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G7 global tax plan may hit corporate titans unevenly

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An agreement by wealthy nations aimed at squeezing more tax out of large multinational companies could hit some firms hard while leaving others – including some of the most frequent targets of lawmakers’ ire – relatively unscathed, according to a Reuters analysis.

Finance ministers from the Group of Seven leading nations on Saturday agreed on proposals aimed at ensuring that companies pay tax in each country in which they operate rather than shifting profits to low-tax havens elsewhere.

One proposed measure would allow countries where customers are based to tax a greater share of a multinational company’s profits above a certain threshold. The ministers also agreed to a second proposal, which would levy a minimum tax rate of 15% of profits in each overseas country where companies operate, regardless of profit margin.

The Reuters review of corporate filings by Google-owner Alphabet Inc suggests the company could see its taxes increase by less than $600 million, or about 7% more than its $7.8 billion global tax bill in 2020, if both proposed measures were applied. Google is among the companies that some lawmakers have criticized as paying too little tax.

Meanwhile, medical group Johnson & Johnson, which is also U.S.-based, could see its tax bill jump by $1 billion, a more than 50% rise over its $1.78 billion global tax expense last year, according to Reuters’ calculations.

Both Google and J&J declined to comment on the calculations.

In a statement Saturday following the G7’s agreement, Google spokesman José Castañeda said: “We strongly support the work being done to update international tax rules. We hope countries continue to work together to ensure a balanced and durable agreement will be finalized soon.”

Determining the exact impact the new rules will have on companies is difficult, in part because companies don’t typically disclose their revenues and tax payments by country. And key details about how the rules would be implemented are still pending, tax specialists say, including to which countries profits would be reallocated and to what degree taxes generated by the new measures would offset taxes owed under the current system.

The proposed rules themselves also face hurdles. In the United States, several top Republican politicians have voiced opposition to the deal. Details of the agreement are also due to be discussed by the wider Group of 20 countries next month.

Four tax specialists concurred with Reuters’ methodology but noted that there is still uncertainty about how the measures would be applied, including which tax breaks are included in the 15% minimum overseas tax.

The G7 comprises Canada, France, Germany, Italy, Japan, the United Kingdom and the United States.

“The deal makes sure that the system is fair, so that the right companies pay the right tax in the right places,” said a spokesperson for the UK Treasury, which hosted the G7 meeting. “The final design details and parameters of the rules still need to be worked through.”

SHARING PROFITS

The first proposed measure focuses on large global firms that report at least a 10% profit margin globally. Countries in which the companies operate would have the right to tax 20% of global profits above that threshold in an effort to stop companies reporting profits in tax havens where they do little business.

Applying that formula to Google could result in as much as $540 million in additional taxes, according to the Reuters analysis.

Based on Google’s 2020 global profits of $48 billion, Reuters calculated what portion of that income could be reallocated based on the G7’s proposed formula. Reuters then calculated how much more the company would pay if tax was levied on that portion of income at the rate of 23% – which is the average tax rate for developed nations as identified by Paris-based research body the Organization for Economic Cooperation and Development – rather than the average overseas tax rate of 14% that Google said it paid last year.

Applying the same methodology to J&J, and its 2020 global profits of $16.5 billion, the healthcare company would see its global tax bill rise by about $270 million as a result of the first measure.

The exact impact on each company’s tax bill would depend on how much income is actually reallocated. Also at issue is which country the profit is moved from and to – and therefore what the increase in tax rate is. If all the reallocated profit comes out of zero-tax jurisdictions, the impact could be greater.

MINIMUM TAX OVERSEAS

U.S. and UK officials say the other measure, involving a 15% global minimum tax, will have a bigger total impact on how much in taxes governments collect. But its effect on companies will vary widely. In recent years, Google-parent Alphabet, like some other targets of tax campaigners, has reorganized its international tax structures and last year reported over three-quarters of its global income in the United States compared to less than half in each of the previous three years, according to its corporate filings.

Google reported $10.5 billion of dollars of earnings from outside the United States last year and an average overseas tax rate of 14%, which is one percentage point below the G7’s proposed minimum tax.

If Google’s overseas earnings were all taxed at 15%, the additional tax due would be $100 million. The impact could be higher if a large proportion of the money is earned in zero-tax jurisdictions like Bermuda, where Google used to report over $10 billion a year in income. Conversely, the impact of the minimum tax would be reduced if the first measure prompted Google to reallocate some of its non-U.S. earnings out of tax havens.

Excluding the impact of the first proposed measure, increasing the tax rate on overseas income to 15% would mean $45 million of additional tax.

The situation for J&J would be very different. It earned 76% of its 2020 income outside of the United States and paid 7% tax on average on that overseas profit. Applying a 15% tax rate to that overseas income figure would result in $990 million in additional taxes, according to Reuters’ calculations.

While the reallocation of profit under the first measure would reduce this impact, the combined result of the two measures would be more than $1 billion.

Academics say businesses are adept at mitigating the impact of measures that are designed to reduce tax avoidance and therefore could re-organize in order to limit the impact of the proposed measures. And, in reality, tax incentives offered by governments mean companies may end up paying less in practice.

 

(Reporting by Tom Bergin; Editing by Cassell Bryan-Low)

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Lufthansa sets 2024 goal, eyes capital increase

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Germany’s flagship carrier Deutsche Lufthansa said it aims to boost its return on capital employed (ROCE) and laid out plans for a capital increase as it prepares for a business recovery amid an easing coronavirus pandemic.

The largest German airline aims to have an adjusted EBIT margin of at least 8% and an adjusted ROCE of at least 10% in 2024, it said late on Monday.

Adjusted ROCE was –16.7% in 2020 and 6.6% in 2019.

The group added it had mandated banks to prepare a possible capital increase, though size and timing have not yet been determined and the German state, which has bailed out the airline during the pandemic, has not yet given its approval.

 

(Reporting by Ludwig Burger; editing by Jonathan Oatis)

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Virtual Law Firms Are on the Rise in Canada

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Virtual law firms have been on the rise for a while. In a 2019 roundtable discussion conducted by the American Bar Association, several firm leaders met to discuss the growing presence of online legal services. The consensus was clear: virtual is the new reality.

That was 2019. In the intervening two years, the world was gripped by a global pandemic that forced most people to conduct their business indoors. As you might have guessed, demand for contactless, remote legal services has only ballooned since that roundtable discussion.

While the roundtable primarily focused on the legal industry in the US, you can witness similar trends here in Canada. Like the taxi industry and entertainment distribution industry before it, law is increasingly moving toward digital spaces.

This article explores what virtual law firms are, what benefits they present for Canadian clients, and what kind of clients are driving the virtual law boom.

Not a Change but an Addition

At its best, the shift from brick-and-mortar law firms to virtual isn’t an alteration of legal services as much as it is an addition.

The best virtual law firms do not compromise on service – they still offer traditional legal services with the expertise of real lawyers. The only difference is that they have added a new medium: a more accessible, transparent means of communication and billing.

Why Canadians Choose Online Law Firms

For some clients, the traditional brick-and-mortar firm was hard to give up. They viewed their lawyer like they viewed their doctor: a professional whose in-person expertise couldn’t be replicated in a digital space. Then, the pandemic hit. As millions more Canadians acclimatized to working online, they also habituated to the idea of doing business online.

 

Credit: Ketut Subiyanto Via Pexels

The benefits were immediately apparent. Virtual law firms feature streamlined communication, available seven days a week. They eliminate the need to go to a physical office. They offer all the same legal expertise and services as a brick-and-mortar lawyer. And, crucially, they often leverage transparent pricing: flat, predetermined legal fees with no hidden costs. A client looking for affordable legal services in Mississauga or Toronto, for instance, can simply click a few buttons and hire a lawyer on the spot.

Who Is Using These New Services?

You might be wondering: do they wheel a computer into the courtroom when someone avails themselves of a virtual lawyer? No, that isn’t quite the case.

Clients tend to use virtual law firms for everyday legal services – not necessarily courtroom representation. A client looking to create a will or name a power of attorney might choose a virtual lawyer for the sake of simplicity. A homebuyer, looking to keep costs manageable might hire a virtual lawyer for closing since their prices are both more transparent and affordable. A couple seeking to draft a cohabitation agreement may find similar benefits in an online lawyer.

The fact is that virtual legal services are not only here to stay – they are on the rise. Fortunately, the future is friendly; online law firms offer the same legal expertise as their physically housed counterparts, with the added benefits of being accessible and affordable.

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Tourmaline to expand in Montney with C$1.1 billion deal for Black Swan

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Canada‘s Tourmaline Oil Corp said on Friday it would buy privately owned Black Swan Energy Ltd in a C$1.1 billion ($908.79 million) deal, as the oil and gas producer looks to expand in the Montney region, one of North America’s top shale plays.

Canada‘s Montney, which straddles Alberta and British Columbia, has seen a wave of consolidation as companies buckled under collapsing oil prices amid the COVID-19 pandemic.

Tourmaline said the deal represents a key part of its ongoing North Montney consolidation strategy and the company sees the area as a key sub-basin for supplying Canadian liquefied natural gas.

The company in April acquired 50% of Saguaro Resources Ltd’s assets in the Laprise-Conroy North Montney play for $205 million and entered into a joint-venture agreement to develop these assets.

Analysts at brokerage ATB Capital Markets called the Black Swan assets a “hand in glove” fit with its recent acquisitions.

Tourmaline stock rose 4.5% to C$32.1.

The deal value consists of 26 million Tourmaline shares and a net debt of up to $350 million, including deal costs.

Tourmaline will acquire an expected average production capacity of over 50,000 boepd when the deal closes, likely in the second half of July.

The company, which also raised its dividend by 1 Canadian cent per share, expects the Black Swan assets to generate free cash flow of $150 million to $200 million in 2022 and beyond.

The Canadian energy sector has seen a flurry of deals with companies expecting to benefit from the rebound in oil prices as global fuel demand picks up.

ARC Resources Ltd in April bought Seven Generations Energy Ltd for C$2.7 billion to create Montney’s largest oil and gas producer.

($1 = 1.2104 Canadian dollars)

 

(Reporting by Rithika Krishna in Bengaluru; Editing by Vinay Dwivedi)

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