International
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August 01, 2024
15 Arrested In Albanian Ring Involving Money Laundering
A "prominent money launderer" was among 15 members of what was called a high-profile Albanian organized crime group arrested by authorities under suspicion of crimes including contract killings and money laundering using cryptocurrency transactions, Europol said Thursday.
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August 01, 2024
Australia Slows Tax Pro Conduct Code Update After Blowback
The Australian government is delaying the start of its newly passed changes to the country's code of conduct for tax agent services, which were supposed to enter into force this month, following pushback from industry groups, a minister said Thursday.
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August 01, 2024
Taxpayers Find Belgian Pillar 2 Request Sudden, Intrusive
Belgian demands for detailed information that must be supplied within a short deadline are troubling taxpayers within the scope of the global minimum corporate tax, who said the country's quest for information is more challenging than that imposed by other governments.
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August 01, 2024
UK Capital Gains Tax Liabilities Decline, HMRC Says
Capital gains tax liability in the U.K. declined in the 2022-2023 tax year, HM Revenue & Customs said in a news release Thursday.
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July 31, 2024
Treasury's New 'Killer B' Rules May Revive Controversies
Recent U.S. Treasury Department regulations centered on contentious 2011 guidance aimed at so-called Killer B transactions have revived long-standing questions about how much authority rule writers have to target what they perceive as corporate tax avoidance in these maneuvers.
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July 31, 2024
'Tax Avoidance' Fuels Global Reporting Pushback, Pro Says
A lobbying effort from multinational corporations to dissuade states from adopting mandatory worldwide combined reporting aims to keep billions of dollars in profits that were shifted into tax-friendly jurisdictions beyond the reach of tax administrators, a retired researcher from a progressive think tank said Wednesday.
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July 31, 2024
Cos. Insist Chevron Ruling Doesn't Change Deduction Claims
A medical device company and a food services firm that are each challenging Internal Revenue Service denials of dividend deduction claims told the U.S. Tax Court that the recent U.S. Supreme Court decision overturning Chevron deference doesn't change the validity of their arguments.
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July 31, 2024
SEC Asked For Public Tax Reporting By Group With $2.3T
The U.S. Securities and Exchange Commission was asked Wednesday to begin a rulemaking procedure to require public country-by-country reporting of tax by nearly 90 investment funds, labor unions, activists and others with combined assets over $2.3 trillion.
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July 31, 2024
Americans Overseas Launch Residence Taxation Lobby Group
An advocacy group representing U.S. citizens living abroad announced it has officially registered as a lobbyist to continue to push Congress to pass residence-based taxation laws for the benefit of individuals comparable to those for corporations.
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July 31, 2024
Senators Ask Treasury To Limit Biofuel Tax Credit Eligibility
The U.S. Treasury Department shouldn't grant biofuel production tax credits to companies that use foreign-sourced feedstocks, a coalition of Republican and Democratic senators said in a letter published Wednesday.
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July 31, 2024
DMH Stallard Adds Tax Atty To London Practice
DMH Stallard LLP hired a tax attorney for its London office who spent more than a decade at HM Revenue & Customs working on compliance and policy, according to a news release.
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July 31, 2024
Large UK Cos. Expect Major Pillar 2 Administrative Burden
While businesses largely reported they expect the U.K.'s implementation of the OECD's corporate global minimum tax to have little to no impact on the amount of tax they pay, they also are concerned about the law's administrative burden, HM Revenue & Customs said.
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July 31, 2024
Australia Seeking Members For Pillar 2 Working Group
The Australian Taxation Office said it is seeking members to join a working group focused on the country's implementation of the Organization for Economic Cooperation and Development's Pillar Two global minimum tax.
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July 31, 2024
EU Seeks Feedback On Effectiveness Of Anti-Avoidance Law
The European Commission said Wednesday that it is looking for feedback on how the European Union's anti-tax avoidance directive has fared since going into force in 2020, in particular concerning the bloc-wide implementation of the OECD's global minimum corporate tax standards.
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July 31, 2024
French Politician Wants VAT Cut For Repairs To Churches
A French politician is asking the European Commission to consider expanding the scope of rate reductions for value-added taxes to include the renovation of historic monuments, including churches, according to a letter released Wednesday.
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July 30, 2024
IRS Spinoff Guidance Raises Practical Concerns, NY Attys Say
Recent IRS guidance narrowing the corporate spinoff transactions that revenue officials will approve as tax-free ahead of time doesn't adequately consider the practical and commercial factors involved in these transactions, the New York State Bar Association's Tax Section said Tuesday.
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July 30, 2024
Israeli Man Seeks To Avoid Discovery In $3.6M FBAR Case
A federal court should not order the Israeli founder of a pet toy company to show cause for defying its discovery orders in the U.S. government's $3.6 million case over his failure to report foreign bank accounts because he is ending his defense, his attorneys said Tuesday.
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July 30, 2024
Kyocera Chides Gov't Attack On Jurisdiction In $7M Tax Case
The government's attempt to defeat a South Carolina federal court's jurisdiction is improper because it relies on a roughly $44 million assessment lodged months after electronics maker Kyocera filed an amended complaint for a $7 million federal tax refund, according to the company.
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July 30, 2024
Ropes & Gray Adds Partner To Int'l Tax Practice
Ropes & Gray LLP recently added a tax adviser with a wealth of experience navigating transactions, funds and investments for clients as a partner in its New York office, the firm said.
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July 30, 2024
Chubb Says It Would Be Harmed By US-Swiss Treaty
Chubb and its shareholders would be significantly harmed by the terms of a proposed new bilateral tax treaty between the U.S. and Switzerland because it would be denied tax relief despite having been domiciled in Switzerland for over 15 years, the global insurer said in a letter released Tuesday.
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July 30, 2024
Husch Blackwell Hires UB Greensfelder Partner In St. Louis
Several years after Husch Blackwell LLP's newest partner, Garrett Reuter Jr., graduated from law school, he joined Greensfelder Hemker & Gale PC to work alongside his late father. Now, he's bringing clients he grew up watching his father work with, to a new platform.
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July 30, 2024
UK Healthcare Ex-Directors Banned For £30M In Unpaid Taxes
Two former directors of a defunct U.K. healthcare company are banned from holding executive positions at any business after failing to pay more than £30 million ($38.5 million) in taxes, the government's insolvency agency said Tuesday.
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July 30, 2024
Israel Moving To Adopt Portion Of Global Minimum Tax
Israel's Ministry of Finance said it is working to adopt a portion of the Organization for Economic Cooperation and Development's 15% global minimum tax on large multinational entities starting in 2026 while delaying consideration of two other portions.
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July 30, 2024
Tax Pros Vent Displeasure At EU Disclosure Law
Tax professionals commenting on a European Union disclosure law by the deadline Tuesday vented long-held displeasure at the measure, which requires tax preparers to reveal cross-border strategies.
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July 30, 2024
Pension Tax Reform Could Unlock £100B For UK Growth
Changing how pensions are taxed in the U.K. could potentially unlock more than £100 billion ($128 billion) for domestic investment over the next five years, according to a recent analysis by a pensions consultancy.
Expert Analysis
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How OECD Transfer Tax Initiative Affects Smaller Businesses
Small and midsize enterprises with cross-border transactions need to consider redefining tax strategies and operational models in light of the Organization for Economic Cooperation and Development's base erosion and profit shifting initiative, even though the agency's new tax guidelines are aimed at large multinational enterprises, says Ganesh Ramaswamy at Kreston Rangamani.
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What The New OECD Double-Tax Procedure Statistics Tell Us
Monique van Herksen and Clive Jie-A-Joen at Simmons & Simmons consider the Organization for Economic Cooperation and Development’s recent report on double taxation cases resolved in 2020 under the mutual agreement procedure process, and examine whether the process has improved dispute resolution mechanisms since its implementation five years ago.
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Navigating FCPA Risks Of Minority-Owned Joint Ventures
The U.S. Department of Justice and U.S. Securities and Exchange Commission will likely continue to focus on third-party risks under the Foreign Corrupt Practices Act, so companies with minority-owned joint ventures should take several steps to mitigate related compliance challenges, say Ben Kimberley at The Clorox Company and Addison Thompson at Covington.
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Questions To Ask If Doing Business In A Corruption Hot Spot
Businesses facing new scrutiny after the U.S. Department of Justice's recently announced task force for combating human trafficking in Central America, the release of the Pandora Papers and continuing fallout from 2019's Panama Papers, should address compliance risks by having employees ask three questions about every transaction, say attorneys at White & Case.
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How The Global Tax Agreement Could Backfire For Biden
If the $3.5 trillion spending package fails, the federal tax code will not conform to the recent 15% global minimum tax agreement spearheaded by the U.S., which would embarrass the Biden administration and could lead to retaliatory tax measures by other nations, says Alex Parker at Capitol Counsel.
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Pandora Papers Reveal Need For Greater Tax Enforcement
The recent Pandora Papers leak is a reminder of the importance of transparency laws and proper funding for enforcement efforts against tax evasion as bad actors increasingly operate in the shadows, says Daren Firestone and Kevin Crenny at Levy Firestone.
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Parsing New Int'l Tax Reporting Rules For Pass-Throughs
Attorneys at Grant Thornton unpack the Internal Revenue Service’s new pass-through entity reporting requirements for international tax matters and the accompanying guidance for penalty relief, and suggest how companies should prepare for what may be the most significant change to the partnership compliance function in decades.
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A Look At Global Tax Enforcement Developments: Part 2
Excerpt from Practical Guidance
Sean Craig at LexisNexis examines recent investigations by the Joint Chiefs of Global Tax Enforcement and their impact on U.S. taxpayers, as well as the growing significance of transfer pricing disputes and policies for future enforcement.
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A Look At Global Tax Enforcement Developments: Part 1
Excerpt from Practical Guidance
Sean Craig at LexisNexis looks at how international initiatives, such as the Joint Chiefs of Global Tax Enforcement, are addressing cryptocurrency-related tax evasion, and how the COVID-19 pandemic and increasing demands for governmental welfare programs are driving global tax policy.
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EU Climate Plan Should Involve Taxing Pollution, Not Borders
In order to crack down on greenhouse gas emissions, the European Union proposes to levy carbon emissions at its borders and to overhaul its long-standing energy tax framework, but the latter would hold polluters directly accountable, giving it the better chance for success, says Rebecca Christie at Bruegel.
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Prepare For Global Tax Regime's New Biz Dispute Risks
Companies should take steps to mitigate the business dispute risks of the new international tax framework, which over a hundred countries agreed to in July, as implementing the new regime will be expensive and require substantial organizational restructuring efforts, says Tim McCarthy at Dykema.
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Prepare For More Audits Of Tax Info And Withholding Filings
Financial institutions and other corporate taxpayers should focus compliance efforts on tax information reporting and withholding, given recent indications from the Biden administration that the IRS will increase enforcement, and the administration's need to fund its infrastructure plan and other costly initiatives, say attorneys at Mayer Brown.
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Anti-Boycott Compliance Still Key In UAE Business Dealings
Notwithstanding recent amendments to U.S. anti-boycott laws that reflect the United Arab Emirates' withdrawal from the Arab boycott of Israel, companies doing business in the UAE and elsewhere still need to maintain effective anti-boycott compliance programs to avoid reporting violations or penalties, says Howard Weissman at Miller Canfield.