International
-
May 03, 2024
HMRC Director Rejoins KPMG To Boost Tax Dispute Offering
A former deputy director at HM Revenue & Customs has returned to KPMG as director of KPMG Law's tax disputes teams, the firm has announced.
-
May 03, 2024
Africa Seeks Early UN Reform On Transfer Pricing, Exchanges
Legally binding protocols that reform transfer pricing and exchange of information to the benefit of all countries where multinational corporations operate should be developed simultaneously with the U.N. framework convention on global tax, the U.N.'s African bloc, India and others said Friday.
-
May 03, 2024
Estonia Implements 2 EU Tax Laws After Delays
Estonia officially enacted two European Union-wide tax measures that it was late putting into national law, both relating to the OECD's standards for global minimum taxation of large companies.
-
May 03, 2024
Aussie Treasury Seeks Input On Powers After PwC Scandal
With investigations into PwC Australia's leak of classified tax plan documents ongoing, the Australian government is asking the public whether it thinks its regulatory powers over tax and accounting firms are sufficient, its Treasury announced Friday.
-
May 03, 2024
New Fiscal Rules Force EU Countries To Limit Deficits
New European Union fiscal rules that recently kicked in will force EU countries to restrict public budget deficits by better balancing tax revenues with government spending, the European Commission said Thursday.
-
May 03, 2024
US Trade Position Seen Contradicting Stance In Pillar 1 Talks
The U.S. trade representative's withdrawal of support for digital trade proposals has caused tax policy observers to worry that the U.S. position on trade is undermining that of U.S. Treasury Department officials negotiating a taxing rights overhaul at the OECD known as Pillar One.
-
May 03, 2024
Finland's Stance On Swiss Treaty Recalls Ended Portugal Deal
Finland's plan to renegotiate its tax treaty with Switzerland in response to concerns about pension tax avoidance has some observers worried that the country will cancel that accord as it did a treaty with Portugal in recent years.
-
May 03, 2024
Taxation With Representation: Skadden, Wachtell, Davis Polk
In this week's Taxation With Representation, L'Occitane International said its executive director and chair is leading an offer to buy the company's shares he doesn't already own, UMB Financial agreed to purchase Heartland Financial USA, Medline said it agreed to acquire Ecolab's global surgical solutions business and The Mosaic Co. said it agreed to sell its stake in a phosphate production joint venture.
-
May 03, 2024
IRS Can Assess Foreign Info Disclosure Penalty, DC Circ. Says
The D.C. Circuit on Friday overturned a major U.S. Tax Court ruling that had struck down the Internal Revenue Service's authority to assess and administratively collect penalties from taxpayers for failing to file an information return on their interests in a foreign corporation.
-
May 03, 2024
Final EV Tax Credit Regs Add New Battery Tracing Test
The U.S. Treasury Department unveiled final regulations Friday for the up to $7,500 electric vehicle tax credit that include a more detailed process for automakers to trace the battery supply chain to qualify for the credit's domestic content requirements.
-
May 03, 2024
German's Austrian Ski Holiday Ends With Arrest In VAT Probe
A German citizen on a skiing holiday in Austria was arrested over a large-scale value-added tax fraud scheme, the Finance Ministry in Vienna said in a statement on Friday.
-
May 02, 2024
Claimed Panama Papers Leaker Fights To Hide ID In €5M Suit
A person claiming to be the Panama Papers leaker told a federal court they would fear for their life if the court made them disclose their identity in a €5 million ($6.3 million) suit against Germany, protesting a magistrate judge's suggestion that the suit be tossed because the person wouldn't identify themselves.
-
May 02, 2024
IRS To Boost Audit Rates By 50% On Wealthy, Werfel Says
The Internal Revenue Service plans to nearly triple audit rates on corporations with assets over $250 million and increase audit rates by more than 50% on wealthy taxpayers with more than $10 million in total positive income by 2026, Commissioner Daniel Werfel said Thursday.
-
May 02, 2024
Latest Stock Buyback Tax Rules May Still Have Wide Reach
The U.S. Treasury Department recently floated regulations that narrow an earlier proposal aimed at preventing foreign-parented corporations from circumventing a new excise tax on stock buybacks, but the regulations still characterize avoidance in ways that could include routine intercompany transactions.
-
May 02, 2024
HMRC Asked To Investigate Firm On Dodging Sanctions
HM Revenue & Customs should investigate a German-owned garage door manufacturer for violating sanctions by importing products from Belarus into the U.K., but instead authorities brushed off the case and now the company might receive a license, a U.K. lawmaker said.
-
May 02, 2024
Canada Budget Seeks To Establish Corp. Min. Tax Standards
Budget proposals submitted to Canada's Parliament by the finance minister would implement the Organization for Economic Cooperation and Development's global corporate minimum tax standards as part of the country's overarching budget plans.
-
May 02, 2024
OECD-Asia Group Helping Reform Agenda, OECD Head Says
A group that brings together countries from the mostly Western Organization for Economic Cooperation and Development and Southeast Asia to discuss issues, including tax, is helping countries make changes, the head of the OECD said Thursday.
-
May 02, 2024
Airlines Slam Increase In German Air Passenger Tax
The increase in Germany's air passenger tax on May 1 will weaken the country's economy and damage the aviation industry's ability to cut down on its carbon use, an airline group said on Thursday.
-
May 01, 2024
No Relief For Fla. Adviser Convicted In $80M Trading Scam
The Eleventh Circuit on Wednesday affirmed the conviction of a Florida investment adviser who bilked more than $80 million from the hundreds of people he persuaded to invest in a fraudulent company, after concluding he was not in custody when he made statements to the police.
-
May 01, 2024
Middle East, North African Gov'ts Back UN For Corp. Tax Talks
Governments should make a high-level commitment to address corporate tax reform within the United Nations' framework convention on international tax cooperation, an intergovernmental group of Middle Eastern and North African countries said Wednesday.
-
May 01, 2024
Think Tank Says 'Distortive' DSTs Not The Right Way Forward
As jurisdictions around the world continue to struggle with how to adequately tax the increasingly digital economy, they should look to expand their consumption taxes, not enact digital services taxes, the Tax Foundation said.
-
May 01, 2024
Liberty Global Defends $109M Tax Refund Bid In 10th Circ.
Telecommunications giant Liberty Global urged the Tenth Circuit to revive the company's $109 million tax refund bid, arguing a lower court rejected the claim by wrongly disregarding intercompany transactions that are permitted under legislation involving the repatriation of foreign profits.
-
May 01, 2024
UN Must Improve Corp. Tax Rules, Platforms, Some Gov'ts Say
Governments must commit to improving existing corporate tax rules and platforms created at the OECD within the terms of reference for a United Nations framework convention on global tax cooperation, two tax officials who participated in drafting those rules said Wednesday.
-
May 01, 2024
HMRC Simplifies Late Filing Penalties For Digital Filers
U.K. taxpayers voluntarily filing their personal income tax returns using a program intended to modernize the country's tax system will receive more leniency and access to a simpler penalty structure in cases of late filing, HM Revenue & Customs said.
-
May 01, 2024
Hong Kong Proposes Amended Automatic Info Exchange List
Hong Kong is considering adjusting the list of countries it automatically exchanges financial information with by subtracting nine jurisdictions and adding 11, which the country's tax authority said is in line with recommendations from the Organization for Economic Cooperation and Development.
Expert Analysis
-
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.
-
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.
-
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.
-
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.
-
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.
-
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.
-
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.
-
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.
-
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.
-
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.
-
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.
-
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.
-
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.