International
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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."
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July 02, 2024
Saudi Arabia Extends COVID-19 Tax Penalty Exemptions
Saudi Arabia's tax authority extended pandemic-inspired broad exemptions from certain tax-related penalties and fines, such as those for late filings and payments, through the end of the year.
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July 02, 2024
Financial Crime Body Updating Risk Assessment Guidance
An intergovernmental task force announced it is seeking public input on ways it could improve guidance for its process for countries to determine their risks of bad actors using their financial systems for money laundering.
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July 02, 2024
Belgium Delays Pillar 2 Reporting For Some Groups
Belgium's finance ministry on Tuesday pushed back the deadline to Sept. 16 for some entities in scope of its implementation of the OECD's Pillar Two global 15% minimum tax to comply with the country's mandatory notification system.
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July 02, 2024
Netherlands Still A Conduit For Tax Evasion, Report Says
The Netherlands remains a conduit for multinational companies channeling their profits to countries with low tax rates despite some tax measures introduced by the Dutch government, a study sent to Law360 on Tuesday said.
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July 02, 2024
Hungary Envoy Praises Its Low Taxes After PM Slams Min. Tax
Hungary's representative to the European Union said Tuesday that Budapest's low tax rate was instrumental in bolstering the business environment in the country as he responded to a question about his prime minister slamming the global minimum tax.
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July 02, 2024
New Dutch Government Sworn In, Plans Tax Reform
The new four-party conservative Dutch government took office Tuesday on a program that includes tax reform for companies and individuals.
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July 01, 2024
Womble Bond Adds Int'l Tax Partner In Houston Office
Womble Bond Dickinson has added a partner to its corporate and securities group in Houston who will focus on tax law and cross-border transactions, the firm announced.
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July 01, 2024
US-Taiwan Biz Groups Push For True Double-Tax Treaty
Top-ranking Senate members should push for the start of consultations on a bilateral tax treaty to avoid double taxation between the U.S. and Taiwan as opposed to measures already included in a stalled larger bill, two groups focused on business relations between the countries said.
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July 01, 2024
Judge Acquits Firm Co-Founder, 27 Others Over Panama Papers
When authorities raided the now defunct Panamanian law firm Mossack Fonseca as part of their investigation into the international money laundering case known as the Panama Papers, they didn't follow the chain of custody for evidence they seized, so 28 people accused in the conspiracy must be acquitted, a Panamanian judge has ruled.
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July 01, 2024
Nelson Mullins Adds 9-Attorney Tax Team In Houston
Nelson Mullins Riley & Scarborough LLP announced Monday that five partners and four other tax attorneys have joined its new Houston office from Chamberlain Hrdlicka White Williams & Aughtry, including a former Texas Supreme Court justice.
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July 01, 2024
Firm Can't Cast Off $1.5M Tax Levy In Alter Ego Case
A Baltimore law firm can't stop a $1.5 million tax levy that allowed the IRS to freeze its bank account, a Maryland federal judge ruled, saying the firm failed to prove at this point in its suit that one of its clients lacked an interest in the money.
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July 01, 2024
3 More Indicted In €54M VAT Fraud Involving Car Sales
Authorities indicted three more suspects for their roles in a value-added tax fraud scheme involving the international trade of more than 10,000 cars that caused over €53.7 million ($57.6 million) in VAT losses, the European Public Prosecutor's Office said Monday.
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July 01, 2024
OECD Tax Chief Affirms Pillar 1 Progress As Deadline Passes
Negotiations continue on Pillar One at the Organization for Economic Cooperation and Development even after a deadline passed to release the final text of a multilateral convention to establish the project's taxing right known as Amount A, the director of the OECD's tax policy office said Monday.
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July 01, 2024
New EU Chair Hungary Aims To Discuss VAT At Fall Meeting
Hungary, the new chair of European Union member states, plans to discuss at a fall meeting a proposed change to value-added tax law that would require platform companies such as Airbnb and Uber to collect VAT for service providers.
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July 01, 2024
EU Bans Giving Tax Consulting Services To Belarus
The European Union has introduced a ban on providing tax consulting and many other professional services to Belarus in a wide-ranging package of measures largely aimed at preventing the circumvention of the bloc's sanctions against Russia, a statement said.
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June 28, 2024
Chevron's End Is Just The Start For Energized Agency Foes
By knocking down a powerful precedent that has towered over administrative law for 40 years, the U.S. Supreme Court's right wing Friday gave a crowning achievement to anti-agency attorneys. But for those attorneys, the achievement is merely a means to an end, and experts expect a litigation blitzkrieg to materialize quickly in the aftermath.
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June 28, 2024
In Chevron Case, Justices Trade One Unknown For Another
The U.S. Supreme Court's decision to overrule a decades-old judicial deference doctrine may cause the "eternal fog of uncertainty" surrounding federal agency actions to dissipate and level the playing field in challenges of government policies, but lawyers warn it raises new questions over what rules courts must follow and how judges will implement them.
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June 28, 2024
IRS Finalizes Broker Rules For Digital Asset Sales
Brokers of digital assets such as cryptocurrency and non-fungible tokens will face tax reporting requirements for the first time similar to those for brokers of securities and other financial instruments under final regulations issued Friday by the Internal Revenue Service.
Expert Analysis
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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.
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Biden Admin. Proposals Both Encourage And Thwart EV Adoption
While the Biden administration has been aggressively focused on promoting electric vehicles from the start, its recently issued guidance on EV tax credits and its restrictive new auto emissions proposal create a sense of implementation whiplash that may frustrate manufacturers and consumers, says Levi McAllister at Morgan Lewis.
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The Key Issues Keeping Transfer Pricing A Top Tax Concern
Several challenges preventing a global economic reemergence from the pandemic era are making practitioners reevaluate commonly used transfer pricing models, and embrace new technologies and ways of doing business, say Farnaz Amini and Sophia Castro Jurado at Marcum.
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Curtailing Offshore Tax-Advantaged Investment In China
The U.S. government's plans to establish a new outbound investment regime hold the potential to arrest Chinese companies' increasing use of offshore, tax-advantaged locations to raise capital, says David Plotinsky at Morgan Lewis.
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Cos. May Want To Wait Out US-EU Green Incentives Fight
As the European Union considers measures to compete with the Inflation Reduction Act's incentives for U.S. production of clean tech, and EU and U.S. officials discuss a possible compromise, companies in the green sector should consider taking a wait-and-see approach to investment decisions, says Todd Thacker at Goldberg Segalla.
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India's Budget Proposals May Ease Entry For Certain Sectors
India’s recently released budget includes proposals to facilitate doing business in Gujarat International Finance Tec-City and moderate thousands of compliance requirements, opening up new opportunities for foreign businesses in the digital infrastructure, manufacturing and renewable energy sectors, say Mukesh Butani and Seema Kejriwal at BMR Legal.
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High Court Ax Of Atty-Client Privilege Case Deepens Split
The U.S. Supreme Court's recent dismissal of In re: Grand Jury as improvidently granted maintains a three-way circuit split on the application of attorney-client privilege to multipurpose communications, although the justices have at least shown a desire to address it, say Trey Bourn and Thomas DiStanislao at Butler Snow.
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US-India Advance Pricing Resolutions Should Reassure Cos.
The United States' and India's tax authorities' recent resolution of a significant number of pending advance pricing agreements should reduce taxpayer uncertainty, reassure companies of the nations' good working relationship and improve India's investment environment, say Miller Williams and Caroline Setliffe at Eversheds Sutherland.
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Stock Buyback Excise Tax Guidance A Mixed Bag For SPACs
Recent IRS guidance on the new stock repurchase excise tax includes a welcome exception for publicly traded special-purpose acquisition companies but does not exclude redemptions in connection with a de-SPAC transaction, and further guidance is needed to clarify ambiguities around the exception's application, say Olga Bogush and Evgeny Magidenko at ArentFox Schiff.
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The IRS' APA Rulemaking Journey: There And Back Again
Attorneys at Dentons examine recent challenges in which taxpayers successfully argued Internal Revenue Service rulemaking was invalid under the Administrative Procedure Act, how tax exceptionalism and U.S. Supreme Court regulatory deference prompted such challenges, and similar challenges the agency will likely face following this line of cases.