International
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July 08, 2024
Leftist Bloc That Wants To Tax Rich Wins French Election
A left-wing bloc that promises to increase taxes on the rich won a plurality of seats in elections to the lower house of France's legislature but fell far short of gaining an outright majority.
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July 05, 2024
How Reshaped Circuit Courts Are Faring At The High Court
Seminal rulings from the U.S. Supreme Court's latest term will reshape many facets of American society in the coming years. Already, however, the rulings offer glimpses of how the justices view specific circuit courts, which have themselves been reshaped by an abundance of new judges.
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July 05, 2024
Breaking Down The Vote: The High Court Term In Review
The U.S. Supreme Court's lethargic pace of decision-making this term left the justices to issue a slew of highly anticipated and controversial rulings during the term's final week — rulings that put the court's ideological divisions on vivid display. Here, Law360 takes a data dive into the numbers behind this court term.
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July 05, 2024
The Sharpest Dissents From The Supreme Court Term
The U.S. Supreme Court's session ended with a series of blockbuster cases that granted the president broad immunity, changed federal gun policy and kneecapped administrative agencies. And many of the biggest decisions fell along partisan lines.
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July 05, 2024
The Firms That Won Big At The Supreme Court
This U.S. Supreme Court term featured high-stakes oral arguments on issues including gerrymandering, abortion and federal agency authority, and a hot bench ever more willing to engage in a lengthy back-and-forth with advocates. Here's a look at the law firms that argued the most cases and how they fared.
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July 05, 2024
Top Federal Tax Cases To Watch In The 2nd Half Of 2024
In the coming months, the U.S. Treasury and the IRS will defend rules designed to go after what they consider as abusive tax practices, including the economic substance doctrine, the Corporate Transparency Act and the moratorium on employee retention tax credits. Here, Law360 looks at key federal tax cases to watch in the rest of 2024.
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July 05, 2024
Starmer Picks Reeves For Treasury To Steer Growth Aims
Prime Minister Keir Starmer has handed the reins of the U.K.'s fiscal and economic policy to Rachel Reeves, formally naming her as the next chancellor of the exchequer in the first of a round of cabinet appointments on Friday.
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July 05, 2024
EU Imposes Anti-Subsidy Duties On Chinese EVs
The European Commission imposed provisional import duties of 17.4% to 37.6% on electric vehicles made in China to compensate for what it said were unfair state subsidies throughout the manufacturing and sales process.
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July 05, 2024
EU Official Says Members Blind To Cross-Border Business
A senior European Union tax official has criticized EU member states for failing to adjust their tax systems to help particularly smaller businesses wanting to carry out activities in multiple countries within the bloc.
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July 04, 2024
Labour's Big UK Election Win Clears Way For Tax Reform
Labour's victory in the U.K. general election clears the way for plans to raise taxes on the rich to close a widening spending gap, but it could also mean wider fiscal reform in the new government's first budget later this year.
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July 04, 2024
Labour Sweeps Tories From Power In UK Election Rout
Keir Starmer was poised to become Britain's next prime minister on Friday after his Labour Party ousted Rishi Sunak's Conservatives in a landslide general election victory, ending 14 years of Tory government with a pledge of "national renewal."
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July 04, 2024
EU Should Tighten Fiscal Policies In 2025, Advisers Say
European countries using the euro should tighten their fiscal policies "sizably" next year, combining raising taxes with cuts to spending, depending on national circumstances, an advisory board has said.
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July 03, 2024
Ex-Defense Contractor Evaded Taxes On $350 Million, US Says
A former defense contractor and his wife face a 30-count indictment alleging they were involved in a decadeslong scheme to defraud the U.S. government and avoid taxes on more than $350 million in income, the Department of Justice announced Wednesday.
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July 03, 2024
Warren, Other Pols Push Yellen For Corp. Minimum Tax Rules
Sen. Elizabeth Warren and three other lawmakers urged Treasury Secretary Janet Yellen for the department to quickly release regulations to implement the corporate alternative minimum tax in a letter released Wednesday.
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July 03, 2024
Australia Clarifies Hybrid Mismatch Tax Rules
The Australian Taxation Office issued guidance Wednesday further clarifying two aspects of its hybrid mismatch rules designed to prevent multinational corporations from exploiting differences in tax treatment between jurisdictions.
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July 03, 2024
Former OECD Deputy Tax Director Joining KPMG Australia
A former deputy tax director for the Organization for Economic Cooperation and Development is joining KPMG Australia as a partner starting next month, the firm said Wednesday.
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July 03, 2024
Fox Rothschild Hires Pryor Cashman Nonprofit Leads
Fox Rothschild LLP announced Wednesday the hiring of two Pryor Cashman LLP partners for its corporate department in New York.
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July 03, 2024
Slovenia Tax Incentives Impair Decarbonization, OECD Says
Slovenia's reduced tax rates for certain harmful fossil fuels have hurt the country's efforts to limit its carbon emissions, the Organization for Economic Cooperation and Development said Wednesday.
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July 03, 2024
Gibraltar Expects Draft Top-Up Tax Legislation In September
Gibraltar is planning to have legislation ready for consideration in September that would enact the domestic top-up tax portion of the Organization for Economic Cooperation and Development's Pillar Two standards to fight tax base erosion and profit shifting, a government official said Wednesday.
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July 03, 2024
11 Arrested In €30M VAT Fraud Involving Olive Oil, Sugar
An investigation into a €30 million ($32 million) value-added tax fraud scheme based in Portugal involving essential food products such as olive oil and sugar resulted in 11 arrests, the European Public Prosecutor's Office said Wednesday.
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July 03, 2024
Shifting Taxes From Labor Helps Growth, EU Report Says
Well-designed tax systems can support socially inclusive and sustainable growth in the European Union, such as by shifting taxes from labor to environmental and property taxes, the European Commission said.
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July 03, 2024
Tax Pros Want To Ensure Cooperation Between UN, OECD
A group representing more than half a million tax advisers across three continents said Wednesday that governments and stakeholders should ensure that the Organization for Economic Cooperation and Development and the United Nations work closely in forming global tax policy.
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July 03, 2024
Federal Tax Policy To Watch In The 2nd Half Of 2024
Congressional lawmakers are grappling with the looming 2025 expiration of the 2017 GOP tax overhaul, a situation made more difficult by the coming elections in November that could define what, if any, tax legislation is eventually signed into law this year. Here, Law360 examines federal tax policy to watch in the second half of 2024.
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July 02, 2024
NJ Couple Ordered To Pay $2.5M In FBAR Penalties
A New Jersey couple were ordered to pay $2.5 million in penalties and interest for failing to report their foreign bank accounts in Switzerland, according to court documents.
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July 02, 2024
Eaton Needs To Cough Up Docs In IRS Probe, US Says
The U.S. government urged an Ohio federal judge to order power management multinational Eaton to produce records on certain European employees in response to an IRS investigation, arguing the company's contention the court lacks jurisdiction is "pure sophistry."
Expert Analysis
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How High Court Could Change FBAR Penalty Landscape
On Wednesday, the U.S. Supreme Court will hear Bittner v. U.S., a case that will affect many people penalized for failing to file a Report of Foreign Bank and Financial Accounts, and there are important procedural implications should the government's position be reversed, say Reuben Muller and Andreas Apostolides at Cole Schotz.
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IRS Memo May Change IP Royalty Tax Prepayment Planning
A recent Internal Revenue Service advice memorandum finding a taxpayer was not permitted to prepay tax on contingent royalties after contributing intellectual property offshore is a noteworthy departure from earlier guidance that highlights potential differences between actual and deemed licenses, says William Skinner at Fenwick.
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What IRS Funding Increase Means For Taxpayers
The Internal Revenue Service will first use the influx of funding from the Inflation Reduction Act to address customer support and personnel issues, but with over half the money allocated to enforcement, corporations and high-net-worth individuals will face increased scrutiny, say Patrick McCann Jr. and Jasen Hanson at Chamberlain Hrdlicka.
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6 Tax Considerations For Life Sciences Collaboration Deals
Given recent IRS guidance and changes to certain tax rates and deductions, biotech and life sciences companies entering into collaboration agreements should assess several unique taxation issues affecting matters ranging from research and development expenditures to profit-sharing terms, say attorneys at Orrick and Andersen Tax.
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Rushed Multilateral Negotiations Caused Two-Pillar Tax Mess
Cracks appearing in the two pillars of the 2021 global tax plan stem from a multilateral tax policy process that rushed to issue rules without first resolving fundamental differences between countries or ensuring that the U.S., a key player, could implement them, says Jefferson VanderWolk at Squire Patton.
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Key Considerations For Seeking Relief From Double Taxation
Caroline Setliffe and E. Miller Williams at Eversheds Sutherland lay out the Organization for International Cooperation and Development’s mutual agreement procedure for settling double-taxation disputes, and discuss six factors U.S. taxpayers doing business in multiple countries should consider when determining the most advantageous form of relief.
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2 Tax Decisions Hold Key Transfer Pricing Takeaways
Richard Slowinski and Stefanie Kavanagh at Alston & Bird discuss two recent decisions in cases against the IRS — Eaton Corp. from the Sixth Circuit and Medtronic from the Tax Court — that may help clarify when the agency can cancel an advance pricing agreement, but leave unanswered questions about which pricing method applies to high-value intercompany licensing transactions.
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Digital Taxation Is Necessary, But Tough To Manage
The U.S. government has started to tackle complex new tax laws as the digital economy continues to grow, but this demands guidelines that will facilitate the growth while protecting investors and the government's finances, say attorneys at Cadwalader.
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Company Considerations For Cash Award Incentives: Part 2
Excerpt from Practical Guidance
Cash awards can help companies address some issues associated with equity awards to compensate employees, but due to potential downsides, they should be treated as a tool in a long-term incentive program rather than a panacea, say Denise Glagau and Kela Shang at Baker McKenzie.
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Company Considerations For Cash Award Incentives: Part 1
Excerpt from Practical Guidance
Denise Glagau and Kela Shang at Baker McKenzie discuss what companies must consider when offering cash awards outside of U.S. jurisdictions, and explain how some challenges associated with equity awards may be addressed with cash awards.
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What AML Bill Could Mean For Firms, Funds And FinCEN
If passed, an amendment within Congress’ annual defense bill would expand the list of institutions subject to anti-money laundering regulations, from law firms to investment funds, creating potential rulemaking and enforcement challenges for the Financial Crimes Enforcement Network, say attorneys at Arnold & Porter.
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Unpacking The New Stock Buyback Tax And Its Exceptions
Xenia Garofalo and Kyle Colonna at Eversheds Sutherland discuss provisions of the recently enacted tax on corporate stock repurchases, how its exceptions may be applied and what companies should consider when evaluating the cost of new or existing programs.
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Inside The OECD Transfer Pricing Documentation Guidance
Excerpt from Practical Guidance
The Organization for Economic Cooperation and Development's recently modified documentation guidelines can assist tax administrations in developing requirements for transfer pricing risk assessments and evaluations, and help multinational entity taxpayers demonstrate satisfaction of the arm's-length principle, says Neil Aragones at Lexis Tax.