International
-
July 09, 2024
EU, India Wary Of Overlap From UN's Global Tax Work
Indian and European Union officials agreed during a meeting that the negotiations around a framework convention on international tax cooperation at the United Nations shouldn't overlap efforts of the ongoing OECD-led global tax overhaul, an EU executive department said.
-
July 09, 2024
UK's Non-Dom Taxpayer Count Increased 7%
A growing number of taxpayers in the United Kingdom claimed last year that their permanent home is outside the country, qualifying them for a non-domiciled tax exemption in the crosshairs of lawmakers, HM Revenue & Customs said Tuesday.
-
July 09, 2024
5 Firms Steer $513M Ryan-Altus Cross-Border Tax Deal
Dallas-based tax services and software provider Ryan said Tuesday it has inked a deal to acquire the property tax business of Altus Group Ltd. for CA$700 million ($513.4 million), enlisting three firms to assist on a deal that will expand its footprint in Canada, the U.S. and the U.K.
-
July 09, 2024
Maltese Case Tests EU Cooperation To Fight VAT Fraud
The case of a Maltese man arrested on suspicion of a key role in Sweden's largest value-added tax fraud illustrates how European countries are trying to boost their imperfect cooperation to combat such fraud, which causes billion-euro losses.
-
July 09, 2024
Mishcon De Reya Adds Blick Rothenberg Partner
Mishcon de Reya has added a former director from Blick Rothenberg to its corporate tax team in London as a partner, the firm announced in a statement.
-
July 09, 2024
Companies Deliberate Pillar 2 Prep After OECD Signals Relief
Multinational corporations facing the Pillar Two global minimum tax in various jurisdictions are weighing comments from OECD officials that hint at more relief as they decide whether to prepare to comply with the rules now or gamble on the prospects of permanent safe harbors.
-
July 09, 2024
Left Group Likely To Chair EU Parliament's Tax Body
A member of the Left group in the European Parliament is expected to chair the body's tax subcommittee, a document seen by Law360 on Tuesday showed.
-
July 09, 2024
EU Proposes Diplomatic VAT Exemptions Go Digital
The European Commission proposed that certificates for diplomatic exemptions from value-added taxes should switch from paper versions to an electronic form, a document said.
-
July 09, 2024
Commission Asks For EU Pressure On French, Italian Deficits
The European Commission proposed that European Union finance ministers put pressure on France, Italy and five other EU countries to lower their budget deficits, leaving it up to the countries to decide the details of tax hikes and spending cuts, the commission announced Tuesday.
-
July 08, 2024
Hong Kong Enacts Patent Box Tax Regime
The Hong Kong government began implementing a tax incentive known as a patent box for income derived from intellectual property in the jurisdiction, the Inland Revenue Department announced.
-
July 08, 2024
Top International Tax Cases Of 2024: Midyear Report
With a U.S. Supreme Court decision affirming a key 2017 tax provision on repatriation, millions of dollars in FBAR penalties upheld and a French ruling confirming the U.S. government's access to foreign bank accounts, the IRS stacked up important court victories on international enforcement in the first half of 2024. Here, Law360 reviews those and other significant rulings from the past six months.
-
July 08, 2024
Italy Outlines Details On Local Min. Tax Under Global Deal
The Italian Finance Ministry published plans for implementing a global rule that allows countries to tax the local affiliates of multinational corporations if their effective tax rates dip below an internationally agreed-upon 15% minimum.
-
July 08, 2024
Reeves Sets Out Plans For Pensions Investing, Fiscal Review
HM Treasury will work to direct pensions investment to British businesses, create a national wealth fund and conduct a fiscal review into government finances, Rachel Reeves said in her first public speech as chancellor on Monday.
-
July 08, 2024
EU Court To Rule On Lithuania Denying Corp. Tax Break
A Lithuanian court asked the European Union's highest court to determine whether Lithuania applies EU law correctly when blocking tax exemptions for dividends transferred to a parent company from a subsidiary in another EU country, a document published Monday said.
-
July 08, 2024
Feds Seize $63M LA Estate Tied To Armenian Bribe Probe
The U.S. Department of Justice said Monday that it will seize a $63 million Los Angeles estate that it claims was bought with bribe payments for the family of a former Armenian government official.
-
July 08, 2024
German Leaders OK Legislative Package With Tax Cuts
Leaders in Germany's three-party government agreed to a legislative package that would result in tax cuts if enacted, an outline of the agreed-to measures said.
-
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.
-
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.
-
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.
-
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.
-
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.
-
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.
-
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.
-
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.
-
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.
Expert Analysis
-
Prepare For More Audits Of Tax Info And Withholding Filings
Financial institutions and other corporate taxpayers should focus compliance efforts on tax information reporting and withholding, given recent indications from the Biden administration that the IRS will increase enforcement, and the administration's need to fund its infrastructure plan and other costly initiatives, say attorneys at Mayer Brown.
-
Anti-Boycott Compliance Still Key In UAE Business Dealings
Notwithstanding recent amendments to U.S. anti-boycott laws that reflect the United Arab Emirates' withdrawal from the Arab boycott of Israel, companies doing business in the UAE and elsewhere still need to maintain effective anti-boycott compliance programs to avoid reporting violations or penalties, says Howard Weissman at Miller Canfield.
-
9th Circ. Adds Pressure To Reject Substance Over Form
The Ninth Circuit’s recent decision rejecting taxes on a family's Roth IRA payments that were made through a foreign sales corporation represents a refreshing trend among federal appeals courts to reject substance-over-form principles and instead look to congressional intent, say Lawrence Hill and Caitlin Tharp at Steptoe & Johnson.
-
Will The OECD Plan Fix International Taxation?
Lilian Faulhaber at Georgetown Law breaks down the Organization for Economic Cooperation and Development’s plan for international tax reform, recently joined by 130 countries, and whether it will solve the problems it was designed to address, including the need for multinational companies to pay their fair share of taxes in the digitized world economy.
-
What Biden's Tax Proposals May Mean For Int'l Private Clients
Jennifer Wioncek and Paul D’Alessandro at Bilzin Sumberg discuss the U.S. Department of the Treasury's recently released explanation of the Biden administration's tax proposals and how the changes would affect income and wealth transfer planning for international private clients.
-
What Crypto Holders Can Learn From Early-2000s Tax Scandal
The Internal Revenue Service’s recent push to gather information about cryptocurrency accounts is similar to its Swiss bank account investigations of the early 2000s, which should prompt taxpayers to consider voluntarily disclosing transactions before they are individually targeted for enforcement, say Timothy Wagner and Thomas Barnard at Baker Donelson.
-
International Tax Reform's Implications For Transfer Pricing
As the Organization for Economic Cooperation and Development overhauls the global tax rules on base erosion and profit shifting, and the Biden administration rolls out new U.S. tax proposals, multinational enterprises need to prepare for the effects of these tax changes on their transfer pricing structures, say Mandy Li and Shuang Feng at MGO.
-
Justices' Preemptive Tax Challenge Ruling Shows Divisions
The U.S. Supreme Court's recent decision in CIC Services v. Internal Revenue Service reveals divisions among the justices about when potentially burdensome tax regulations can be challenged, making the holding less clear and less valuable, say George Isaacson and David Swetnam-Burland at Brann & Isaacson.
-
Takeaways From 2 New FBAR Rulings
In light of two recent California federal court decisions, capping penalties for nonwillful violations of foreign bank account reporting but broadening the willfulness standard, U.S. taxpayers must be vigilant about understanding their reporting obligations, and prepare for the Internal Revenue Service to target willful conduct, which yields much higher penalties, say Friedemann Thomma and Marianna Felshtiner at Venable.
-
El Salvador's Use Of Bitcoin Complicates US Commercial Law
El Salvador recently became the first country to recognize Bitcoin as currency, presenting significant implications for U.S. commercial law as the development will likely trigger the cryptocurrency to now fall within the definition of "money" under the Uniform Commercial Code, say Joe Carlasare and Eric Fogel at SmithAmundsen.
-
Justices' Nod To Preemptive Tax Challenges May Caution IRS
The U.S. Supreme Court's recent decision in CIC Services v. Internal Revenue Service, allowing pre-enforcement challenges of tax reporting rules despite the Anti-Injunction Act, is likely to make the U.S. Department of the Treasury more careful about its own compliance obligations under the Administrative Procedure Act, says Robert Carney at Caplin & Drysdale.
-
Let's End The Offshoring Of US Patents
Congress should work toward removing the loophole that allows companies to avoid U.S. taxes by moving their patents offshore, and ensure profits are taxed where the sales take place, says Sen. Patrick Leahy, D-Vt.
-
Long Road Ahead For Biden's Individual Tax Hike Proposal
Dustin Stamper at Grant Thornton provides insight into President Joe Biden's recently proposed individual tax increases to pay for his American Families Plan, and explains how competing interests among congressional Democrats and Republicans may shape the final provisions and prolong their implementation.