International
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July 23, 2024
Newell Says IRS Misapplied Pricing Law In $124M Dispute
Newell Brands told the U.S. Tax Court the Internal Revenue Service misapplied transfer pricing law to levy almost $124 million in additional taxes and penalties.
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July 23, 2024
IRS Notice Signals Direction On Corp. AMT Regs, Official Says
An Internal Revenue Service notice regarding the U.S. corporate alternative minimum tax can be read as a signal about how the agency will more broadly address the measure's potential for counting offshore income twice, an IRS official said Tuesday.
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July 23, 2024
Winston & Strawn Adds MoFo Tax Pro As Partner In NY
Winston & Strawn LLP has added a transactional tax specialist from Morrison Foerster LLP as a partner with the firm's transactions department and tax practice in New York.
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July 23, 2024
India Eyes End Of Digital Tax For E-Commerce, But Not Ads
Foreign e-commerce companies would be exempted from India's equalization levy, a 2% digital tax, but online advertisers would continue to pay a 6% rate on gross revenues sourced to Indian customers under a budget bill presented Tuesday by the government.
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July 23, 2024
Australia Mulling Higher Foreign Resident Capital Gains Tax
The Australian Treasury said Tuesday it is seeking feedback on a plan to increase the country's capital gains withholding tax rate for foreign residents, among other plans it said will strengthen the country's foreign resident capital gains tax regime.
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July 23, 2024
EU Seeking Comments On Digital VAT Exemption Certificate
The European Commission is seeking public comments on a proposal to replace the current paper version of certificates for value-added tax exemptions with a digital version, the European Union's executive branch said Tuesday.
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July 23, 2024
Former Doctor To Be Released From Jail In FBAR Fight
A former doctor will be released from U.S. custody after a Michigan federal court lifted Tuesday an order of civil contempt against him for failure to pay about $1 million in foreign account reporting penalties.
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July 23, 2024
Orrick Hires Ex-Winston & Strawn Tax Partner In Chicago
Orrick Herrington & Sutcliffe LLP announced the hiring of a former partner at Winston & Strawn LLP for its renewables tax equity and tax credit team.
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July 23, 2024
5-Hour Energy Partner Owes No Tax On Sale, DC Circ. Says
The D.C. Circuit found Tuesday that a Canadian citizen's $6.5 million in gains from her sale of a U.S. partnership interest in a company that sold 5-hour Energy drinks was not federally taxable as inventory income, reversing a U.S. Tax Court ruling.
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July 23, 2024
Hungary's EU Leadership Could Slow Tax Progress
Hungary's six-month term leading meetings of European Union ministers could hinder progress toward agreement on tax legislation, as the country's position on the war in Ukraine alienates other bloc members.
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July 23, 2024
EU Parliament's New Tax Group Head Has Eye On Evasion
The newly elected chair of the European Parliament's subcommittee on tax affairs said Tuesday that a major committee goal would be to examine the issue of tax fraud and evasion at a multinational level.
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July 22, 2024
3 Policies Tax Pros Want Congress To Pass This Year
As momentum around the House-passed tax break bill has fizzled and election season ramps up, tax experts hope lawmakers use what little time they have left to extend expired research tax breaks, approve the Taiwanese tax agreement and pass disaster relief before the end of the year. Here are three policy changes tax professionals think Congress should make before the end of the year.
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July 22, 2024
HMRC Wins Appeal Over Taxation Of Partnership Rewards
Financial rewards from a partnership were taxable as income even though they were made at the partnership's total discretion and the partners had no legally enforceable right to receive them, a London court ruled, siding with HM Revenue & Customs.
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July 22, 2024
US Treasury Working To Extend Pillar 1 DST Compromise
As OECD-led negotiations continue on a taxing rights overhaul known as Pillar One after a missed June deadline, the U.S. Treasury Department is working to extend the political agreement between it and several countries to nullify their digital services taxes once the rights overhaul is implemented.
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July 22, 2024
Pension Plans Slam Biz Docs In $2B Danish Tax Fraud Case
Denmark's tax agency has produced experts who are relying on unauthenticated documents in litigation accusing U.S. pension plans of participating in a $2.1 billion fraud scheme, the pension plans claimed in urging a New York federal court to exclude the testimony.
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July 22, 2024
Argentina Broadens Access To Beneficial Ownership Info
Argentina is opening up access to its collection of beneficial ownership information in what it is calling a "significant advance" in transparency and anti-money laundering and terrorist financing measures in line with international standards.
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July 22, 2024
UN Aims Tax Convention At Digital Economy, Rich Individuals
The United Nations General Assembly should take aim at taxation of the digital economy and wealthy individuals in a framework convention on international tax cooperation, according to a U.N. committee's revised draft term of reference released after a consultation.
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July 22, 2024
Spain Busts €100M Hydrocarbon VAT Fraud Scheme
Spanish authorities said they busted a suspected tax fraud scheme involving the sale of large quantities of hydrocarbons at below-market prices that ultimately defrauded Spain out of more than €100 million ($109 million) in corresponding value-added tax payments.
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July 22, 2024
South Korea, Turkey Amended Tax Treaty Takes Effect
An amended version of the treaty to avoid double taxation between South Korea and Turkey, which features lower maximum tax rates on dividend and interest income earned by those covered by the treaty, has taken effect, South Korea said.
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July 22, 2024
Kyocera Failed To Back R&D Credits With Records, US Says
Multinational electronics maker Kyocera AVX Components Corp. failed to back up its claim to research tax credits with the required paperwork, the U.S. government told a South Carolina federal court in asking it to stop part of the company's nearly $9 million refund suit from going to trial.
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July 22, 2024
Challenge To Romanian Trading Tax Referred To ECJ
Europe's highest court has been handed a challenge to trading tax in Romania, as a national court seeks guidance on whether EU law would prevent a member country from creating an extra tax liability for some participants in the wholesale energy market.
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July 19, 2024
Edwin Coe Adds To Team Ahead Of Planned UK Tax Changes
Edwin Coe LLP is preparing for an expected surge in disputes following the U.K.'s planned tax changes by hiring as a partner a Harbottle & Lewis lawyer with expertise in litigation and tax planning, according to a news release.
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July 19, 2024
Luxembourg Floats Corp. Tax Cut To Boost Attractiveness
Corporations in Luxembourg may see their income tax rate drop by a percentage point in a bid to make the country more attractive to businesses as part of a larger proposed tax package presented by its finance minister.
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July 19, 2024
6 Nations Must Improve Transparency Measures, OECD Says
Six countries were found largely compliant with the Organization for Economic Cooperation and Development's tax transparency and exchange of information measures due to needed improvements to their beneficial ownership information mechanisms, the organization said Friday.
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July 19, 2024
Attorney Denied Separate Trial In $2.1B Danish Tax Fraud
An attorney facing trial alongside his clients for alleged ties to a $2.1 billion Danish tax fraud has been denied a separate hearing by a New York federal court, which remained unconvinced that his co-workers' advice to the clients could rebound on him prejudicially in a joint trial.
Expert Analysis
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How Taxpayers Can Prep As Justices Weigh Repatriation Tax
The U.S. Supreme Court might strike down the 2017 federal tax overhaul's corporate repatriation tax in Moore v. U.S., so taxpayers should file protective tax refund claims before the case is decided and repatriate previously taxed earnings that could become entangled in dubious potential Section 965 refunds, say Jenny Austin and Gary Wilcox at Mayer Brown.
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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.