International
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May 21, 2024
EU Adopts Decision To Send Russian Profits To Ukraine
European Union countries adopted a formal decision Tuesday to transfer the net income from frozen and immobilized Russian state assets to EU funds for rebuilding Ukraine and buying arms for the war-torn country, a news release said.
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May 21, 2024
I Am An Honest Man, British Trader Tells £1.4B Fraud Trial
Sanjay Shah, a former hedge fund owner who is accused of defrauding Denmark's tax authority out of £1.4 billion ($1.8 billion), told a London court on Tuesday that he is an "honest man" who traded using a legal "loophole."
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May 21, 2024
IMF Report Warns UK Against More Tax Cuts
The United Kingdom should refrain from additional tax cuts unless they are credibly shown to boost economic growth and are offset by measures to cut the deficit, the International Monetary Fund said Tuesday.
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May 20, 2024
Transparency Act Violates Constitution, Groups Tell 11th Circ.
The Corporate Transparency Act's reporting requirements violate the Fifth Amendment's protection against self-incrimination and other constitutional provisions, libertarian think tank Cato Institute and others said Monday in urging the Eleventh Circuit to uphold an Alabama district court's ruling against the law.
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May 20, 2024
India's Top Court Says Accounting Body Can Limit Tax Audits
India's regulatory association for accountants has the authority to limit the amount of tax audits performed by an individual accountant to 60, the Supreme Court of India ruled — even as it canceled ongoing disciplinary proceedings over the restriction because of inconsistent enforcement.
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May 20, 2024
IRS Guidance Plan Should Cover Corp. AMT, AICPA Says
The Internal Revenue Service should provide guidance on the definitions and applications of the 15% corporate alternative minimum tax, among other topics, the American Institute of Certified Public Accountants said in comments published by the agency Monday.
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May 20, 2024
Turkey Will Introduce 15% Global Minimum Tax, Minister Says
The Turkish government will introduce the 15% global minimum corporate tax and will not provide any incentives that would allow companies to pay a lower rate, the country's finance minister told its public broadcaster Monday.
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May 20, 2024
Isle Of Man Commits To Portion Of Global Minimum Tax
The Isle of Man plans to introduce legislation implementing the qualified domestic minimum top-up tax portion of the OECD's Pillar Two directive starting in 2025 but is less committed to adopting the income inclusion rule, the island's Treasury said Monday.
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May 20, 2024
HMRC Lays Out Registration Rules For Pillar 2
Companies covered by the U.K.'s implementation of the Organization for Economic Cooperation and Development's Pillar Two global minimum tax directive must register with HM Revenue & Customs within six months of the accounting period that makes them eligible, the agency said Monday.
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May 20, 2024
US, Argentina To Carry Out 1st FATCA Info Exchange
The Internal Revenue Service approved cybersecurity measures by Argentina in a step that clears the way for the first automatic information exchange under the Foreign Account Tax Compliance Act between the two countries in September, Argentina's revenue service said Monday.
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May 17, 2024
Med Device Co. Allowed $160M In Deductions, Tax Court Told
A tax code provision in place before the 2017 federal tax overhaul changed it allows a medical device manufacturer to claim more than $160 million in deductions for dividends despite the government's attempt to apply the law retroactively, company counsel told the U.S. Tax Court on Friday.
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May 17, 2024
Michigan Doctor Seeks Release From Contempt In FBAR Fight
A Michigan doctor incarcerated for civil contempt in a case in which he was ordered to repay more than $1 million in penalties for failure to report foreign accounts should be freed because he can no longer satisfy the terms of his release, he told a Michigan federal court.
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May 17, 2024
Koch-Tied Group Says Transparency Law Offends Federalism
The Corporate Transparency Act is unconstitutional because it does not regulate interstate commerce yet mandates that state-registered entities disclose personal information, a conservative group affiliated with the billionaire Koch brothers told the Eleventh Circuit on Friday.
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May 17, 2024
Credit Suisse Can't Reverse $21.3M Biz Loss Denial
Credit Suisse cannot carry forward $21.3 million in business losses from 2015-2017 to its 2018 Michigan tax return, a state appeals court said, letting stand a ruling that the bank miscalculated its business income from those years on its returns.
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May 17, 2024
New Domestic Content Guidance May Boost Energy Credits
The U.S. Treasury Department's new guidance on bonus tax credits for clean energy projects that source domestic-made materials and components aims to simplify the process for determining eligibility and spur more development to get those extra incentives.
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May 17, 2024
Italian Financial Police Uncover €1B Tax Credit Scam
The Italian Financial Police placed more than 300 people under investigation after uncovering a scheme to collect more than €1 billion ($1.09 billion) in tax credits designed to promote construction and energy matters, authorities said.
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May 17, 2024
Transfer Pricing Deal Needed For Pillar 1, OECD Official Says
It's crucial for countries to agree on transfer pricing policies under an international profit reallocation agreement known as Pillar One as they work toward their end-of-June deadline to sign a related multilateral treaty, an OECD official said Friday.
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May 17, 2024
New Dutch Gov't Outlines Range Of Tax Measures
The incoming Dutch government has outlined numerous tax measures affecting companies and individuals in its preliminary coalition agreement, a government document showed.
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May 17, 2024
UK, Peru Agree To Double-Tax Treaty
The U.K. and Peru reached a deal on a treaty to prevent double taxation after several years of discussion, the countries said Friday.
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May 17, 2024
Taxation With Representation: Wachtell Lipton, Freshfields
In this week's Taxation with Representation, Nippon Life acquires Corebridge Financial, Crescent Energy buys SilverBow Resources and Uber purchases Foodpanda.
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May 16, 2024
Pillar 1 Faces Hard June Deadline, Ex-Treasury Official Says
An international agreement to reallocate certain corporate profits, known as Pillar One, will likely stall if countries miss their deadline to sign a multilateral treaty by the end of June, a former U.S. Treasury official said Thursday.
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May 16, 2024
Australian Lawmakers OK Tougher Corporate Promoter Rules
Australian lawmakers agreed Thursday to raise maximum penalties on corporations that promote tax avoidance schemes and to introduce a cap on deductions under its petroleum resource rent tax despite concerns from some members, according to documents published by Parliament.
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May 16, 2024
P&G Exec Says FDII Uncertainty May Sway Cos.' IP Decisions
The 2017 tax overhaul's measure for foreign-derived intangible income, a regime that gives tax breaks for domestically held intellectual property, faces uncertainty that could be one factor in keeping some companies from repatriating IP, a tax executive for Procter & Gamble said Thursday.
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May 16, 2024
Eaton Must Give Up Personnel Docs In Transfer Pricing Probe
Eaton must comply with an Internal Revenue Service summons for the personnel records of its foreign employees in the government's transfer pricing investigation of the multinational power management company, an Ohio federal judge ruled Thursday.
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May 16, 2024
African Tax Admins Promote Use Of Voluntary Disclosures
Voluntary disclosure programs have been very effective when countries launch them in anticipation of complying with an international standard on automatic exchanges of financial account information, the African Tax Administration Forum said Thursday in guidance on the programs.
Expert Analysis
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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.
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BigLaw Needs More Underrepresented Attorneys As Leaders
Hiring more women, people of color and members of the LGBTQ community to BigLaw positions of power is the first key to making other underrepresented attorneys believe they have an opportunity for a path to leadership, says Ernest Greer, co-president at Greenberg Traurig.
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Advancing Racial Justice In The Legal Industry And Beyond
In addition to building and nurturing a diverse talent pipeline, law firms should collaborate with general counsel, academics and others to focus on injustices within the broader legal system, says Jonathan Harmon, chairman at McGuireWoods.
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Diversity Work Doesn't Have To Be Reserved For Partners
Serving on my firm's diversity committee as an associate has allowed me to improve access, support and opportunity for minority attorneys at the firm, while building leadership skills and fostering meaningful relationships with firm management and industry professionals, says Camille Bent at BakerHostetler.
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Foreign Income Regs Provide Some Clarity But Issues Remain
The U.S. Department of the Treasury recently released final regulations on global intangible low-taxed income and foreign-derived intangible income that largely addressed the numerous technical issues plaguing these sections but left the high GILTI rate and other substantive problems unresolved, says Robert Kiggins at Culhane Meadows.
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New Unified High-Tax Election Brings Planning Challenges
The U.S. Department of the Treasury's recently released high-tax election regulations for global intangible low-taxed income create unwanted planning challenges by conforming to the stricter Internal Revenue Code Subpart F high-tax exclusion, rather than aligning with the GILTI election rules as many hoped, say attorneys at Mayer Brown.
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EU's Tax-Centered State Aid Campaign May Have Peaked
The European Commission's recent tax-related state aid investigations of the likes of Apple, McDonald's and Nike may have reached their limit as changes in international tax rules, the rapid growth of digital companies and COVID-19 reprioritize the commission's anti-competitive initiatives to broader issues focused on tech giants, says Joyce Beebe at Rice University.
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Get Ready For IRS Repatriation Enforcement
Beginning this fall, taxpayers should expect to see IRS enforcement efforts with respect to their repatriation tax liabilities, including audits that will likely focus on taxpayers' earnings and profits calculations, classification of assets as cash versus noncash, and how taxpayers determined foreign tax credits, say David Fischer and Teresa Abney at Crowell & Moring.
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Canadian Tax Ruling Boosts Cross-Border Deal Confidence
The Queen v. Cameco Corp., a recent Canadian appellate decision and the first case to test Canada's transfer pricing recharacterization rules, has significant implications for cross-border intragroup transactions and the intersection of Canadian tax law with the Organization for Economic Cooperation and Development’s guidance, says Matt Billings at Duff & Phelps.