The OECD is seeking to reach an agreement on a US side-by-side pillar two deal by the end of the year, the organisation revealed this week.
The controversial side-by-side plan, which came to light in June, would see US-parented groups exempted from pillar two’s income inclusion rule and undertaxed profits rule.
An OECD report released on Wednesday, October 15, said that the side-by-side deal will “preserve the gains achieved under pillar two” and provide greater stability to the international tax system.
It added: “Technical work on design and impact is being undertaken by the Inclusive Framework to explore the evidence base for the issues raised, and to find common ground.
“Further meetings are scheduled for the coming months, with progress continuing and hope for a solution acceptable to all members by the end of the year.”
HMRC publishes approach to dealing with ‘harmful’ tax advisers
UK tax agency HM Revenue and Customs published guidance on Tuesday, October 14, which outlines how it is dealing with “harmful intermediary behaviour”.
Intermediaries include tax advisers, software providers and repayment agents, HMRC said.
Examples of harmful behaviour include advertising to the public in misleading ways, using HMRC’s rules and systems in ways that were not intended, and establishing arrangements that mean taxpayers incur tax penalties and interest.
The tax agency said: “We recognise that most intermediaries provide value to taxpayers, and support HMRC in administering the tax system.
“However, a minority of intermediaries can behave in ways that are harmful to the tax system, HMRC, and taxpayers.”
HMRC explained that it had used its powers to block tax advisers from using its services and reported harmful behaviour to professional bodies or other enforcement organisations such as the Advertising Standards Authority.
In addition, HMRC has published the names of people promoting tax avoidance schemes and taken criminal action against intermediaries involved in fraud.
HMRC can also use the data it collects and conduct risk analysis to spot new issues early and apply anti-money laundering rules to tax advisers, it said.
Ashurst hires senior tax partner in Australia
International law firm Ashurst has appointed Nathan Deveson as a senior partner in its tax practice in Sydney, it announced on Tuesday, October 14.
Deveson, who will join in 2026 from Australian firm MinterEllison, will offer support to the firm’s corporate transactions, projects and energy transition, and real estate practices.
The seasoned Deveson had been a partner at MinterEllison since 2002 and previously served as the firm’s Sydney managing partner.
He also has expertise in stamp duty, land tax, and other state-based taxes in Australia, according to Ashurst.
Deveson said: “Having long admired the strength and depth of the Ashurst team, I have consistently been impressed by the firm’s reputation for excellence, its collaborative culture, and its truly global platform.”
Morgan Lewis hires ex-IRS special counsel as partner
Morgan Lewis has hired former US Internal Revenue Service special counsel Randall Thomas as a partner, the US-headquartered law firm announced on Monday, October 13.
He is joining as a partner in the firm’s Washington DC office, having most recently served as special counsel at the Office of Chief Counsel for the IRS.
Thomas has counselled the US justice department’s tax and appellate divisions and the solicitor general’s office on litigation involving exempt organisations and charitable giving.
He also has experience with supporting IRS audit teams and responding to inquiries from Congress and other federal agencies.
At Morgan Lewis, he will concentrate on advancing the firm’s tax-exempt organisations and broader tax capabilities.
“Randall brings a sharp policy lens and seasoned judgment at a pivotal moment for US tax policy,” said Morgan Lewis chair Jami McKeon.
“His perspective and government service experience further enhance our ability to provide our clients with valuable insight into today’s regulatory decision-making as well as the broader policy shifts shaping the future of the tax-exempt sector.”
‘Bitcoin Jesus’ strikes deal with Trump administration, resolves tax charges
Early bitcoin investor Roger Ver has reportedly struck a deal with the Donald Trump administration, agreeing to pay up to $49.9 million to resolve charges that he evaded tens of millions of dollars in tax.
Ver had previously been charged with mail fraud, tax evasion and filing false tax returns.
News of the deal came via a US Department of Justice court filing on Tuesday, October 14, Reuters has reported.
Ver, said to have avidly promoted Bitcoin, has obtained the moniker ‘Bitcoin Jesus’.
While Trump did not pardon him, the deal does ensure he can avoid being sentenced to prison were he to be convicted at trial at a future date – it is understood.
The deal reportedly calls for the indictment against Ver to be dismissed after one month if he abides by its terms.
In addition, the deal means the Internal Revenue Service may collect up to $49.9 million, covering his tax liability, civil penalty and interest – it has been reported.
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