The 2021 Africa Cup of Nations, known as AFCON 2021, kicked off earlier this month. If that has you scratching your head, let me clarify: the tournament was supposed to have been played in the summer of 2021 but was rescheduled due to the pandemic. Even though it began in 2022, the name remained as it had been for branding purposes.
The tournament was big news in our house. My son is a soccer—or football in the rest of the world—fanatic, and two of the players at AFCON 2021 played professionally for his favorite team, the Philadelphia Union.
Those of you who follow me on social media may also know that, despite his age, my son writes a soccer blog. In the run-up to the tournament, he wrote a few posts analyzing the talent on the teams and making his predictions. When it came to the Round of 16, he predicted that Gabon, Nigeria, Guinea, Cameroon, Cape Verde, Morocco, Ivory Coast, and Equatorial Guinea would advance. He went three for eight.
When we were talking about it later, he remarked on his misses, saying, “I should have known how hard it would be to predict winners in an unpredictable tournament.” That was a throwback to his remarks last year that there could be some “surprises in a tournament already famous for its lack of predictability.”
After reminding him to avoid the tables in Vegas, we chatted about how sports can be that way sometimes. Even though he’s in the U.S., my son follows international soccer with great attention. He constantly reads newspapers and soccer magazines—and has Transfermarkt notifications on his phone. If I trusted anyone in my circle to get it right, it would be him. And yet, his predictions fell flat.
On some level, it was sheer bad luck. Three of those games were decided on penalties. Red cards, or expulsions, were handed out in five of those games. And in one game the goalkeeper was an outfield player, since the original goalkeeper was injured, and the backup keepers were quarantined after testing positive for Covid.
No matter how certain you might be about a particular outcome, there is always the possibility that something could shake it up. That’s true in soccer—and it’s true in tax. Tax practitioners have learned that the hard way since the beginning of the pandemic.
There’s value in knowing what to expect. And this week, as always, our experts have the latest federal, state, and international tax analysis to help you stay a step ahead.
But there’s also value in being prepared for the unpredictable—and trying to sort it out afterward. Our experts have written about that, too, this week. It’s a great reminder that when things don’t always go to plan, that’s not the time to give up—it’s the time to take another look at your strategy. You may still be able to eke out a win after all.
And in case you’re wondering, despite his record, my son’s pick to win it all in AFCON 2021—Morocco—remains in the tournament. The final is Sunday, Feb. 6, at 2:00 p.m. EST.
The Exchange… It’s where great ideas intersect.
—Kelly Phillips Erb
Quick Numbers Trivia
In addition to bragging rights, AFCON winners receive cash prizes. How much will this year’s winner receive?
Answer at the bottom.
Our Roundup
This week, our experts touched on a wide range of topics, from litigation to tax treaties. For a look at what’s making news, here’s our roundup:
Taxpayers don’t like uncertainty, but sometimes it feels inevitable. In What’s Certain in State Tax Litigation: Unpredictable Outcomes, Michael J. Semes of Baker & Hostetler LLP takes a look at opinions written by Pennsylvania Supreme Court Justices David N. Wecht and Debra Todd and discusses the difficulty in predicting the outcome of state tax litigation.
Is remote work the new normal? In Six Key Considerations for a Successful Remote Work Strategy, Jason Walker and Rey Ramirez of Thrive HR Consulting say that employees may be in a position to demand remote work—and employers should be ready with a strategy.
What happens if things don’t go to plan? In late December, the OECD released model rules for the global minimum tax with a goal for implementation focusing on 2023. But, writes George Salis of Vertex, Inc. in Three Hurdles to Implementing OECD’s Global Minimum Tax, it’s not a sure thing—at least three critical contingencies could become a major obstacle for implementation.
Even if you think you know the rules, there could be a surprise. Before undertaking any trading activities in Vietnam, entities with foreign direct investment must be aware of complex regulations. In Trading in Vietnam—Regulations for Foreign Direct Invested Entities, Tran Nguyen Mong Van of Grant Thornton Vietnam discusses the regulations and shows how businesses can ensure that they comply with the rules.
Nothing stays the same. In India Inc.'s Expectations of Budget 2022, Rakesh Nangia and Neha Malhotra of Nangia Andersen LLP look ahead to potential changes to be introduced in India’s Budget 2022, and discuss whether they will address the needs of business as well as boosting the economy.
Redomiciliation allows for business continuity, but only if you know what to expect. In London Calling? Government Proposes Overseas Companies Re-Domicile to the U.K., Elizabeth Small of Forsters LLP looks at the U.K. government’s proposed scheme for international companies to re-domicile to the U.K. and assesses the processes and potential tax implications for businesses that contemplate doing so.
Tax treaties can help taxpayers avoid an unpredictable outcome. In Brazil—Application of Double Tax Treaties to Cross-Border Service Fees, Ricardo Maitto of TozziniFreire Advogados summarizes the Brazilian tax administration’s current position on the application of double tax treaties to outbound payments of service fees by Brazilian companies and considers the practical impact for multinational groups that have entered into cross-border services agreements with their Brazilian subsidiaries.
If the path forward were always clear, we probably wouldn’t need courts—but conflict is inevitable when it comes to laws between states. In a two-part series focusing on a closely watched case currently on appeal before the Massachusetts Supreme Judicial Court, Jaye A. Calhoun, Bruce P. Ely, and Kelvin M. Lawrence discuss the relevance of the unitary business principle as the sole test for determining whether a state can tax an apportioned share of a non-domiciliary’s capital gains under the U.S. Supreme Court’s Due Process Clause and Commerce Clause jurisprudence.
- VAS Holdings and the Battle Over Taxing Non-Unitary Capital Gains
- Full Speed Ahead: Competing Amicus Briefs in the VAS Holdings Case
Opinion and Commentary
The Build Back Better Act has stalled in Congress. President Joe Biden said last week that he’d settle for enacting as much of it as possible. A Bloomberg Editorial suggests in To Revive Build Back Better, Set Some Priorities that if the administration is willing to prioritize and apply sound fiscal policy, the result could be a better bill—or bills—with every chance of passing.
Don’t look for Republicans to run on the same economic message they used 12 years ago, writes Conor Sen, when they emphasized spending cuts to address states’ economic problems states following the 2008 financial crisis. Today, state coffers are flush with cash, and more pressing concerns for many are disruptions to daily life caused by labor shortages. In Biden’s Economy Gives GOP Governors Money to Burn, Sen writes that you should expect Republican governors to put forward a mix of both tax cuts and spending increases to shore up voter support in this election year, which will mean a different outcome both for the economy over the next couple years as well as the GOP.
Columnists & Contributors
You can’t always know how proposals for change will be received. The IRS’ latest efforts to combat ID theft are causing controversy: Selfies. Here’s what you need to know about verifying your identity, including what services you can access—and those you can’t—if you don’t want to snap a photo on your smartphone.
Listen In
The European Union is targeting 2023 to implement the OECD’s 15% minimum tax. Companies will have to overhaul the way they collect information internally to be able to accurately calculate their effective tax rate for each jurisdiction. In this week’s episode of Talking Tax, Bloomberg Tax reporter Isabel Gottlieb speaks with Marlies de Ruiter, global international tax policy leader at EY in the Netherlands, about what to watch for from the OECD, and what it means for corporate taxpayers.
In this week’s episode of the Taxgirl podcast, I sort through the Taxgirl mailbag of questions submitted by listeners and column readers. From what taxpayers have to know when they’re paid under the table to whether it’s necessary to report gifts, I chat about some of my most common tax questions.
Get Caught Up
It’s been a busy week in tax news from state capitals to D.C. Here are some of the stories you might have missed from our Bloomberg Tax news team:
- In response to criticism that it hasn’t done enough to provide penalty relief to taxpayers, the IRS said Wednesday that it is committed to looking for ways to help.
- IRS Commissioner Chuck Rettig, former President Donald Trump’s pick to run the tax agency, said that the agency needs the $80 billion in President Joe Biden’s economic agenda to fund the tax laws, a measure that Republicans in Congress have criticized.
- President Vladimir Putin backs a Russian government proposal to tax and regulate mining of cryptocurrencies, rejecting the central bank’s proposal to ban it completely, according to three people familiar with the matter.
- Prime Minister Boris Johnson’s government is resurrecting a proposal to eliminate the value-added tax from energy bills as ministers consider ways to alleviate the growing cost-of-living crisis in Britain.
- Massachusetts senior citizens, renters, and low-income taxpayers would be able to claim $700 million in tax benefits under Gov. Charlie Baker’s $48.5 billion fiscal year 2023 budget proposal.
- KPMG LLP said it would give its thousands of U.S. professionals their second salary increase in less than six months to keep them on the payroll and entice others to join its ranks amid high turnover and demand for its services.
*Note: Your Bloomberg Tax login will be required to access Tax News.
Spotlight
Our Spotlight series highlights the careers and lives of tax professionals across the globe. This week’s Spotlight is on Jessica Harger, who focuses primarily on tax insurance on Aon’s Transaction Solutions team in New York.
Be Noticed
At Bloomberg Law, we’re proud of our continuing efforts to highlight the next generation of leaders in the legal profession.
We’re thrilled to announce our call for 2022 nominations for “They’ve Got Next: The 40 Under 40,” Bloomberg Law’s special report recognizing the accomplishments of sterling young lawyers nationwide.
Here are nomination criteria and submission instructions.
Quick Numbers Answer
The winning team will receive $5 million, while the second-place team will receive $2.75 million. Teams knocked out before the quarter-finals won’t receive a prize.
By comparison, winners of the European Championships in July 2021 received $11.1 million while champions of the Copa America took home $6.5 million.
Be Social
Follow Bloomberg Tax on Twitter, Facebook, Instagram, and LinkedIn—and check out Bloomberg Law on TikTok.
We also have a growing LinkedIn group where our authors, contributors, and readers can share tax-related stories and exchange ideas. We hope you’ll join the conversation!
What Did You Think?
Your feedback and suggestions are important to us, so don’t hesitate to reach out on social or email me directly at kerb@bloombergindustry.com.
To contact the reporter on this story:
Learn more about Bloomberg Tax or Log In to keep reading:
See Breaking News in Context
From research to software to news, find what you need to stay ahead.
Already a subscriber?
Log in to keep reading or access research tools and resources.