International
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June 06, 2024
Switzerland, Italy Agree To Permanent Rules For Remote Work
Switzerland and Italy have established permanent rules regarding the taxation of cross-border workers, replacing a temporary arrangement that was agreed to last year, the Swiss government said Thursday.
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June 05, 2024
Nigeria Holding US Binance Exec Hostage, Lawmakers Say
The White House's hostage negotiator should begin seeking the release of a top executive at cryptocurrency exchange Binance whom the Nigerian government is holding personally liable for tax evasion charges against the company, the House Foreign Affairs Committee's chairman has said.
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June 05, 2024
German Draft Bill Would Adjust Tax Laws To EU Rules
Changes could be coming to a number of German tax laws, including some spurred by European Union law and both national and international case law, Germany's Finance Ministry said Wednesday.
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June 05, 2024
Win May Embolden IRS Use Of Economic Substance Doctrine
The IRS' successful wielding of the economic substance doctrine to characterize multinational telecommunications corporation Liberty Global's sophisticated set of intercompany deals as an abusive tax shelter could encourage the agency to apply similar analysis to even the most basic tax transactions.
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June 05, 2024
Streamers To Be Hit With 5% Charge On Canadian Revenue
Streaming services such as Netflix and Disney+ soon will be required to contribute 5% of their Canadian revenues to the country's broadcasting system, which could generate CA$200 million ($146 million) a year, Canada's government said, drawing the ire of the National Foreign Trade Council.
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June 05, 2024
Gov't UK ISA Savings Proposal Gets Cold Shoulder
More financial firms on Wednesday warned that the U.K. government's plans to give consumers a new tax break for investing in U.K. companies was unworkable, adding it could conflict with the Financial Conduct Authority's consumer protection rules.
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June 05, 2024
EU Corp. Tax Proposal Delayed By Uncertainty On OECD Plan
European Union countries' negotiations on a proposal to streamline corporate taxation have been delayed because of a lack of clarity on implementation of the OECD's global minimum tax and the design of the accompanying reallocation of taxing rights, a top European Commission tax official said Wednesday.
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June 05, 2024
OECD Official Hopes Pillar 2 Ends Some 'Wasteful' Incentives
The introduction of the global minimum corporate tax known as Pillar Two should lead to the end of some "wasteful" incentives that narrow the tax base, an official from the Organization for Economic Cooperation and Development said Wednesday.
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June 05, 2024
Labour's Pension Tax Plans Backed By Fiscal Research Body
An influential economics think tank has backed plans by the Labour Party to reintroduce the lifetime allowance, arguing that there should be a cap on the tax-free accumulation of pensions wealth.
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June 04, 2024
Full DC Circ. Asked To Weigh Foreign Info Disclosure Penalties
A D.C. Circuit panel made questionable assumptions about congressional intent when it revived the IRS' authority to assess and administratively collect penalties related to undisclosed foreign corporations, a businessman said Tuesday in asking the full appellate court to hear his case.
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June 04, 2024
Australian Court Upholds Ex-Chinese Citizen's $7.7M Tax Bill
An Australian court upheld an AU$11.5 million ($7.7 million) tax bill from the Australian Taxation Office to a former Chinese citizen after determining he failed to provide enough evidence to support his alternative tax liability calculation.
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June 04, 2024
Calif. OTA Rejects Couple's Claim Of Bolivia Residency
A California couple owes additional state income tax on a retirement account distribution, the state Office of Tax Appeals said in an opinion released Tuesday, rejecting the pair's assertion that they were domiciled in Bolivia at the time.
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June 04, 2024
EU OKs Italian Renewable Energy Plan Funded By Levy
The European Commission said Tuesday that it approved Italy's plan to introduce a levy on the electricity bills of final consumers to fund construction of renewable energy plants, finding the benefits far outweigh any potential damage to competition and trade.
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June 04, 2024
Spain Sends Pillar 2 Bill To Legislature After EU Pressure
The Spanish government announced Tuesday it has sent a bill to its legislature that would transpose the European Union directive to implement the Organization for Economic Cooperation and Development's global minimum tax on large corporations following pressure from the bloc.
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June 04, 2024
New Dutch Gov't Seen Returning To Pro-Biz Positions
The incoming conservative Dutch government is expected to adopt tax policies that align with the Netherlands' long-standing reputation as a tax-friendly jurisdiction for businesses, in part by reversing a recently enacted measure that taxed companies' purchases of their own shares.
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June 04, 2024
Luxembourg Candidate Calls To End EU Tax Unanimity Rule
The leading Socialist candidate in the upcoming European parliamentary elections said the European Union should scrap the need for unanimity for all tax decisions, clashing with his home country of Luxembourg's longtime stand that's meant to protect its status as a financial center.
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June 04, 2024
Austrian Authorities Reveal Spike In Fake Companies
The number of fake companies in Austria is increasing, according to data from the Finance Ministry, which said that it hoped a new law would aid in combating the trend.
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June 03, 2024
Danish Tax Agency Says $2.1B Tax Fraud Suits Not Filed Late
Denmark's tax administrator urged a New York federal court to reject bids to toss its suits against U.S. pension plans and individuals it accuses of participating in a $2.1 billion fraud scheme, saying the suits were not filed too late.
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June 03, 2024
Treasury Aims To Salvage Corp. Transparency Act At 11th Circ.
The Corporate Transparency Act is a valid exercise of congressional authority to curb money laundering under the commerce clause and the necessary and proper clause in the Constitution, the U.S. Treasury Department told the Eleventh Circuit on Monday in a bid to restore the law's reporting requirements.
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June 03, 2024
Tax Convictions Withstand Poor Counsel Claim, 4th Circ. Says
A North Carolina man's claim of ineffective counsel is not sufficient reason to vacate his convictions for filing false tax returns and obstructing an official proceeding in a case involving $2.1 million in unreported income sent from Bermuda entities, the Fourth Circuit ruled.
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June 03, 2024
Texas Oil Co. Says IRS Hasn't Paid $36M Promised Refund
The Internal Revenue Service has promised to pay a Texas oil company more than $36 million in tax refunds and credits for the 2009 tax year but has failed to do so, the company told a federal court.
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June 03, 2024
African Gov'ts Made Big Gains From Data Swaps In 2023
African tax authorities made huge headway last year in using the international standard for exchange of information on request to find additional revenues of €2.2 billion ($2.4 billion), which is more than over the past 13 years combined, the OECD reported Monday.
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June 03, 2024
UK Liberal Democrats Call For Buyback Tax, Tripling DST
The U.K. Liberal Democrat party called for a 4% share buyback tax on the 100 largest corporations on the stock market as well as for tripling the country's 2% digital services tax, with the additional revenue generated to be earmarked to benefit schoolchildren.
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June 03, 2024
South Korea Extending Tax Breaks For Growing Businesses
Companies in South Korea that graduate from being considered small and medium enterprises to middle-market enterprises will see the grace period that allows them to continue to receive tax breaks granted to smaller entities extended, the country's finance ministry said Monday.
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June 03, 2024
7 Arrested In €18M Italian VAT Fraud Ring
Financial police in Italy arrested seven suspects Monday in connection with a value-added tax fraud scheme involving beverages that resulted in losses of €18 million ($19.6 million), the European Public Prosecutor's Office said.
Expert Analysis
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5 Ways Firms Can Avoid Female Atty Exodus During Pandemic
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.
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IRS Real Estate Push Should Wake Up Foreign Investors
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.
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CFTC Climate Change Report Highlights Costs Of Inaction
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.
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Dems' Int'l Tax Policy Comes With Unintended Consequences
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.
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How Cos. Can Respond To Growing Crypto Tax Enforcement
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.
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Trump's Tax Tactics May Be Criminal
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.
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Why Cum-Ex Tax Fraud Probes Are On The Rise
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.
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Managing New IRS Global High-Wealth Audits
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.
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Employers Should Act Now To Mitigate Remote Work Tax Risk
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.
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Pros And Cons Of State Transfer Pricing Program Participation
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.
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BigLaw Cannot Reap Diversity Rewards Without Inclusion
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.
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Ideas For Closing BigLaw's Diversity Gap
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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How Law Firms Can Hire And Retain More Black Attorneys
The pipeline of Black lawyers is limited, so BigLaw firms must invest in Black high school students, ensure Black attorneys receive origination credit and take other bold steps to increase Black representation in the industry, says Benjamin Wilson, chairman at Beveridge & Diamond.