International News

EU Gets a New System to Resolve Double-Taxation Disputes

The European Council recently approved a new system for resolving disputes between European Union (EU) nations, including disagreements related to double taxation. The new procedures are designed to ensure that businesses and citizens can resolve disputes related to the interpretation of tax treaties more swiftly and effectively. It will also cover issues related to double taxation….

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Global NewsBits: EU Commission Wants Tech Companies to Pay Fair Share of Taxes

Digital companies in the European Union (EU) pay less than half the amount of tax that other companies pay, the European Commission said in a report.The EU needs a modern tax framework to seize digital opportunities, while also ensuring fair taxation, the report added. Within the EU, international businesses typically pay a 10.1% tax rate…

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Court Bars Tax Deduction on Sham Transaction

A U.S. District court has determined that a United States-based bank, having been denied foreign tax credits for UK taxes paid in connection with a Structured Trust Advantaged Repackaged Securities (STARS) transaction that was held to be a sham, couldn’t deduct those taxes. The U.S. District Court of Minnesota found that the bank had waived…

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Commercial Pilot Fails Tests for Foreign Earned Income Exclusion

The U.S. Tax Court has held that a commercial airline pilot stationed in South Korea failed both the “tax home” and the “bona fide residence” tests that determine whether a taxpayer qualifies for the foreign earned income exclusion. The pilot flew airplanes for Korean Air Lines (KAL) in 2011 and 2012. KAL considered him to…

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Tax Court: IRS Abused Discretion in Canceling Pricing Agreements

The U.S. Tax Court, which previously held that it had jurisdiction to review the IRS’s cancellation of advance pricing agreements (APAs) that it had entered into with Eaton Corporation, held that the IRS had abused its discretion in canceling those agreements. Eaton and the IRS entered into two APAs in which they agreed on the…

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