border services, two key areas of concern for developing countries, a UN official said.

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U.S. Multinationals Are Becoming Less Multinational

  • By Martin A. Sullivan

Martin A. Sullivan uses new Bureau of Economic Analysis data on U.S. multinational foreign activities for a more detailed perspective now that some of the worst effects of the recent pandemic have subsided.

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QDMTTs: Pillar 2’s Minimum Tax Trendsetter

  • By Mindy Herzfeld

Mindy Herzfeld checks in on how countries are using and customizing qualified domestic minimum top-up taxes to meet their pillar 2 goals.

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Puerto Rico Seeks Global Minimum Tax Consulting Services

  • By Stephanie Soong

Puerto Rico’s Treasury Department is looking for international tax consulting services related to potential implementation of global minimum tax rules under pillar 2 of an OECD-brokered, two-pillar global tax reform plan.

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Saudi Arabia’s Tax Reforms Aim to Attract Foreign Investors

  • By Ahmed Altawyan

The Kingdom of Saudi Arabia is aiming to transform into a significant business hub, attracting a growing influx of foreign companies.

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US Sets Limits on Chinese Content to Receive EV Tax Credits

  • By Joe Deaux, Gabrielle Coppola, and Ari Natter

The Biden administration released long-awaited rules designed to block electric-vehicle manufacturers from sourcing battery materials from China and other foreign adversaries, while giving automakers some flexibility to comply with the new mandates.

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U.S. Limits China's Ability to Benefit From Electric Vehicle Subsidies

  • By Ana Swanson
  • By Jack Ewing
  • By Alan Rappeport

The Biden administration issued new rules to prevent Chinese firms from supplying parts for electric cars set to receive billions of dollars in tax credits.

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Too Soon to Make Pillar 2 a Blacklist Factor, EU Official Says

  • By Elodie Lamer

The chair of the EU Code of Conduct Group on business taxation said implementation of pillar 2 probably won’t become a determining factor for the list of noncooperative jurisdictions until after the peer review.

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Taiwan Tax Bill Advances in House With Bipartisan Support

  • By Cady Stanton

House taxwriters unanimously advanced a fix to the issue of double taxation with Taiwan, moving a unique bill combining approaches from two Senate committees.

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EU Panel to Widen Checks on Member Countries’ Tax Regimes

  • By Stephen Gardner

Tax measures put in place by EU countries will face closer scrutiny beginning next year for their possible harmful effects on other member countries’ economies, the chair of the bloc’s Code of Conduct Group (Business Taxation) told the European Parliament tax subcommittee.

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Pillar 2 Peer Review Guidance Expected Soon, Plowgian Says

  • By Stephanie Soong

More pillar 2 guidance is likely to be published by the end of 2023, including advice on the peer review process and on antiabuse rules related to a key safe harbor, a top Treasury official said.

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EU Won't Introduce Pillar 1 Directive, Commission Official Says

  • By Stephanie Soong

The European Commission has decided against proposing a directive to implement pillar 1 of the OECD’s two-pillar global tax reform plan because the pillar 1 multilateral convention would be enough, an EU official said.

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Barbados Minister Criticizes Use Of Tax Transparency Blacklists

  • By Danish Mehboob

A minister from Barbados discouraged countries from blacklisting others based on how far they’ve developed their tax transparency frameworks.

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EU Nearing Full Pillar Two Implementation, But Not Pillar One

  • By Stephen Gardner

European Union countries are largely on track to start applying Pillar Two of the global tax deal next year, but the finalization of Pillar One remains uncertain, an EU official said at a European Tax Adviser Federation seminar.

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Promising Tax Talks Face Hurdles as Taiwan Bills Go Their Own Way

  • By Doug Sword
  • By Cady Stanton

Tax talks that would combine a beefed-up child tax credit and reinstate full research and development expensing aren’t exactly sizzling, but they are picking up speed after a year in the doldrums.

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UK Minimum Tax Estimates Are Highly Uncertain, Economist Says

  • By Danish Mehboob

The UK’s projection of £12.7 billion ($15.9 billion) in revenue within the next six years from the global minimum tax is highly uncertain, a top budget economist told lawmakers in a government budget hearing Tuesday.

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More European Governments Propose Global Minimum Tax Bills

  • By Stephanie Soong

The Austrian, Norwegian, and Slovenian governments have proposed legislation implementing an EU directive for adopting global minimum tax rules under pillar 2 of the OECD’s two-pillar global tax reform plan.

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IP Transfers and Profit Shifting

  • By Martin A. Sullivan

Martin A. Sullivan explores financial data for more than 300 multinational companies to uncover trends in intellectual property transfers.

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U.K. Makes Full Expensing Business 'Tax Cut' Permanent

  • By Sarah Paez

The United Kingdom will make full expensing for business capital investments permanent as part of a plan to invest £20 billion annually in businesses over the next decade, said Chancellor of the Exchequer Jeremy Hunt.

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U.N. Tax Cooperation Resolution Passes in Committee Vote

  • By Sarah Paez

U.N. countries passed a resolution in committee to establish a framework convention for international tax cooperation, which would shift negotiations from the OECD to the U.N.

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EU to Assess Support for Withholding Tax Relief Framework Deal

  • By Elodie Lamer

While EU countries generally reacted positively to the Spanish EU Council presidency’s proposal exempting comprehensive withholding tax relief systems from some Faster and Safer Relief of Excess Withholding Taxes provisions, several requested time to study the impact.

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Colombia’s Introduction of Tax Arbitration a ‘Big Advance’

  • By Sam Edwards

Colombia will seek to allow arbitration in tax disputes for the first time in a major step forward, although questions remain about the proposal’s efficacy, tax professionals say.

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UK Sees About $16 Billion From Global Minimum Tax Over Six Years

  • By Danish Mehboob

The UK government estimates it will net about £12.7 billion ($15.9 billion) from the global minimum tax over the next six years, according to figures published in its Autumn budget statement.

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As Its Economy Sputters, Britain Cuts Taxes Ahead of Election

  • By Eshe Nelson

The U.K.’s top financial official, Jeremy Hunt, outlined measures to spur business investment and push more people into jobs.

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Barbados's Evolving Approach to Pillar 2

  • By Nana Ama Sarfo

Nana Ama Sarfo discusses Barbados's changing approach to pillar 2.

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Canada Reaffirms Its Plans for Unilateral DST

  • By Amanda Athanasiou

Despite opposition from business groups and the Biden administration, Canada has confirmed its intent to move ahead with its digital services tax just weeks before its planned effective date.

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UN Releases Draft Tax Resolution Calling for Framework Treaty

  • By Lauren Vella

A draft resolution released by the UN calls for the development of a framework convention to make international tax cooperation more inclusive.

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Corporate Income Tax Rates Decreased Globally Over Last 20 Years

  • By Lauren Vella

Income tax rates for companies have decreased on average over the past 23 years, according to a report on corporate tax statistics released by the OECD on Tuesday.

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EU to Consider Making Unshell Substance Test a Minimum Standard

  • By Elodie Lamer

A note prepared by the EU Council's Spanish presidency suggests pursuing the European Commission's idea to maintain the tax consequences of its proposal to tackle the misuse of shell entities.

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Report Reveals Hidden Costs of Canada's Battery Plant Subsidies

  • By Amanda Athanasiou

The cost of government support for electric vehicle battery manufacturing projects in Canada that includes U.S.-credit-matching subsidies to major automakers could exceed estimates by almost C $6 billion, a budget watchdog said.

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Switzerland Mulls Later Start Date for Global Minimum Tax

  • By Bastian Benrath

Switzerland may postpone raising the minimum tax rate on multinationals to 15%, amid widespread delays in implementing a global deal on the issue.

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U.S. Signs Indo-Pacific Tax Transparency Pact

  • By Alexander Rifaat

The United States has joined 13 other countries from the Indo-Pacific region in agreeing to, among other measures, strengthen cooperation to combat cross-border tax evasion.

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Bermuda Seeks Input on Draft Corporate Tax Legislation

  • By Stephanie Soong

The Bermudian government is holding a third consultation on its proposed corporate tax regime — this time on draft legislation intended to align with the global anti-base-erosion rules under pillar 2.

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