International

  • May 09, 2024

    Pension Plans Want Witness Stopped In $2B Danish Dispute

    U.S. pension plans accused by Denmark's tax authority of committing $2.1 billion in fraud against the European country by taking illegal refunds on dividends asked a New York federal court to reject the authority's request to depose a witness who pled guilty in Denmark.

  • May 09, 2024

    Voluntary Carbon Credit Trades Will Trigger UK VAT

    Transactions involving voluntary carbon credits in the U.K. will be assessed value-added tax starting in September, HM Revenue & Customs said Thursday.

  • May 09, 2024

    IRS Turning to Final PFIC Rules This Year, Official Says

    The Internal Revenue Service expects to "begin in earnest" this year on final regulations for partnerships that hold stock in passive foreign investment companies, including guidance that would treat partnerships as an aggregate of their partners, an agency official said Thursday.

  • May 09, 2024

    Country Adjustment Would Undermine Common EU Tax Base

    Allowing countries within the European Union to adjust companies' allocated tax base under proposed rules would undermine the rules' goal of streamlining the corporate tax base, according to business groups. 

  • May 08, 2024

    DOJ Says Man Owes $6.2M After Failing To Report Foreign Biz

    A man owes tax penalties of $6.2 million to the U.S. after failing to disclose his ownership interests in two foreign entities from 1997 to 2004, the government told a California federal court Wednesday.

  • May 08, 2024

    Biz Groups Tell 10th Circ. Economic Substance Doesn't Apply

    The economic substance doctrine doesn't apply when a business considers tax in making a choice between two legally permissible alternatives, two organizations told the Tenth Circuit in their briefs supporting Liberty Global's position in its $109 million tax refund bid.

  • May 08, 2024

    4th Circ. Asks If High Court Ruling Bars Credit Suisse Tipster

    A Fourth Circuit panel questioned Wednesday whether a U.S. Supreme Court ruling prevented it from reviving a whistleblower case by a former Credit Suisse employee alleging the bank helped U.S. citizens evade taxes after paying a $2.6 billion criminal penalty.

  • May 08, 2024

    Auto Cos. Brace For EV Battery Compliance Hurdles

    New federal regulations aimed at shoring up the domestic electric vehicle manufacturing supply chain give automakers a much-needed two-year cushion to navigate a compliance minefield, and to figure out how to reinvigorate the recent waning consumer demand for electric vehicles.

  • May 08, 2024

    Africa Should Solve Own Tax Problems, Nigerian Official Says

    The solutions to Africa's taxation challenges should come from those actually on the continent, not the Western world, the chairman of Nigeria's tax authority said at an African Tax Administration Forum meeting, the authority said Wednesday.

  • May 08, 2024

    EGC Won't Annul EU Decision To Toss Spanish Tax Scheme

    The European General Court will not annul a European Commission decision that a Spanish tax scheme for vessels built in its domestic shipyards must be abandoned because it was incompatible with the European Union's internal market, according to a judgment released Wednesday.

  • May 08, 2024

    Ambulance Co.'s Former Owner Gets 6 Years For Tax Evasion

    The former owner of an ambulance company was sentenced to more than six years in federal prison for failing to pay employment taxes to the federal government and obstructing the Internal Revenue Service as it tried to collect, according to Virginia federal court documents.

  • May 08, 2024

    A Foley Hoag Co-Chair Joins Litigation Firm As Name Partner

    Litigation and dispute resolution firm Elliott Kwok Levine & Jaroslaw LLP will operate under a new name after welcoming as its newest name partner a former federal prosecutor who most recently co-chaired Foley Hoag LLP's white-collar crime and government investigations practice.

  • May 08, 2024

    UN To Publish Draft Terms Of Reference For Tax Pact In June

    National governments agreed Wednesday to publish the first draft of terms of reference for the United Nations Framework Convention on International Tax Cooperation for a two-week consultation during the week beginning June 3.

  • May 08, 2024

    EU Races To Deals On Withholding Tax, Digital VAT

    European Union countries are trying to clear the final hurdles for deals on May 14 regarding a withholding tax refund law and a package to modernize value-added tax reporting, although some potential vetoes remain after a preparatory meeting, EU sources said Wednesday.

  • May 08, 2024

    Offshore Drilling Co. Demands $70M Refund From IRS

    The IRS wrongfully withheld $69.7 million in tax refunds to an offshore drilling company, despite acknowledging that the refunds are justified by net operating loss carrybacks authorized by a pandemic law and then promising to pay, the company said in Texas federal court.

  • May 08, 2024

    EU Agrees To Send Russian Assets' Revenue To Ukraine

    European Union countries reached a deal Wednesday to transfer the net income from frozen and immobilized Russian state assets to EU funds for rebuilding Ukraine and buying arms for the country, an EU commissioner said.

  • May 08, 2024

    EU Discusses Monitoring Measures Against Tax Havens

    The European Union is considering an annual monitoring process over defensive measures against tax havens in force in the 27 bloc countries, an EU official said Wednesday.

  • May 08, 2024

    Slow Tax Decisions By EU States Are Harmful, Lawmaker Says

    The slow pace of European Union countries in reaching decisions on tax issues harms the bloc's economy, a conservative member of the European Parliament said in a document sent to journalists Wednesday.

  • May 08, 2024

    EU Calls For Responses On Information Exchange Law

    The European Union's executive branch is seeking responses on the law that governs the exchange of information between tax authorities in the group of 27 nations, as a senior EU tax official said it was time to "assess the need for fine tuning."

  • May 07, 2024

    Biz Orgs. Ask 10th Circ. To Toss Economic Substance Ruling

    The Tenth Circuit must not uphold a Colorado federal court's ruling that it didn't need to determine whether economic substance doctrine was relevant before disallowing an intercompany transaction by Liberty Global Inc., three business groups told the Tenth Circuit in briefs Tuesday.

  • May 07, 2024

    India's Top Court Upholds Tax On Employee Perks

    A catch-all provision in India's tax on employee perks does not grant excessive power to the tax authority, and the tax rate on interest-free loans as perks is not unconstitutional, the Supreme Court of India affirmed Tuesday.

  • May 07, 2024

    Industry Groups Suggest Changes To Aussie Reporting Rules

    A coalition of global fund industry associations asked Australia to further amend its proposal for public country-by-country tax data reporting by including, among other measures, a provision that would allow companies to withhold sensitive information, according to a letter released Tuesday by the U.S. Treasury Department.

  • May 07, 2024

    India High Court Says Biz's Tax Refunds Can't Be Held Back

    Indian tax authorities must refund value-added taxes of 225 million rupees ($2.7 million) to a business instead of withholding them to offset future tax liabilities, the country's top court ruled.

  • May 07, 2024

    Latin American, Caribbean 2022 Tax Revenue Up, OECD Says

    Tax revenue in Latin American and Caribbean countries rose in 2022, thanks in large part to gains in the gas and oil sector, but the average tax-to-gross domestic product ratio in the region still lags behind the OECD average, the organization said Tuesday.

  • May 07, 2024

    14 Arrested In €15M VAT Fraud Ring Tied To Lubricating Oil

    Authorities arrested 14 people as part of an investigation into a crime ring that evaded more than €15 million ($16.1 million) in value-added taxes and other levies tied to lubricating oil, the European Public Prosecutor's Office said Tuesday.

Expert Analysis

  • Mentorship Is Key To Fixing Drop-Off Of Women In Law

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    It falls to senior male attorneys to recognize the crisis female attorneys face as the pandemic amplifies an already unequal system and to offer their knowledge, experience and counsel to build a better future for women in law, says James Meadows at Culhane Meadows.

  • 5 Ways Firms Can Avoid Female Atty Exodus During Pandemic

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    The pandemic's disproportionate impact on women presents law firms with a unique opportunity to devise innovative policies that will address the increasing home life demands female lawyers face and help retain them long after COVID-19 is over, say Roberta Liebenberg at Fine Kaplan and Stephanie Scharf at Scharf Banks.

  • IRS Real Estate Push Should Wake Up Foreign Investors

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    Two recently announced Internal Revenue Service audit campaigns targeting nonresident alien investment in U.S. real estate should prompt foreign investors to prepare for greater scrutiny as the agency works to improve tax compliance around such transactions, say attorneys at Holland & Knight.

  • CFTC Climate Change Report Highlights Costs Of Inaction

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    The Commodity Futures Trading Commission's recent report on climate change and financial markets makes it clear that while government regulation of carbon dioxide pollution may have negative consequences, letting greenhouse gas emissions go unaddressed could harm investors, asset managers and financial institutions, says Nicholas Fox at Goldberg Segalla.

  • Dems' Int'l Tax Policy Comes With Unintended Consequences

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    Former Vice President Joe Biden and Sen. Kamala Harris’ "Made in America" tax policy overstates the importance of revenue raising, which may encourage foreign ownership of global activity and disadvantage U.S.-based companies, says George Callas at Steptoe & Johnson.

  • How Cos. Can Respond To Growing Crypto Tax Enforcement

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    As the U.S. Department of Justice and the Internal Revenue Service remain laser-focused on abusive cryptocurrency schemes, companies operating in this high-risk industry should review their compliance measures in areas such as data analysis, employee oversight and industry benchmarking, say attorneys at Norton Rose.

  • Trump's Tax Tactics May Be Criminal

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    Apologists who defend President Donald Trump as having shrewdly exploited legal loopholes by deducting dubious consulting fees from his taxes are ignoring major badges of fraud that would have led the Internal Revenue Service to investigate any other taxpayer, says Daren Firestone at Levy Firestone.

  • Why Cum-Ex Tax Fraud Probes Are On The Rise

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    ​​​​​​​Neil Williams at Rahman Ravelli outlines why European regulatory investigations into cum-ex — a 1990s-era dividend arbitrage trading practice involving tax rebate claims worth tens of billions of euros — are gaining momentum years after the activities that sparked them, and who should be concerned.

  • Managing New IRS Global High-Wealth Audits

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    Global high-wealth individuals on the receiving end of an audit letter under the Internal Revenue Service Large Business and International Division's new program should prepare for a thorough examination process that includes their entire network of persons and affiliated entities, say attorneys at MoFo.

  • Employers Should Act Now To Mitigate Remote Work Tax Risk

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    Where employees have been overseas since the start of COVID-19 and are nearing the 183-day tax threshold, there is little time left for U.S. employers to incorporate tax planning into policies to ensure more flexible working arrangements do not create tax complexities and risks, says Richard Tonge at Grant Thornton.

  • Pros And Cons Of State Transfer Pricing Program Participation

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    A company's decision to settle a transfer pricing dispute through a state program — such as those recently announced by North Carolina and Indiana — will turn on the quality of its documentation, its willingness to pay for certainty and the perceived level of aggressiveness of the state's revenue department, say attorneys at Eversheds Sutherland.

  • BigLaw Cannot Reap Diversity Rewards Without Inclusion

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    BigLaw firms often focus on increasing their diversity numbers, but without much attention to equity and inclusion, minority lawyers face substantial barriers after they get their foot in the door, says Patricia Brown Holmes, managing partner at Riley Safer.

  • Ideas For Closing BigLaw's Diversity Gap

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    If enough law firms undertake some universal diversity best practices, such as connecting minority lawyers to key client relationships and establishing accountability for those charged with spearheading progress, the legal industry could look a lot different in the foreseeable future, says Frederick Nance, global managing partner at Squire Patton.

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