International
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January 03, 2025
UK Levy Hike Drives Labor Costs Up In 2025, Think Tank Says
U.K. businesses are facing a spike in labor costs, thanks to the government's decision to raise employers' National Insurance contributions, a payroll levy used to fund social programs, a think tank said Friday.
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January 02, 2025
Japanese Cabinet Approves Backstop To 15% Min. Tax
Japan's Cabinet approved a backstop to its 15% global minimum tax that would enable authorities to collect on multinational corporations' profits in foreign jurisdictions taxed below the minimum rate, according to the country's Ministry of Finance.
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January 02, 2025
Republicans Want Yellen To Answer For Chinese Cyberattack
Congressional Republicans want U.S. Treasury Secretary Janet Yellen to explain how a Chinese state-sponsored entity hacked into Treasury's computer systems and accessed potentially sensitive information.
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January 02, 2025
NJ Residents Freed Of $2.1M Tax Bill On Repatriated Income
Two New Jersey residents don't owe state tax on income repatriated under the 2017 federal tax overhaul, the state's tax court ruled, saying New Jersey's personal income tax laws don't include deemed dividends as a category of taxable income.
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January 02, 2025
Feds Ask High Court To Unpause Corporate Transparency Law
The federal government is asking the U.S. Supreme Court to lift a Texas judge's injunction against the Corporate Transparency Act, telling the justices in a new application that the 2021 anti-money laundering law's compliance deadlines should take effect while the Fifth Circuit hears the full case.
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January 02, 2025
IRS, Treasury Float Regs On Excise Taxes For Drugmakers
The IRS and Treasury proposed rules for charging excise taxes to drugmakers that refuse to negotiate drug prices with Medicare under requirements of the 2022 tax and climate law, saying the tax only would apply to manufacturers and importers that initially sell the drugs.
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January 02, 2025
Consolidated Return Regs Revised With Gender-Neutral Terms
The IRS and Treasury finalized rules for companies that file consolidated federal income tax returns, saying the new regulations provide needed modernizations to terminology, including removing gender-specific pronouns.
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January 01, 2025
US International Tax Issues to Watch In 2025
As President-elect Donald Trump and Republicans take control of the U.S. government in 2025, policymakers are expected to address changing international provisions in the Internal Revenue Code and reevaluate the country's role in global tax talks. Here, Law360 examines key U.S. international tax policy issues to watch in the new year.
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January 01, 2025
Federal Tax Policy To Watch In 2025
While Republicans will hold majorities in both chambers of Congress in 2025, internal party divisions and procedural hurdles could complicate the GOP's effort to renew its 2017 tax overhaul law. Here, Law360 details federal tax policy to watch this year.
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January 01, 2025
Top International Tax Cases To Watch In 2025
Major multinational corporations such as 3M and Coca-Cola will continue to litigate high-stakes international tax cases during 2025, including transfer pricing disputes with billions of dollars on the line and fights against regulations that allegedly exceed the government's authority. Here, Law360 looks at six key international tax cases to follow in the new year.
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January 01, 2025
European Tax Policy To Watch In 2025
The European Union may have to go it alone on international tax policy in 2025, especially because President-elect Donald Trump's return to power means the U.S. will likely oppose any multilateral solution to taxing the digital economy. Here, Law360 looks at important European tax developments to watch for this year.
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January 01, 2025
Top Federal Tax Cases To Watch In 2025
Over the next year, tax practitioners will be closely monitoring suits that challenge the IRS' use of the economic substance doctrine, take advantage of the U.S. Supreme Court's landmark decision curbing federal agencies' regulatory authority and dispute the government's handling of worker retention credits. Here, Law360 looks at key federal tax cases to follow in 2025.
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December 23, 2024
Anti-Laundering Law Is Likely Constitutional, 5th Circ. Rules
The Fifth Circuit on Monday lifted a lower court's nationwide block of a federal corporate transparency law, ruling in an unpublished order that the federal government made a "strong showing" that it could successfully defend the law's constitutionality.
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December 20, 2024
Utah Judge Pauses Challenge To Corporate Transparency Act
A Utah federal judge has stayed a case seeking to block the Corporate Transparency Act to see how the new administration of President-elect Donald Trump handles the law after a kindred case in Texas won a preliminary injunction on it.
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December 20, 2024
Rules On Earnings, Profits Still Being Vetted, IRS Official Says
Recently proposed rules for previously taxed earnings and profits aren't able to be relied on by taxpayers until they are finalized because they contain new approaches that have to be properly vetted through a notice and comment period, an IRS official said Friday.
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December 20, 2024
Top Federal Tax Decisions Of 2024
Over the past year, federal courts have issued decisions further delimiting the power of the Internal Revenue Service, with the First Circuit affirming a decision to allow agency summonses for cryptocurrency account records and an Arizona federal court rejecting a call to lift the agency's moratorium on processing pandemic-era worker credits. Here, Law360 reviews some of the most significant federal tax decisions of 2024.
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December 20, 2024
Digital Taxes In Flux Amid Renewed US Tariff Threats
Governments around the world revisited their approaches to digital services taxes this year by adopting broader versions, raising rates, carving out industries and analyzing the impacts of adopting unilateral measures as threats of U.S. tariffs materialize once again. Here, Law360 looks at how countries around the world are considering, adopting or changing their DSTs.
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December 20, 2024
Osborne Clarke Pro Fined £50K Over Zahawi Libel Letter
A tribunal fined an Osborne Clarke LLP partner who represented Nadhim Zahawi £50,000 ($62,700) on Friday for trying to stop a blogger revealing that the former chancellor was contemplating libel action over allegations of dishonesty in his tax affairs.
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December 19, 2024
Atty Exits Denmark's $2.1B Tax Fraud Case After Settlement
A New York federal court removed an attorney from a $2.1 billion tax fraud suit after Denmark's tax authority settled with him on his involvement in the matter, according to recent filings.
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December 19, 2024
Denmark Says $500M Recovered In Dividend Tax Fraud Suits
Denmark's tax administration has recovered a total of 3.6 billion Danish kroner ($500 million) in money lost to suspected dividend tax refund fraud after entering settlements of civil cases in several countries in 2024, Denmark's tax minister announced.
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December 19, 2024
5th Circ. Urged To Deny Tax Break For Doc's Captive Insurance
A physician who owns a network of urgent care clinics was correctly denied tax deductions along with his wife for over $1 million in premiums they paid to insurance companies they owned, the government told the Fifth Circuit, saying the captive arrangements didn't qualify as insurance for tax purposes.
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December 19, 2024
UK Adds Pillar 2 Backstop To Finance Bill
The U.K. government introduced amendments to its latest finance bill Thursday that would update its Pillar Two global minimum tax system and add the backstop to the regime known as the undertaxed profits rule.
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December 18, 2024
Skat Fights To Bring New Cum-Ex Fraud Case Against Broker
The Danish tax authority argued at a London appeals court on Wednesday that it should not be blocked from bringing fresh tax fraud claims against an English brokerage, contending that the claims cover new material not already decided in earlier proceedings.
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December 18, 2024
Morrison Foerster Cites Tariffs As Key M&A Variable For 2025
International law firm Morrison Foerster LLP is among those citing President-elect Donald Trump's tariff plans as a key wild card that could affect mergers and acquisitions deal flow in 2025, a Wednesday report from the firm shows.
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December 18, 2024
Dutch Bank Exec Gave IRS Good Tax Tip, DC Circ. Judge Says
D.C. Circuit judges grappled Wednesday with the denial of a whistleblower award to a late Dutch bank executive who tipped off the IRS to tax reporting schemes, with one judge saying during oral arguments that the executive appeared to have handed the agency "gift-wrapped" evidence of wrongdoing.
Expert Analysis
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OFAC Designation Prosecutions Are Constitutionally Suspect
Criminal prosecutions based on the Office of Foreign Assets Control’s sanctions-related listing decisions — made with nearly unfettered discretion through an opaque process — present several constitutional issues, so it is imperative that courts recognize additional rights of review, say Solomon Shinerock and Annika Conrad at Lewis Baach.
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How The OECD Global Tax Proposal Could Affect M&A
Following agreement on the Organization for Economic Cooperation and Development’s Pillar Two proposal to introduce a global minimum tax, domestic implementation is expected to have a significant impact on international M&A transactions, with financial modeling, deal structuring, risk allocation and joint venture arrangements likely to be affected, say lawyers at Freshfields.
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UK Shares-Tax Proposals Offer Long-Awaited Modernization
The U.K. government's recent consultation on the introduction of a new tax on transactions in securities raises detailed legal and practical issues, but the prospect of a single digital stamp tax offering both streamlined legislation and administration will be welcomed, say Zoë Arnautov and Mark Sheiham at Simmons & Simmons.
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IRS Foreign Tax Credit Pause Is Welcome Course Correction
A recent IRS notice temporarily suspending application of 2022 foreign tax credit regulations provides wanted relief for the many U.S. multinational companies and other taxpayers that otherwise face the risk of significant double taxation in their international operations, say attorneys at Mayer Brown.
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IRS Criminal Probe Spells Uncertainty For Malta Pension Plans
The IRS’ recent scrutiny of Malta pension plan arrangements — and its unusual issuance of criminal administrative summonses — confirms that it views many of these plans as illegal tax evasion schemes, and the road ahead will not be smooth and steady for anyone involved, say attorneys at Kostelanetz.
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IRS Announcement Will Aid Cos. In Buyback Tax Planning
Recent IRS transitional guidance regarding current requirements for reporting and payment of the stock repurchase excise tax will help corporate taxpayers make decisions about records retention and establishing reserves for future tax payments, say Xenia Garofalo and Kyle Colonna at Eversheds Sutherland.
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Flawed Analysis Supports Common Law Tax Deficiency Ruling
The Colorado federal district court’s recent decision in Liberty Global, holding that the U.S. Department of Justice may assert a common law tax claim without the notice of tax deficiency required by the Internal Revenue Code, relies on a contorted reading of the statute and irrelevant case law, say Loren Opper and Christie Galinski at Miller Canfield.
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Review Of Repatriation Tax Sets Justices On Slippery Slope
The U.S. Supreme Court’s recent decision to review the constitutionality of the repatriation tax in Moore v. U.S. has implications for many tax rules involving unrealized amounts and could leave the court on the brink of invalidating large swaths of the Internal Revenue Code, say attorneys at Eversheds Sutherland.
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What To Make Of IRS' New Advance Pricing Guidance
Recent guidance on the IRS' goals for its advance pricing agreement system provides helpful insight into review and decision-making procedures for advance pricing agreement requests, but it also raises questions about the IRS' objectives, say Richard Slowinski and Stefanie Kavanagh at Alston & Bird.
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Reserved Investor Fund Would Plug Gap In UK Finance Market
The reserved investor fund recently proposed by HM Treasury has the potential to be a welcome tax-efficient addition to the U.K.’s canon of products for real estate investments, with attractive features for companies and, in particular, large asset managers, say lawyers at Herbert Smith.
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The Reciprocal Tax Bill Is A Warning Shot At Pillar 2
A bill recently introduced in the House of Representatives to reciprocally tax countries deemed to have imposed discriminatory taxes on U.S. citizens and businesses takes aim at countries implementing the global minimum tax treaty known as Pillar Two, with which the U.S. has not complied, says Alan Cole at the Tax Foundation.
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What Tax-Exempt Orgs. Need From Energy Credit Guidance
Guidance clarifying the Inflation Reduction Act’s credit regime, expected from the U.S. Department of the Treasury this summer, should help tax-exempt organizations determine the benefits of clean energy projects and integrate alternative energy investments into their activities, say attorneys at Morgan Lewis.
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How Foreign Info Return Penalty Case May Benefit Taxpayers
The U.S. Tax Court's recent decision that the Internal Revenue Service cannot penalize taxpayers for failing to file foreign corporation information returns may give similarly situated taxpayers an opportunity to also avoid penalties, provided they protect their rights before the decision is overturned or mooted by legislation, say attorneys at Arnold & Porter.