International
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May 27, 2024
EU Flags 6 Countries For Failures On Transparency Law
The European Commission flagged six countries for deficiencies in its implementation of an EU law requiring some companies to publish their tax data, the EU's executive said in a news release.
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May 27, 2024
Fiji Joins International Framework Against Tax Avoidance
Fiji joined an international group of jurisdictions aiming to stop tax avoidance, the Organization for Economic Cooperation and Development said Monday, adding that the country would participate in the two-pillar solution to change tax rules for large multinational companies.
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May 24, 2024
Court Upholds Limit To Award In Ecopetrol, Texas Co. Dispute
An arbitration tribunal was within its authority to limit the number of years and the amount that a Houston-based oil company had to reimburse Colombia's state-owned entity, Ecopetrol, for the value-added tax liability of a subsidiary while owned by the company, a New York federal judge determined.
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May 24, 2024
CohnReznick Adds Tax Planning Partner From Mazars
CohnReznick LLP added a top accountant and tax partner from Mazars USA LLP to its roster of tax professionals, the firm announced.
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May 24, 2024
Global Minimum Tax Should Be Tied To Inflation, Report Says
The €750 million ($814 million) annual revenue threshold for businesses to be considered in scope of the OECD's global corporate minimum tax should be indexed to inflation to protect businesses from being wrongly forced to comply, a think tank report said.
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May 24, 2024
UK Calls On Belarus To Undo Suspension Of Tax Agreement
The U.K. is demanding that Belarus reverse a council resolution that suspends provisions of the double-taxation agreement between the two countries starting June 1, according to a statement released by HM Revenue & Customs.
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May 24, 2024
IRS Corrects Notice On Bonus Energy Tax Credit Safe Harbors
The Internal Revenue Service and U.S. Department of the Treasury issued a correction Friday to a notice providing additional safe harbors that clean energy project developers can use to qualify for bonus tax credits for domestically sourcing their steel and aluminum parts.
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May 24, 2024
€14M VAT Fraud Scheme In Belgium, Netherlands Busted
Seven people were arrested in the Netherlands in connection to a value-added tax fraud scheme involving the Belgian subsidiary of a Dutch company fraudulently claiming a €13.7 million ($14.9 million) refund on trades of goods that never happened, the European Public Prosecutor's Office said Friday.
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May 24, 2024
EU Withholding Tax Deal Lacks Ambition, Investors Say
A recently agreed-to streamlining of how cross-border withholding taxes are refunded in the European Union lacks ambition and may not do much to help smaller investors, investor advocates said.
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May 24, 2024
Taxation With Representation: Davis Polk, Wachtell, Latham
In this week's Taxation With Representation, SouthState Corp. buys Independent Bank Group Inc., CyberArk acquires Venafi, Carlyle clinches its fifth Japanese buyout fund, and AuditBoard Inc. agrees to be bought by Hg Capital.
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May 24, 2024
Cyprus, Portugal Aim For National Implementation Of Pillar 2
Cyprus and Portugal both said Friday that they are moving toward putting the minimum tax known as Pillar Two into their national legislation, which EU law requires them to have done by the end of 2023.
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May 23, 2024
Premier League Team Goes Down 2-Nil In VAT Bill Appeal
Premier League soccer team Nottingham Forest must pay its more than £345,000 ($438,000) value-added tax bill, the U.K.'s Upper Tribunal ruled in a decision published Thursday, dismissing an appeal of a lower court ruling that found HM Revenue & Customs filed its tax assessment on time.
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May 23, 2024
Italy Adopts Safe Harbor Global Minimum Tax Rules
Italy has added a temporary safe harbor provision to its implementation of the Organization for Economic Cooperation and Development's global minimum tax to ease the transition for in-scope companies, the country's finance ministry said.
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May 23, 2024
White & Case Adds Former A&O Tax Pro In Luxembourg
White & Case LLP announced it has added a tax partner to its Luxembourg office from A&O Shearman who specializes in international and Luxembourg corporate tax law.
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May 23, 2024
Carbon Pricing Generated Over $100B In 2023, Report Says
Carbon pricing mechanisms worldwide generated a record $104 billion in revenue in 2023, according to a World Bank report, though it said the 75 instruments currently in force are too few and doing too little.
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May 23, 2024
Spain, Greece, Sweden Have Tax Policy Problems, EU Says
The European Union's executive arm called on Spain, Greece and Sweden on Thursday to change tax laws the bloc finds problematic, while also referring a Spanish tax issue to the European Court of Justice.
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May 23, 2024
EU Flags Nations For Shortcomings On Pillar 2, Exchange Law
The European Commission said Thursday that six European Union countries still have failed to implement the global minimum tax for large companies, and it noted that an additional three aren't properly implementing an information exchange law.
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May 23, 2024
Yellen Opposes Global Redistribution Of Billionaires' Wealth
U.S. Treasury Secretary Janet Yellen repeated Thursday that she opposes a global minimum tax on billionaires and added that she does not support basing a redistribution of the revenue from such a tax on damage from climate change and related financing needs.
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May 23, 2024
G7 Should Agree On Frozen Russian Assets, Yellen Says
U.S. Treasury Secretary Janet Yellen said Thursday that the Group of Seven countries should agree now on a concept of how the capital of frozen and immobilized Russian state assets should be used to support Ukraine's war against Russia.
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May 23, 2024
EU Could Add Sectors To Border Tax, Commissioner Says
The European Union should consider expanding its carbon border tax beyond the initial sectors covered, an EU commissioner has said.
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May 23, 2024
Akerman Brings On Kilpatrick Tax Ace In LA
Akerman LLP is boosting its tax team, bringing in a Kilpatrick Townsend & Stockton LLP corporate tax and energy tax credit expert as a partner in its Los Angeles office.
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May 22, 2024
Justices' CFPB Alliance May Save SEC Courts, Not Chevron
A four-justice concurrence to the U.S. Supreme Court's decision upholding the Consumer Financial Protection Bureau's unique funding scheme last week carries implications for other cases pending before the court that challenge the so-called administrative state, or the permanent cadre of regulatory agencies and career government enforcers who hold sway over vast swaths of American economic life.
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May 22, 2024
German Legislature Moves To Update Certain Tax Treaties
The lower house of Germany's legislature has approved a bill to update multiple bilateral tax treaties as part of the country's implementation of the Organization for Economic Cooperation and Development's project against base erosion and profit shifting.
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May 22, 2024
Doctor Must Stay In Jail In Tax Penalty Fight, Gov't Says
A doctor incarcerated for civil contempt for not paying $1.1 million in penalties for failing to report his foreign accounts should remain in jail until he has done more to comply, the U.S. government told a Michigan federal court Wednesday.
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May 22, 2024
Belgium Provides Pillar 2 Reporting Rules
Belgium's finance ministry has issued guidance on what large multinational entities and domestic groups will need to do to comply with the country's coming registration requirement as part of its implementation of the Organization for Economic Cooperation and Development's global corporate minimum tax.
Expert Analysis
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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.
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The Nuts And Bolts Of IRS Domestic Content Tax Credit
Recent IRS guidance provides specifics on how renewable energy projects can qualify for bonus tax credits by meeting U.S. domestic content rules, but also creates a qualification framework that will be complicated for project developers to navigate, say Scott Cockerham and Wolfram Pohl at Orrick.
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Taxing The Digital Economy: The Good, The Bad And The Ugly
U.S. tech companies should watch for important developments in international taxation, including the resolution of Apple's decade-old state aid case, growing frustration with the Organization for Economic Cooperation and Development's global tax plan and adoption of the digital services tax instead, says Joyce Beebe at Rice University's Baker Institute for Public Policy.
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Big Tax Changes For Multinational Cos. In Budget Proposal
The Biden administration’s fiscal year 2024 budget proposes changes that would materially alter decades-old Internal Revenue Code provisions, requiring a shift in multinational corporations' tax planning strategies comparable to that required after enactment of the Tax Cuts and Jobs Act, say Xenia Garofalo and Kyle Colonna at Eversheds Sutherland.
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Senate Credit Suisse Report Puts Attention On Banks, Trusts
The Senate Finance Committee's recent finding that Credit Suisse violated a plea agreement struck over its role in enabling offshore tax evasion has important ramifications for banks and trusts, including how they onboard, document and report on transactions relevant to U.S. reporting requirements, say Will Barry and Ian Herbert at Miller & Chevalier.
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Seeking IRS Accountability For Faulty Microcaptive Notice
Like the taxpayers in Standard Insurances v. U.S. seeking to expand earlier wins in microcaptive insurance cases that limit IRS use of improperly obtained information, others should consider ways to hold the agency accountable and provide incentive for it to follow the law going forward, says Joshua Smeltzer at Gray Reed.