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La sentenza della Cassazione sulla proroga COVID di 85 giorni, il bollino verde dell'OCSE per la normativa nazionale sulla Global Minimum Tax, l'imputazione temporale dei canoni di locazione non riscossi. A cura di Cecilia Pasquale
Contributed by Christian Athanasoulas, Tax Practice Leader – Services, KPMG LLP, and Global Head of International Tax and M&A Tax, KPMG International; Janette Wilkinson, Partner, KPMG in the UK and Global BEPS Leader, KPMG International; Andy Baik, Tax Partner and BEPS Center of Excellence Leader, KPMG in Singapore; and Shawn Brade, National Service Line Leader, International Corporate Tax, KPMG in Canada, this podcast is created for those clients just beginning their journey or those that have taken steps forward but need to validate work completed to date.
President Cyril Ramaphosa has signed the Global Minimum Tax Act into law. This groundbreaking legislation enforces a 15% effective tax rate on multinational corporations, ensuring they contribute their fair share. The act targets tax avoidance by closing loopholes that allow companies to benefit from low-tax jurisdictions, potentially raising R8 billion in revenue by 2026. Rooted in the OECD's global tax reform framework, it applies to firms with annual revenues exceeding €750 million. While some organizations applaud the move, critics argue the threshold is too high, leaving many companies unaffected. Implementation begins this year. Bongiwe Zwane spoke to Executive Director at Firstsource Money, Redge Nkosi
President Cyril Ramaphosa has signed the Global Minimum Tax Act into law. This groundbreaking legislation enforces a 15% effective tax rate on multinational corporations, ensuring they contribute their fair share. The act targets tax avoidance by closing loopholes that allow companies to benefit from low-tax jurisdictions, potentially raising R8 billion in revenue by 2026. Rooted in the OECD's global tax reform framework, it applies to firms with annual revenues exceeding €750 million. While some organizations applaud the move, critics argue the threshold is too high, leaving many companies unaffected. Implementation begins this year. Bongiwe Zwane spoke to Executive Director at Firstsource Money, Redge Nkosi
Nosipho Radebe speaks to Jordan Mulindi, Tax Legal Specialist at Latita AfricaSee omnystudio.com/listener for privacy information.
2 ม.ค. 68 หุ้นไทยปิดตลาด -1.45% มาอยู่ที่ 1,379.85 จุด GULF ปิดตลาด -4.62% DELTA ปิดตลาด -8.85% หลังไทยเริ่มใช้ Global Minimum Tax (GMT) อัตราภาษีเงินได้นิติบุคคลข้ามชาติขั้นต่ำ เท่ากันทั่วโลกที่ 15% ธุรกิจไทยที่เข้าเกณฑ์เหล่านี้ จะได้รับผลกระทบแค่ไหนหลังจากนี้ แล้วเม็ดเงินจากการลงทุนต่างชาติ ที่จะเข้ามาในไทยจะชะลอหรือไม่ และจะส่งผลต่อตลาดหุ้นไทยหลังจากนี้อย่างไร Talk ลงทุนแมน ชวนคุณสุวัฒน์ สินสาฎก กรรมการผู้จัดการ Globlex Group มาร่วมวิเคราะห์ เรื่องนี้ไปพร้อม ๆ กัน
1) A Gaza la pioggia peggiora le condizioni dei rifugiati, mentre in 24 ore i raid israeliani hanno ucciso quasi 80 persone. Intanto in Cisgiordania la popolazione palestinese vive nel terrore. Nella notte un gruppo di coloni dà fuoco ad una moschea. (Omar da Tulkarem) 2) Una delegazione statunitense visita Damasco e incontra Al Jolani per la prima volta, mentre i siriani si interrogano sul futuro. (Maher Akraa - giornalista siriano rifugiato in svizzera) 3) Kiev si prepara ad affrontare il terzo natale sotto le bombe. Nella capitale Ucraina l'umore è sempre più cupo. (Gioele Scavuzzo - Soleterre) 4) Macron, Mayotte e il colonialismo strisciante. Il presidente francese visita l'isola devastata dal ciclone e risponde alla disperazione della popolazione con arroganza. (Francesco Giorgini) 5) Mondialità. L'ipocrisia della Global Minimum Tax che fa male al mondo.(Alfredo Somoza) 6) Storie Estreme. Da Scozia e Galles arriva Rewilding, la nuova frontiera per la conservazione della biodiversità (Sara Milanese)
The tax credit equity market is affected by a variety of factors'and several looming factors could create upward or downward pressure on the pricing for low-income housing tax credits (LIHTCs), new markets tax credits (NMTCs), historic tax credits (HTCs) and clean energy tax credits. In this week's Tax Credit Tuesday podcast'the second of a two-part series'Michael Novogradac, CPA, discusses the issues that could affect equity pricing with three Novogradac partners: Brad Elphick, CPA; Tony Grappone, CPA; and Dirk Wallace, CPA. They begin by looking at how proposed Community Reinvestment Act (CRA) regulations might impact their respective credits, then look at the Basel III and Global Minimum Tax proposals and how they could affect tax credit equity markets. After that, they examine generally accepted accounting procedure (GAAP) regulations, as well as how proposed legislation could impact the markets and wrap up with what proposed tax law changes would have the greatest positive effect in the areas in which they work.
ROMA (ITALPRESS) - Un impegno europeo per una global minimum tax su multinazionali e grandi player digitali, il ruolo della contrattazione per aumentare i salari, la lotta alla desertificazione dei centri storici causata dalla chiusura dei negozi. Sono alcuni dei punti affrontati dal presidente di Confcommercio Carlo Sangalli nel corso dell'Assemblea nazionale 2024 dell'associazione di categoria. All'assemblea è intervenuto anche il presidente della Repubblica Sergio Mattarella, che ha sottolineato l'importanza del commercio nel contesto sociale ed economico. Il ministro delle Imprese e del Made in Italy Adolfo Urso ha fatto il punto sulla strategia del governo per la crescita delle imprese.f07/sat/gtr
Six months into implementation of the new global corporate minimum tax, countries are racing to craft incentives to attract and maintain outside investment. Companies, too, are pouring resources into complying with the tax. The tax took effect in January in dozens of countries across the globe, with a goal of "raising the floor" tax rate to 15% in every country that a multinational company operates in, to reduce profit shifting to low-tax countries. In this podcast episode, Bloomberg Tax reporter Lauren Vella talks through all the ways companies and countries are responding to the new global tax regime, and what new guidance companies can expect in the future. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.
Over 140 countries have joined hands to implement a groundbreaking global tax agreement, designed to ensure that multinational corporations contribute their fair share through a minimum tax rate. Spearheaded by the OECD, this agreement imposes a minimum effective tax rate of 15% on corporate profits, aiming to put an end to the practice of sheltering massive profits in tax havens. Additionally, it aims to eliminate the allure of countries serving as tax havens for corporate giants.While neighboring Southeast Asian economies like Singapore and Thailand have opted to postpone the implementation of the OECD global minimum tax initiative until 2025, Vietnam has set its sights on adopting the tax this year.In a significant move, the Vietnam National Assembly passed a Resolution on November 29, 2023, paving the way for the implementation of additional corporate income tax aligned with the Global Anti-Base Erosion Rules (global minimum tax), effective from January 1, 2024.In this episode, we're joined by distinguished guests:Thang Vu, Tax Advisor at Luther Law VietnamKoen Soenens, General Sales and Marketing Director at DEEP C Industrial ZonesTogether with our host, Trang Dao, Head of Business Development Services at AHK Vietnam, we explore the potential ramifications of this resolution on foreign investors operating in Vietnam.*****AHK Vietnam is dedicated to supporting German and international businesses in navigating the complexities of the Vietnamese market. Our proficient team provides a comprehensive suite of services, including business partner search, investment location analysis, branding strategies, and more. Discover how we can assist you at https://vietnam.ahk.de/en/
The new 15% global minimum tax that took effect this year is turning out to be compliance beast. The tax, which is part of an international tax deal agreed to by more than 140 countries in 2021, contains a slew of new technical terms, complex rules, and hundreds of pages of administrative guidance. Now, some of the largest accounting firms in the world have been tasked with interpreting these rules, educating their clients, and building complex data systems to help multinational companies calculate their global minimum tax bills. In this week's episode of "Talking Tax," reporter Lauren Vella sits down with Danyle Ordway, principal of tax technology and data analytics at Ernst & Young LLP, to talk about how the firm is helping clients adapt to the new levy. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.
#支柱二 #Pillar 2 #全球最低稅負制 #國際租稅 #跨國企業 OECD全球企業最低稅負制(Global Minimum Tax, GMT)已於2024年在許多國家開始推行,包括歐盟、英國、日本、韓國、越南等。到達適用門檻(合併營收約新台幣250億元)的企業受GMT的影響也須開始進行財報的揭露。IAS12要求企業在2023年財報中揭露支柱二對其稅務的影響,本期影片說明支柱二的規則範本以及IFRSs財務報表的附註參考。 歡迎閱讀相關文章:《大型台資企業應重新評估國別報告揭露方式 以降低全球企業最低稅負》https://pwc.to/3voWuIo 歡迎成為資誠會員:https://pwc.to/2V8Lh8v
This Day in Legal History: Janet Reno Sworn in as U.S. Attorney GeneralOn March 12, 1993, a groundbreaking moment in the annals of American legal and political history unfolded as Janet Reno was sworn in as the first female U.S. Attorney General. Appointed by President Bill Clinton, Reno's confirmation by the Senate marked a significant milestone, shattering a glass ceiling in the highest echelons of the U.S. justice system. Her tenure, which lasted until January 20, 2001, remains the longest in the 20th century for this pivotal role. Reno was known for her straightforward approach and her commitment to addressing complex issues directly, which earned her both admiration and criticism.Reno's time in office was characterized by her involvement in some of the most contentious and high-profile cases of the 1990s. She oversaw the prosecution of the 1993 World Trade Center bombers and the 1995 Oklahoma City bombing, demonstrating her dedication to combatting domestic terrorism. Her decisions, such as the authorization of the armed seizure of Elián González, a Cuban boy embroiled in international custody and immigration controversy, and her handling of the Branch Davidian siege in Waco, Texas, were sources of national debate, highlighting the challenges and pressures of her role.Despite the controversies, Reno's contributions to justice and her trailblazing role as the first woman to serve as U.S. Attorney General had a lasting impact on the legal landscape. Her tenure helped pave the way for future generations of women in law and public service, inspiring countless individuals to pursue careers in these fields. Janet Reno's legacy is a testament to her resilience, leadership, and unwavering commitment to justice, marking March 12 as a notable date in legal history for celebrating her historic swearing-in and the doors it opened for women in the legal profession.An anonymous ethics complaint has been filed against William Lee, a distinguished attorney from WilmerHale, urging the Massachusetts attorney general's office to delve into the firm's interactions with Harvard University. Lee, who also served on Harvard's governing board for over a decade, and WilmerHale represented Harvard in its legal fight to maintain its race-based admissions policy, a battle ultimately lost at the Supreme Court. Additionally, the firm prepared former Harvard president Claudine Gay for a congressional hearing on antisemitism, which contributed to her resignation. Despite these incidents highlighting the connections between WilmerHale and Harvard, experts like Stephen Gillers from NYU suggest there's no apparent wrongdoing based solely on Lee's dual roles.The complaint alleges Lee may have breached conflict of interest regulations for public entities due to his position at Harvard and his involvement in its legal affairs, especially the affirmative action litigation. WilmerHale defended its legal representation of Harvard, stating Lee recused himself from any school decisions regarding the case, and Harvard, in a 2018 statement, claimed Lee received no payment for his work on the affirmative action case or any related revenue from the firm's billing to Harvard. Legal ethics professionals note that Lee's actions, including his decision to recuse himself, likely didn't violate any rules, though questions about compensation remain partially unanswered.Lee's role in WilmerHale's relationship with Harvard during the legal challenges to its admissions policies has drawn scrutiny, especially considering the firm's substantial legal fees from Harvard during this period. However, both Harvard and WilmerHale have maintained that Lee's involvement and the firm's compensation practices were ethical and transparent. Lee's significant contributions to both Harvard and WilmerHale, including his leadership in a pivotal lawsuit and his recusal from fiduciary duties related to the case, illustrate the complexities of navigating legal ethics in high-profile cases.WilmerHale's Work for Harvard Scrutinized in Ethics ComplaintThe parent company of Alex Jones' Infowars, Free Speech Systems LLC, amidst its bankruptcy proceedings, has obtained court approval to change its legal representation as it faces a pivotal phase that could lead to either a restructure or a systematic shutdown. This decision was sanctioned by Judge Christopher Lopez from the US Bankruptcy Court for the Southern District of Texas, emphasizing that this switch in counsel should not decelerate the ongoing case. The approval came after stakeholders in the Chapter 11 bankruptcy case, filed under a special chapter for small businesses separate from Jones himself in 2022, consented to the replacement of lead attorney Ray Battaglia with the O'ConnorWechsler PLLC firm.This strategic move is part of broader efforts to navigate through bankruptcy while addressing over $1.5 billion in judgments against Jones and Infowars for defaming Sandy Hook victims' families. Jones had previously called the tragedy, where 26 were killed in Newtown, Connecticut, a hoax perpetrated by "crisis actors." The trustee overseeing the bankruptcy highlighted concerns about the viability of Free Speech Systems' reorganization and suggested that the court might need to consider converting the case to a Chapter 7 liquidation. This comes as litigation continues against PQPR Holdings, an Infowars vendor implicated in insider payments, suggesting an intricate web of financial and legal challenges as the company seeks to resolve its liabilities and navigate through bankruptcy.Infowars Parent Gets New Lawyer Amid Bankruptcy Case ConcernsIn a significant development in the ongoing opioid crisis litigation, Walmart Inc. achieved a partial victory when a federal judge dismissed two of the three charges against it brought by the US government. Chief Judge Colm F. Connolly of the US District Court for the District of Delaware ruled in favor of Walmart by dismissing charges that accused the retail giant of failing to report suspicious orders of controlled substances and not adhering to standard pharmacy practice in filling prescriptions. These dismissals were grounded in interpretations of the Controlled Substances Act, with Connolly stating that the act does not deem the failure to comply with reporting requirements or to adhere to standard pharmacy practices as unlawful, nor does it subject violators to civil penalties.However, Walmart's motion to dismiss a third charge was denied. This charge alleges that Walmart, through its agents and employees, knowingly dispensed controlled substances on prescriptions that were not issued for legitimate medical purposes or were outside the usual course of professional treatment. The decision to keep this charge intact was influenced by precedent from the Third Circuit, underscoring that knowledge of wrongdoing by any employee is attributable to the corporation itself. This mixed ruling leaves Walmart partially vindicated but still facing serious allegations related to its handling of opioid prescriptions, highlighting the complexities of legal responsibilities in the context of the opioid epidemic. Walmart has yet to comment on the judge's rulings.Walmart Scores Partial Win in Opioid Crisis Suit Brought by USLegislation aimed at compelling TikTok's parent company, ByteDance, to divest the app or face a U.S. ban is gaining momentum in Congress, despite former President Donald Trump's recent remarks questioning the necessity of a ban. The bipartisan bill, led by House China Committee Chairman Mike Gallagher, seeks to prohibit app stores and ISPs like Apple and Google from hosting TikTok unless ByteDance divests it within six months. This legislative effort received a unanimous vote of approval from the Energy and Commerce Committee. Trump's shift in stance, from previously attempting to ban TikTok due to national security concerns to now suggesting Meta's Facebook poses a greater threat, introduces a complex variable for Republican lawmakers. FBI Director Christopher Wray and the annual report from the Office of the Director for National Intelligence have reiterated significant national security risks associated with TikTok, citing instances of China's alleged use of the platform to influence U.S. politics. TikTok has countered these allegations by denying any data sharing with Beijing and by investing over $1.5 billion to safeguard its U.S. operations, including a partnership with Oracle for oversight. The bill's future in the Senate remains uncertain, though some senators have expressed potential support. TikTok has mobilized efforts to oppose the bill, including enlisting Republican figures. Meanwhile, voices within Congress advocate for broader internet data protection measures rather than focusing solely on TikTok. This ongoing debate highlights the complexities of addressing cybersecurity, data privacy, and the influence of social media on public discourse.TikTok Divestment Bill Moves Ahead in House as Trump WaversIn my column, I delve into the urgent need for the United States to adopt a global minimum tax as a means to combat rampant corporate tax avoidance, a situation exacerbated by the Tax Cuts and Jobs Act (TCJA) of 2017. Despite the act's promises, its aftermath has primarily seen the institutionalization of tax evasion practices rather than the anticipated economic growth. I argue that President Joe Biden's proposal for a global minimum tax of 21% on multinational earnings in each jurisdiction is a critical step towards halting the detrimental race to the bottom in corporate tax rates, thus leveling the playing field for U.S. businesses.My analysis points out that following the TCJA, many corporations have paid significantly less in taxes than intended, with a study showing an effective tax rate of just 14.1% for 342 of the most profitable companies. This starkly contrasts with the act's reduced rate of 21%, underscoring the policy's failure to curb tax evasion effectively. I contend that revisiting the advocacy for a global minimum tax is not only timely but essential for the integrity of the corporate tax framework, especially as Biden's administration's tax policies face uncertainty with the approaching presidential election.I emphasize the necessity of tax transparency in achieving equitable corporate taxation. This involves mandating standardized disclosures of taxes paid across jurisdictions and the specifics of tax benefits and credits received, thereby allowing tax authorities, the public, and stakeholders to scrutinize corporations' tax strategies more effectively.Further, I discuss the broader context of the global minimum tax initiative led by the G20 and OECD, which the U.S. has yet to join. This reluctance leaves the U.S. missing out on potential revenue from the global minimum tax rate of 15% agreed upon by over 140 countries, which could support critical domestic investments. I challenge the arguments against the global minimum tax, highlighting the benefits of discouraging harmful tax competition and simplifying compliance for multinational corporations.In sum, I tried through my column to underscore the imperative for the U.S. to embrace the global minimum tax as a robust solution to corporate tax avoidance, fostering fairness, equity, and the necessary fiscal resources to invest in the nation's future.US Must Adopt Global Minimum Tax to Fight Corporate Tax Avoidance Get full access to Minimum Competence - Daily Legal News Podcast at www.minimumcomp.com/subscribe
KPMG Partners Peter Oliver, Alia Lum and Denis Larkin, along with Manager Lydia Morris, reflect on international tax developments as they affect multinational entities, including recent case law and guidance on intangibles and royalties, preparing for Pillar 2 and other developments.
One veteran portfolio manager holds the view that we've been in a truly extraordinary period since the early 1980s--- but things have now returned to normal. Today's Stocks & Topics: SWK - Stanley Black & Decker Inc., TRMLF - Tourmaline Oil Corp., AAPL - Apple Inc., 15% Global Minimum Tax, MGRC - McGrath RentCorp, TFX - Teleflex Inc., D - Dominion Energy Inc., Fixed Rate Debt.Our Sponsors:* Check out Rosetta Stone and use my code TODAY for a great deal: https://www.rosettastone.com/Advertising Inquiries: https://redcircle.com/brandsPrivacy & Opt-Out: https://redcircle.com/privacy
Join Andrew Quinn for this podcast and fireside chat with Ireland's Minister for Finance Michael McGrath TD and Noelle O'Connell from European Movement Ireland on the new EU Global Minimum Tax Directive. The Directive came into force in Ireland, Luxembourg and across the EU on 31 December 2023 and introduces a new 15% global tax rate on large consolidated group of companies with an EU presence. To listen to this episode and others from the Tax & Coffee EU & International Tax Podcast series, visit EU and International Law .To listen to this episode and others from the Tax & Coffee EU & International Tax Podcast series, visit https://maples.com/eu-and-international-taxThe Tax & Coffee Podcast is available on most podcast platforms, including Apple Podcasts, Spotify and Google Podcasts. To subscribe, visit https://eu-and-international-tax.captivate.fm/listenSpeakers:Andrew Quinn | Partner | +353 1 619 2038 | Andrew.Quinn@maples.com | View BioAndrew Quinn, Head of Tax at Maples Group, and his colleagues in our Irish and Luxembourg legal tax teams share insights on key EU and international tax developments relevant to business and the investment funds industry.Related Services:Maples Group Tax Legal ServicesThe Maples Group Tax Group advises leading companies, banks and investment firms on tax matters from our Irish and Luxembourg law firms. We advise our clients on Irish, Luxembourg, EU and international tax and we are supported by a large tax compliance team.FOLLOW US: LinkedIn: https://www.linkedin.com/company/maplesgroup/Instagram: https://www.instagram.com/maplesgroup/Twitter: https://twitter.com/maplesgroupFacebook: https://www.facebook.com/maplesgroup/Website: https://maples.com/eu-and-international-tax
ROMA (ITALPRESS) - È entrata in vigore nell'Unione Europea la global minimum tax. Viene introdotta un'aliquota minima di imposizione effettiva del 15% per le società multinazionali attive negli Stati membri. Il nuovo quadro di regole punta a una maggiore equità e stabilità al panorama fiscale nell'Unione e a livello mondiale, rendendolo nel contempo più moderno e più adatto al mondo digitale globalizzato.fsc/gsl
ROMA (ITALPRESS) - È entrata in vigore nell'Unione Europea la global minimum tax. Viene introdotta un'aliquota minima di imposizione effettiva del 15% per le società multinazionali attive negli Stati membri. Il nuovo quadro di regole punta a una maggiore equità e stabilità al panorama fiscale nell'Unione e a livello mondiale, rendendolo nel contempo più moderno e più adatto al mondo digitale globalizzato.fsc/gsl
In the Free Zone with Norm: Discussing Underrated and Overrated Bands and Movie PreferencesIn this episode, Norm, Derek, and guest, Brandon, discuss a wide range of topics including COVID-19 testing, perception of the common cold versus COVID, capital punishment, global minimum taxes, controversies surrounding the ownership of the Washington Commands, and ethics of execution methods. They also dive into their perception of overrated and underrated bands, highlighting the evolution of the music industry. In movie-related discussions, they consider their favorite films and touch on the subject of movies being tied up in digital rights legalities. In the end, Norm introduces a new segment of creating top 10 lists from different categories for future episodes.00:00 Introduction and Welcome01:10 COVID-19 Conspiracy Theories and Personal Experiences01:55 Discussion on Common Cold vs COVID-1903:18 Impact of COVID-19 on Personal Relationships04:10 Pre-COVID Illness Experiences05:31 Ethics of Capital Punishment12:02 Global Minimum Tax on Corporate Profits15:35 NCAA Tournament and College Football Discussion29:22 Impact of Social Media on Celebrity Culture34:17 Record Deals and Music Industry Changes39:49 Discussing Overrated and Underrated Bands40:49 Exploring the Band UFO42:05 Derek's Take on Underrated Bands43:25 Norm's Perspective on Underrated Rap Bands46:33 Debate on the Evolution of Music Genres52:04 Norm's List of Overrated Bands57:50 Bringing Back Movie Discussions01:03:44 Favorite Movies and Final Thoughts
Low Value Goods Tax, e-invoicing, Service Tax increase, Capital Gains Tax, Luxury Tax, and the Global Minimum Tax. To kickstart the new year here on Resource Centre, we review all the key tax related developments for businesses in 2023 and how they will need to navigate them in 2024 with Thenesh Kannaa, Executive Director at Tratax.2023 saw the introduction and acceleration of a few key things in the tax space for businesses, this includes the increase to the Service Tax to 8% (and introduction of the Service Tax to industries such as logistics and food delivery at a 6% rate), Capital Gains Tax on the disposal of unlisted shares by companies (with some exemptions), the charging and levying of sales tax on Low Value Goods sold online from foreign sellers effective 1 January 2024, the acceleration of the e-invoicing timeline, and the Global Minimum Tax.Resource Centre is your one-stop shop to help build, scale and manage your business. Learn from industry experts and experienced practitioners how to power your growth, better develop and manage talent, build your brand, and much more.
In today's episode, we're delighted to welcome Robert Stack, Managing Director at public accounting firm Deloitte, to provide an update on the global efforts to impose this tax.
Listen to the November episode of IFRS Talks for an overview of the global minimum tax rules, practical challenges, safe harbours, and accounting implications. Catching up on global minimum taxes? Listen to PwC's latest #IFRSTalks episode for an overview of the rules, practical challenges, safe harbours, and accounting implications
In this episode Grahame and Harriet discuss the proposals from the EU Tax Observatory for a global minimum tax to be imposed on individuals. They discuss the design of such a system and possible alternatives
In part 1 of this two-part episode, Mike Linter, Global Head of Private Enterprise Tax, Global Tax & Legal, KPMG International, Shay Menuchin, Policy Lead for KPMG's Private Enterprise Tax Network, KPMG in Canada, John Riva, Head of Tax for the KPMG Islands Group, and Greg Limb, Global Head of Family Office and Private Client at KPMG International unpack some of the potential impacts of the Global Minimum Tax on private companies and family offices.
In part 2 of this two-part episode, Mike Linter, Global Head of Private Enterprise Tax, Global Tax & Legal, KPMG International, Shay Menuchin, Policy Lead for KPMG's Private Enterprise Tax Network at KPMG in Canada, John Riva, Head of Tax for the KPMG Islands Group, and Greg Limb, Global Head of Family Office and Private Client at KPMG International, continue the conversation on the potential impacts of the Global Minimum Tax on private companies and family offices.
In this podcast, Andrew Quinn and David Burke discuss the EU Global Minimum Tax Directive which comes into force across the EU on 31 December 2023 and implements the OECD Pillar Two Rules. They explain how the Directive will impose a 15% global minimum tax on certain large groups which contain an EU entity, by charging the EU entity with additional tax in respect of low taxed profits of group entities elsewhere in the world. They discuss the draft legislation published in Ireland and consider the potential impact on certain investment fund structures.To listen to this episode and others from the Tax & Coffee EU & International Tax Podcast series, visit https://maples.com/eu-and-international-taxThe Tax & Coffee Podcast is available on most podcast platforms, including Apple Podcasts, Spotify and Google Podcasts. To subscribe, visit https://eu-and-international-tax.captivate.fm/listenSpeakers:Andrew Quinn | Partner | +353 1 619 2038 | Andrew.Quinn@maples.com | View BioAndrew Quinn, Head of Tax at Maples Group, and his colleagues in our Irish and Luxembourg legal tax teams share insights on key EU and international tax developments relevant to business and the investment funds industry.David Burke | Of Counsel | +353 1 619 2779 | David.Burke@maples.com | View Bio Related Services:Maples Group Tax Legal ServicesThe Maples Group Tax Group advises leading companies, banks and investment firms on tax matters from our Irish and Luxembourg law firms. We advise our clients on Irish, Luxembourg, EU and international tax and we are supported by a large tax compliance team.FOLLOW US: LinkedIn: https://www.linkedin.com/company/maplesgroup/Instagram: https://www.instagram.com/maplesgroup/Twitter: https://twitter.com/maplesgroupFacebook: https://www.facebook.com/maplesgroup/Website: https://maples.com/eu-and-international-tax
Explore the global tax reform, GMT, aimed at ending tax competition and profit shifting. Discover how businesses in Malaysia may be affected as multinational companies face a 15% minimum tax regardless of their location.
On this day, June 22nd, in legal history, the Supreme Court handed down their decision in Escobedo v. Illinois, which held that suspects have the right to an attorney when they are questioned by the police.The decision established that defendants have the right to counsel even before they are formally charged with a crime. The impact of the Escobedo decision was overshadowed by the subsequent Miranda decision two years later. Although later court decisions limited the application of Escobedo, the Supreme Court never directly overruled it.The case involved Danny Escobedo, who was initially arrested for the murder of his brother-in-law but released after consulting his lawyer. When he was rearrested ten days later, his repeated requests to contact his attorney were denied. Escobedo's lawyer arrived at the police station and requested to see him but was refused permission. The police informed Escobedo that his alleged co-conspirator had confessed and implicated him. Escobedo demanded to confront his co-conspirator and, in that confrontation, made an incriminating statement. Based on this admission, the police obtained a written confession, leading to Escobedo's conviction for murder.The Supreme Court's decision in Escobedo came shortly after the Massiah v. United States case, which ruled that the right to counsel attaches once an individual has been indicted. In Escobedo, the Court reached a similar result with a 5-4 decision. Justice Arthur Goldberg, writing for the majority, stated that Escobedo's right to counsel did not depend on a formal indictment. The Court overturned Escobedo's conviction, declaring that his right to counsel had been violated. Goldberg laid out several benchmarks for determining when a defendant's Sixth Amendment right to counsel is violated.Many believed that the Escobedo decision would establish a broad right to counsel whenever a suspect is in police custody. However, two years later, the Supreme Court shifted direction in Miranda v. Arizona. The Miranda decision utilized the Fifth Amendment right against self-incrimination and held that statements obtained during incommunicado interrogation without full warning of constitutional rights were inadmissible. Miranda focused on whether a defendant was in custody or significantly deprived of freedom, rather than the "focus of investigation" test used in Escobedo.Perkins Coie, a law firm based in Seattle, is postponing the start dates for some of its first-year associates to January 2024, following a trend among law firms facing a slowdown in demand. In a memo from managing partner Bill Malley, the firm explained that the move is a response to challenging market conditions affecting various areas of legal practice. The deferred associates, with the exception of those in the intellectual property practice, will now begin on January 16, 2024. Those joining the intellectual property group will start on September 18, 2023. To assist the deferred associates, Perkins Coie is providing a $15,000 stipend to cover their living expenses. Other law firms, such as Orrick, Herrington & Sutcliffe, Cooley LLP, and Fenwick & West, have also delayed the start dates for their incoming associates due to the sluggish demand for legal services. Some firms have implemented cost-cutting measures, including layoffs of attorneys and staff. The legal industry as a whole is navigating through the challenges posed by reduced dealmaking and a slowdown in the demand for legal work.Perkins Coie Delays Starts for Some First-Year Associates (1)A new analysis from the Joint Committee on Taxation suggests that the United States could face significant revenue losses if it does not enact a 15% global minimum tax alongside the rest of the world. A global minimum tax is a proposal aimed at imposing a minimum tax rate on corporate income worldwide through international agreement. In October 2021, 136 countries and jurisdictions endorsed a proposal by the Organisation for Economic Co-operation and Development (OECD) for a two-pillar solution to address tax avoidance practices and the digitalization of the global economy. The first pillar would redistribute over $125 billion in corporate profits annually for taxation in jurisdictions where the profits were earned, while the second pillar would generate an estimated $150 billion by applying a 15% minimum tax rate to corporate income. Implementation of the global corporate minimum tax requires each country to incorporate the rate and rules into its tax system. The United States, as a party to the agreement, needs to adopt the two-pillar plan and impose a 15% minimum corporate tax that aligns with the OECD model. The recently enacted Inflation Reduction Act of 2022 in the US introduced a 15% alternative minimum corporate tax, which brings the US closer to the OECD tax structure. However, further amendments may be required to ensure conformity with the OECD tax rules. If the US corporate minimum tax does not meet the standards of the global corporate minimum tax, Congress would need to pass amendments to the Internal Revenue Code, and bilateral and international tax treaties would also require modifications. Treaties in the US necessitate approval by the Senate and the president.If the US fails to act while other countries implement the minimum tax in 2025, tax revenue in the US could decline by $122 billion over the next decade. On the other hand, if the US does enact the tax, its tax revenue could still decline by $56.5 billion. These estimates are based on a comparison with a baseline scenario where neither the US nor the rest of the world enacts the minimum tax. The analysis predicts that the US would lose revenue when other countries tax the foreign-source income of controlled foreign corporations and when other countries tax US income. However, depending on how companies respond to the new tax regimes and shift their profits, there are scenarios where the US could gain as much as $224 billion in revenue over the next decade. Conversely, the US could lose up to $174.5 billion if multinational corporations allocate their low-taxed profits to jurisdictions applying domestic minimum top-up taxes. The report emphasizes the level of uncertainty in predicting the outcomes and does not represent a likely outcome. The analysis was requested by Senate Finance Committee ranking member Mike Crapo and Ways and Means Committee Chairman Jason Smith, who criticized the Biden administration's handling of the global minimum tax negotiations. The report comes as Republicans remain skeptical of the international agreement signed by nearly 140 countries to establish a minimum tax rate of 15% for multinationals worldwide. In response, the Ways and Means Committee introduced a bill to impose retaliatory taxes on the US income of foreign investors and businesses in countries that impose minimum tax rules on US multinationals.US Could Lose Billions Under Global Minimum Tax, JCT Report SaysJCT: U.S. Stands to Lose Revenue Under OECD Tax DealLegislation that would ban employee noncompete agreements in New York is heading to Governor Kathy Hochul's desk for review. The measure, similar to a recent law enacted in Minnesota, would apply to contracts signed or modified after it becomes effective. Noncompete agreements, which currently cover about one-fifth of the US workforce, have faced criticism from federal and state policymakers. The Federal Trade Commission is in the process of finalizing a nationwide ban on such contracts, and the National Labor Relations Board's general counsel has stated that noncompetes violate federal labor law in most situations. While business groups argue that noncompetes are necessary to protect trade secrets, policymakers and worker rights advocates argue that they are often misused and hinder low-wage workers from seeking better job opportunities. The New York legislation would still allow employment contracts that protect trade secrets and confidential client information, as long as they don't unreasonably restrict competition. The bill has already passed the state Senate and Assembly.New York Ban on Employee Noncompetes Heads to Hochul's DeskThe U.S. Federal Trade Commission (FTC) is set to argue in federal court for a preliminary injunction to temporarily block Microsoft's acquisition of Activision Blizzard, the videogame maker. The FTC wants the deal to be put on hold until its in-house court rules on whether the merger would harm competition in the video game industry. The agency is concerned that without intervention, the combined company could alter Activision's operations and give Microsoft access to sensitive business information. The administrative hearing within the FTC is scheduled to begin on August 2. Microsoft has asserted that a temporary block could jeopardize the deal, but courts typically do not consider real-world consequences in their decisions.FTC to argue Microsoft's deal to buy Activision should be paused | ReutersA group of Credit Suisse AT1 bondholders has filed a class action lawsuit accusing three former CEOs of the Swiss bank, Thomas Gottstein, Tidjane Thiam, and Brady Dougan, along with other executives, of being responsible for the bank's collapse. The lawsuit, filed in a New York court, alleges that the executives engaged in excessively risky trades to achieve short-term returns and bonuses, disregarding sound risk management and compliance with the law. The collapse of Credit Suisse led to the decision by Switzerland's regulator to render around $18 billion of the bank's Additional Tier 1 (AT1) debt worthless, which sparked numerous lawsuits. The class action suit highlights the loss of trust in the bank and the culture of prioritizing profits and self-dealing over responsible risk management.Three former Credit Suisse CEOs accused of excessive risk-taking -court filing | Reuters Get full access to Minimum Competence - Daily Legal News Podcast at www.minimumcomp.com/subscribe
We provide an overview of the Pillar Two GloBE rules and accounting for the new top-up tax.
On this episode of Trade Splaining, hosts Ardian Mollabeciri and Robert Skidmore are joined by Peter S. Goodman, Global Economics Correspondent for the New York Times and author of Davos Man: How the Billionaires Devoured the World. They talk about why he believes rising inequality and the concentration of wealth among billionaires has come not only at the expense of most of the world's population but has not been by accident or natural result of “Globalization”, but rather a conscious push by “Davos Men”. We also talk about why he believes trade oftentimes incorrectly bears the brunt of this blame and carrys so many negative consequences. Ardian and Rob also digest the latest news coming from COP27, Germany and Apples political and economic dilemma when it comes to China and the US, the OECDs Global Minimum Tax as well as big layoffs in the tech industry. The co-hosts are also joined by TS producer Michelle Olguin as she also gives her thoughts on the vibe shift happening right under Boomers, Gen X....and even Millenial's noses.
The Inflation Reduction Act omits the key global minimum corporate tax agreed to by over 135 countries. Will cooperation still happen?
The Inflation Reduction Act omits the key global minimum corporate tax agreed to by over 135 countries. Will cooperation still happen?
What is the global minimum tax? At the end of last week, finance ministers from the G7 countries met in London and formally endorsed a global minimum corporate tax rate. Going forward, companies will have to pay a minimum of 15% tax on their profits. The framework is part of an effort to stop multinationals, and in particular the GAFA companies Google, Amazon, Facebook and Apple, from profit-shifting to tax havens. Tech companies are able to easily move between countries due to the nature of their business. How will the global minimum tax rule actually work? Why do we need such a tax in the first place? In under 3 minutes, we answer your questions! To listen to the last episodes, you can click here : Why are there so many spin offs in the world of cinema? How were the Stonewall riots the starting point for the LGBT struggle? How did Internet Explorer go out of fashion? A podcast written and realised by Joseph Chance. In partnership with upday UK. Learn more about your ad choices. Visit megaphone.fm/adchoices
More than 130 nations are working toward an agreement to ensure that multinational corporations pay a minimum level of income taxes. The second of two “pillars” in this framework would ensure that the world's largest and most profitable companies are taxed in each jurisdiction in which they do business at an effective rate of 15%. Since any rate less than 15% would make the corporation subject to a top-up tax to reach that level, there are concerns about how U.S. general business credits–including the low-income housing tax credit (LIHTC), historic tax credit (HTC), new markets tax credit (NMTC) and renewable energy tax credits (RETCs)–would contribute to lowering effective tax rates below 15%. In this podcast, Michael Novogradac, CPA, and Novogradac partner Brad Elphick, CPA, discuss the global minimum tax and issues associated with it concerning tax credit equity. They discuss how and when potential guidance would affect tax equity investments, potential approaches to mitigate the damage to tax equity investments, how the equity investment exclusion approach would work, how the proportional amortization and HLBV approaches fit, the joint venture rule and portfolio shareholdings. The conclude with the next steps that stakeholders in community development tax incentives should take.
More than 130 nations are working toward an agreement to ensure that multinational corporations pay a minimum level of income taxes. The second of two "pillars" in this framework would ensure that the world's largest and most profitable companies are taxed in each jurisdiction in which they do business at an effective rate of 15%. Since any rate less than 15% would make the corporation subject to a top-up tax to reach that level, there are concerns about how U.S. general business credits'including the low-income housing tax credit (LIHTC), historic tax credit (HTC), new markets tax credit (NMTC) and renewable energy tax credits (RETCs)'would contribute to lowering effective tax rates below 15%. In this podcast, Michael Novogradac, CPA, and Novogradac partner Brad Elphick, CPA, discuss the global minimum tax and issues associated with it concerning tax credit equity. They discuss how and when potential guidance would affect tax equity investments, potential approaches to mitigate the damage to tax equity investments, how the equity investment exclusion approach would work, how the proportional amortization and HLBV approaches fit, the joint venture rule and portfolio shareholdings. The conclude with the next steps that stakeholders in community development tax incentives should take.
In December 2021, the Organisation for Economic Co-operation and Development (OECD) published a widely anticipated “two pillar” model rule for domestic implementation of a 15% global minimum tax.Heather Horn was joined by Jennifer Spang, PwC National Office partner, and Pat Brown, PwC's Washington National Tax Services co-leader, to discuss the challenges and taxation implications of the OECD model rule, along with considerations for how companies can prepare.In this episode, you will hear:1:30 - A refresher on the role of the OECD 4:16 - The evolution of a global minimum tax and potential challenges countries face in adopting the model rule11:56 - Potential interpretations that could impact how countries enact and enforce the model rule20:54 - An overview of the rules and how they create the concept of a minimum effective tax rate25:38 - Adjustments to financial statement income to arrive at global income32:18 - How the global minimum tax computation of the model rule is creating US domestic tax policy implications41:26 - Considerations on how to prepare for rule adoptionWant to learn more? Read the proposed rules, commentary, and illustrative examples. Also, listen to our previous podcast, What global tax initiatives could mean for your company.Jennifer Spang is PwC's National Office income tax accounting leader specializing in tax accounting under US GAAP and IFRS. She has over 25 years of experience helping companies in a variety of industries navigate complex tax accounting matters.Pat Brown is PwC's Washington National Tax Services co-leader. Prior to joining PwC, he spent 16 years in the private sector, including a role as the director of tax policy for a Fortune 50 company. Pat has also served in the US Treasury's Office of Tax Policy as an attorney-advisor and as Associate International Tax Counsel.Heather Horn is PwC's National Office thought leader, responsible for developing our communications strategy and conveying firm positions on accounting and financial reporting matters. She is the engaging host of PwC's accounting and reporting weekly podcast and quarterly webcast series. With over 30 years of experience, Heather's accounting and auditing expertise includes financial instruments and rate-regulated accounting.Transcripts available upon request for individuals who may need a disability-related accommodation. Please send requests to us_podcast@pwc.com.
For years, large corporations have exploited international tax laws to pay less taxes. But last year, 137 countries backed a potential solution: a 15 percent corporate tax applied regardless of a company's location. The reform could raise global tax revenues by $150 billion a year, but as advocates garner political support, there are significant roadblocks. Featured Guests: Shu-Yi Oei (Professor, Boston College Law School) Richard Rubin (U.S. Tax Policy Reporter, Wall Street Journal) For an episode transcript and show notes, visit us at: https://www.cfr.org/podcasts/what-in-the-world-is-a-global-minimum-tax
Poland has vetoed the EU's proposed plan to implement a global minimum tax. Daniel Bunn from the Tax Foundation joins Inside Sources to discuss the future of the tax agreement. See omnystudio.com/listener for privacy information.
Are big countries bullying developing countries under the guise of the OECD's Inclusive Framework? It the framework really inclusive, or is it really an exclusive club of rich countries looking out for themselves? Jeff and Scott discuss these issues with Afton Titus who gives the African perspective.
Scott and Jeff discuss the OECD's Base Erosion and Profit Shifting (BEPS) project with Tom Neubig, a former Economist with the OECD. We answer basic questions about the OECD, BEPS, Pillar One and Pillar Two, which includes the proposed global minimum tax. The project is designed to stop the "race to the bottom" and to prevent large multinational companies from shifting their income to low-tax jurisdictions like tax havens. We also briefly discuss how country by country reporting will help with analysis after implementation.
On this episode of Weaver: Beyond the Numbers, host Tyler Kern discussed the proposed implementation of a Global Minimum Tax with Vince Houk, CPA, Partner-in-Charge, International Tax Services at Weaver. Houk explained that many countries within the OECD are considering certain measures, including a global minimum tax rate of 15 percent for larger companies because it would help to “level the playing field.” In addition to the competition between countries for tax revenue, many have seen the digital age hinder their ability to collect taxes. Together, these two issues have led to low tax rates worldwide and many countries are eager for changes. The Organization for Economic Cooperation and Development (OECD) is looking at three key rules to ensure that countries receive their fair share of taxes: 1. Income inclusion rule; 2. Undertaxed payments rule; and 3. Subject to tax rule The income inclusion rule and the undertaxed payments rule will effectively provide for a minimum rate of tax for multinational businesses, whereas the subject to tax rule will help ensure that a country's tax base is not eroded through certain deductible payments (interest, royalties, etc.) where the recipient country subjects the payment to a low rate of tax. While the income inclusion and undertaxed payments rule would affect multinational businesses with global revenue of more than 750 million euros, it is not clear whether the subject to tax rule will be subject to any threshold. Under the current framework, a key consideration for multinational businesses will be the effective tax rate which could, for example, impact a country's ability to boost their economies through tax incentives. These situations and more are issues the OECD must discuss and iron out before initiating the rule. While it's unclear why the members of the OECD are considering a 15 percent rate, it's evident it will apply to many large companies and may have a significant impact on their tax bill. Weaver's tax professionals are known for helping multi-national clients achieve global business growth. Listen to the full episode to hear all of Houk's insights, and visit weaver.com for more thought leadership. Subscribe and listen to future episodes of Weaver: Beyond the Numbers, The Business of Government on Apple Podcasts or Spotify.
A record number of Americans quit their jobs, the Biden administration warns of a growing supply chain crisis, and Congress eyes a Global Minimum Tax. Get the facts first on Morning Wire. Learn more about your ad choices. Visit podcastchoices.com/adchoices
In this video, we look at the details behind the recent, triumphant announcement that so many countries around the world are agreeing to a global minimum tax. Despite appearances, the results will be far from what people expect. iTrustCapital - https://bit.ly/itrstcptl
This week we examine the recent G7 Summit and responses to the meeting between world leaders over their goals toward unifying against threats from Russia and China. This week, as we pick up recent coverage of Vice President Kammala's southern trip, and how it became mired in controversy following problematic statements the VP made when confronted by the media about the Biden Administration's immigration policies. Meanwhile, a shake up has occurred in Israel as a narrow vote has ousted Israeli Prime Minister Benjamin Netanyahu, who has remained in power for more than a decade. Then getting to the heart of the discussion, we turn our attention toward the 2021 G7 Summit in Cornwall, England, and the response from the international community to the meeting of world leaders. Among the focus of their discussions had been a new global corporate tax, the ongoing battle against COVID-19, and other issues. However, much of the focus of this year's summit also had to do with those countries who were not in attendance--namely China and Russia--and what the response from the G7 member countries should be in the years ahead as the rise of Autocracies in the East remain ever present. Coronavirus Charities: If you are able, please consider supporting the following charities that are offering relief for those affected by the coronavirus pandemic. Visit our Coronavirus Charities Page to learn more. DOLLARS FOR DONUTS A special thank you to those who donated to the podcast this week: RUNE Charles Baldwin Vicky Pinderski Jonathan Taylor Douglas Davis James Malone If you like Middle Theory and want to help support the show, you can donate to the program here: We also offer SUBSCRIPTION accounts for those who would like to make recurring monthly payments to Middle Theory. If you would prefer to SUBSCRIBE to the program, click here to visit our DONATES page, and scroll down below the primary DONATE button. SHOW NOTE ROCKY ROAD: Harris hears criticism from all sides amid difficult first trip White House Insiders Perplexed by Kamala Harris Answers BYE BYE BIBI: Israel's new prime minister is sworn in, ending Netanyahu's 12-year grip Netanyahu Pushed Out In Razor Thin Vote Israel's new government gets to work after Netanyahu ouster Israeli elections: Raucous scenes in Knesset as Benjamin Netanyahu ousted from office BURNING BRIDGES: Netanyahu tries to go 'scorched earth' in last speech, swipes at Biden administration over Iran OPINION: Did Israel Just Have a Constitutional Revolution? Op-Ed: Israel's most diverse coalition ever reaffirms the Middle East's 'miracle' democracy G7: Summit Ends With Agreement on Global Minimum Tax and Common Threats BACKGROUND: What is the G7 summit? History and significance of the world leaders event WHITE HOUSE MEMO: CARBIS BAY G7 SUMMIT COMMUNIQUÉ Biden's Europe Trip Is an End Not a New Beginning PUTIN: Putin dismisses criticism of hacking and internal crackdowns ahead of Biden summit Joe Biden explains how he'll handle Putin meeting AUTOCRATS: G7: Biden says democracies in 'contest with autocrats' as G7 summit ends TAKEAWAYS: G7 2021: Takeaways from President Biden's first summit DISAPPOINTMENT: 'The selfie summit': Why some economists and activists are disappointed with the G-7 ANALYSIS: G7 leaders seek right balance in dealing with their China dilemma Why Leaders Can't Stop Talking About China China denounces G7 after statement on Xinjiang and Hong Kong NATO: Biden and the Democrats Love NATO. Should They? JOIN US: REACH OUT TO MIDDLE THEORY To send us feedback, you can email us here. Also, follow Middle Theory on Twitter too... this is highly recommended, and may even be vital for some of you. Finally, as mentioned earlier, some may be further compelled to donate to the program, which helps keep ads for survival gear, water filters, male enhancement supplements, and do-it-yourself earthworm farming kits off the program.
It's the tax news heard 'round the world: the G7 announced their support for the United States-proposed 15 percent minimum global tax on multinational corporations. CrossBorder Solutions Chief Economist Mimi Song and Director of International Tax Michael Desimone examine the details, contemplate what comes next, and advise MNEs on how they can best prepare. CrossBorder Solutions
In this episode, we go over the reasons behind the new global minimum tax, as well as the implications of something like this going into effect. Despite the common rhetoric, it is not about increasing tax revenue for "cash strapped" governments or creating a "fair playing field" for families and individuals. BOOKS: Tax Free Wealth: https://amzn.to/3e9r220 How Innovation Works: https://amzn.to/2UtsKnN Nomad Capitalist: https://amzn.to/2RD3Sfa
It's certainly not out of the question. Here, Dr. Lorraine Eden, a transfer pricing expert, professor, author -- and lately, podcast rockstar -- explains why. CrossBorder Solutions