International
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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.
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July 19, 2024
Taxation With Representation: A&O Shearman, Gibson Dunn
In this week's Taxation With Representation, Cleveland-Cliffs Inc. buys Stelco Holdings Inc., KBR acquires LinQuest Corp., Blue Owl Capital Inc. purchases Atalaya Capital Management LP, and Amphenol Corp. buys two mobile networks units from CommScope.
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July 19, 2024
2 Arrested In €8.8M VAT Fraud Involving Cleaning Products
Italian financial police arrested two people Friday who are suspected of leading an €8.8 million ($9.6 million) value-added tax fraud scheme involving cleaning products and beverages, the European Public Prosecutor's Office said.
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July 19, 2024
Gov't Floats Draft Proposal For OBR 'Fiscal Lock' Powers
HM Treasury proposals for a new "fiscal lock" in a draft Budget Responsibility Bill will allow the Office for Budget Responsibility to scrutinize any tax-and-spend decisions with a cost factor of 1% of gross domestic product or more.
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July 19, 2024
International Tax Policy To Watch In The 2nd Half Of 2024
An abundance of loose threads pervades the international tax landscape as the first year of the global minimum tax unfolds, with the battle over digital services taxes still smoldering and diplomats talking tougher taxes on the wealthy. Here, Law360 looks at international tax policy to watch in the second half of 2024.
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July 19, 2024
EU Parliament's Tax Body To Elect Chair On July 23
The European Parliament's subcommittee on taxation plans to elect its chair and vice chairs when it meets on July 23, the Parliament confirmed in a statement on Friday.
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July 18, 2024
Treasury Starting To Address Amount B, Official Says
The U.S. Department of the Treasury is just starting to decide how to handle a transfer pricing regime under a prong of the OECD-led global tax overhaul, a Treasury official said Thursday.
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July 18, 2024
Tax Pros Say Gov'ts Stretching 'Realistic Alternative' Analysis
Tax authorities including the Internal Revenue Service are overstepping in their use of "realistic alternative" arguments, substituting their own judgment for that of businesses, transfer pricing specialists said Thursday.
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July 18, 2024
Ex-Venable Trusts And Estates Partner Joins Stradling In LA
Stradling Yocca Carlson & Rauth PC announced that it launched a trusts and estates practice with the hiring of an experienced Los Angeles-based partner from Venable LLP.
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July 18, 2024
Most Top US Cos. To Report Tax Under Aussie Bill, Study Says
Australia's Senate is expected to consider adoption next month of the world's most extensive public country-by-country reporting rules, which would require 51% of large U.S. multinational corporations to disclose tax arrangements retroactively from July 1, according to a study published Thursday.
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July 18, 2024
UK Brothers Sentenced For £3.2M Offshore Tax Evasion
A pair of brothers each received suspended two-year prison sentences for charges related to a tax evasion scheme where they hid more than £3.2 million ($4.1 million) using companies in Gibraltar and the British Virgin Islands, HM Revenue & Customs said Thursday.
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July 18, 2024
Rising Star: Latham's Eric Kamerman
Eric Kamerman of Latham & Watkins LLP in recent years handled the tax aspects of several multibillion-dollar acquisitions of powerhouses in British soccer and American fashion, earning him recognition as one of the tax attorneys under age 40 honored by Law360 as Rising Stars.
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July 18, 2024
Top International Tax Cases To Watch In The 2nd Half Of 2024
Tax attorneys will be tracking several high-stakes cases in the second half of 2024 that could define the bounds of the IRS' ability to craft regulations or lodge direct challenges aimed at what it sees as the tax avoidance maneuvers of multinational corporations. Here, Law360 looks at key international tax cases to follow during the rest of the year.
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July 18, 2024
GE Can't Claim Credit For £189M In Double Tax, Court Says
A U.K.-registered subsidiary of General Electric does not qualify for at least £189 million ($245 million) in double tax relief under a U.S.-U.K. treaty because it lacks a U.S. presence akin to a domicile, a London appellate court ruled.
Expert Analysis
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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.
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ECJ Fiat Ruling Sets Clear Boundaries For EU State Aid Law
The European Court of Justice's recent landmark decision in Fiat v. Commission limiting the commission’s attempts to circumvent the lack of EU powers in the area of tax law has important implications in EU state aid law and beyond, say Andreas Reindl and Pietro Stella at Van Bael.
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Unpacking The Interim Guidance On New Stock Buyback Tax
The U.S. Department of the Treasury and Internal Revenue Service's recent notice on applying the newly effective excise tax on stock repurchases provides much-needed clarity on the tax's scope, which is much broader than anticipated given its underlying policy rationale, say attorneys at Eversheds Sutherland.
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IRS Will Use New Resources To Increase Scrutiny In 2023
The new year promises to be a busy one for the Internal Revenue Service, which is poised to apply the boost in funding provided by the Inflation Reduction Act to bolster and expand its enforcement capability, and there are four areas to watch, say attorneys at Skadden.
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How Japan's Implementation May Change The Pillar 2 Debate
Japan’s outline of proposed legislation adopting a primary component of the Organization for Economic Cooperation and Development's 15% global minimum tax will increase pressure on countries — including the U.S. — that have not committed to adopting Pillar Two, says Takato Masuda of Nishimura & Asahi.
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Foreign Tax Credit Proposal Is Some Help, But More Is Needed
New foreign tax credit regulations proposed by the U.S. Treasury Department provided some measure of relief on cost recovery and royalty withholding, two of the most troublesome aspects of the 2021 final foreign tax credit regulations, but the final regulations are still harmful to many taxpayers, making litigation inevitable, say attorneys at Fenwick.
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IRS' Tax Gap Statistics Don't Paint A Full Compliance Picture
The Internal Revenue Service's recent report indicating a widening tax gap sheds important light on tax compliance, underlines key pressure points and provides insights into how tax administration could be improved; but tax gap estimates also have their limits, says Joyce Beebe at Rice University.
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How High Court Could Change FBAR Penalty Landscape
On Wednesday, the U.S. Supreme Court will hear Bittner v. U.S., a case that will affect many people penalized for failing to file a Report of Foreign Bank and Financial Accounts, and there are important procedural implications should the government's position be reversed, say Reuben Muller and Andreas Apostolides at Cole Schotz.
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IRS Memo May Change IP Royalty Tax Prepayment Planning
A recent Internal Revenue Service advice memorandum finding a taxpayer was not permitted to prepay tax on contingent royalties after contributing intellectual property offshore is a noteworthy departure from earlier guidance that highlights potential differences between actual and deemed licenses, says William Skinner at Fenwick.