International
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July 03, 2024
Australia Clarifies Hybrid Mismatch Tax Rules
The Australian Taxation Office issued guidance Wednesday further clarifying two aspects of its hybrid mismatch rules designed to prevent multinational corporations from exploiting differences in tax treatment between jurisdictions.
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July 03, 2024
Former OECD Deputy Tax Director Joining KPMG Australia
A former deputy tax director for the Organization for Economic Cooperation and Development is joining KPMG Australia as a partner starting next month, the firm said Wednesday.
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July 03, 2024
Fox Rothschild Hires Pryor Cashman Nonprofit Leads
Fox Rothschild LLP announced Wednesday the hiring of two Pryor Cashman LLP partners for its corporate department in New York.
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July 03, 2024
Slovenia Tax Incentives Impair Decarbonization, OECD Says
Slovenia's reduced tax rates for certain harmful fossil fuels have hurt the country's efforts to limit its carbon emissions, the Organization for Economic Cooperation and Development said Wednesday.
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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.
Expert Analysis
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9th Circ. Adds Pressure To Reject Substance Over Form
The Ninth Circuit’s recent decision rejecting taxes on a family's Roth IRA payments that were made through a foreign sales corporation represents a refreshing trend among federal appeals courts to reject substance-over-form principles and instead look to congressional intent, say Lawrence Hill and Caitlin Tharp at Steptoe & Johnson.
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Will The OECD Plan Fix International Taxation?
Lilian Faulhaber at Georgetown Law breaks down the Organization for Economic Cooperation and Development’s plan for international tax reform, recently joined by 130 countries, and whether it will solve the problems it was designed to address, including the need for multinational companies to pay their fair share of taxes in the digitized world economy.
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What Biden's Tax Proposals May Mean For Int'l Private Clients
Jennifer Wioncek and Paul D’Alessandro at Bilzin Sumberg discuss the U.S. Department of the Treasury's recently released explanation of the Biden administration's tax proposals and how the changes would affect income and wealth transfer planning for international private clients.
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What Crypto Holders Can Learn From Early-2000s Tax Scandal
The Internal Revenue Service’s recent push to gather information about cryptocurrency accounts is similar to its Swiss bank account investigations of the early 2000s, which should prompt taxpayers to consider voluntarily disclosing transactions before they are individually targeted for enforcement, say Timothy Wagner and Thomas Barnard at Baker Donelson.
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International Tax Reform's Implications For Transfer Pricing
As the Organization for Economic Cooperation and Development overhauls the global tax rules on base erosion and profit shifting, and the Biden administration rolls out new U.S. tax proposals, multinational enterprises need to prepare for the effects of these tax changes on their transfer pricing structures, say Mandy Li and Shuang Feng at MGO.
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Justices' Preemptive Tax Challenge Ruling Shows Divisions
The U.S. Supreme Court's recent decision in CIC Services v. Internal Revenue Service reveals divisions among the justices about when potentially burdensome tax regulations can be challenged, making the holding less clear and less valuable, say George Isaacson and David Swetnam-Burland at Brann & Isaacson.
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Takeaways From 2 New FBAR Rulings
In light of two recent California federal court decisions, capping penalties for nonwillful violations of foreign bank account reporting but broadening the willfulness standard, U.S. taxpayers must be vigilant about understanding their reporting obligations, and prepare for the Internal Revenue Service to target willful conduct, which yields much higher penalties, say Friedemann Thomma and Marianna Felshtiner at Venable.
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El Salvador's Use Of Bitcoin Complicates US Commercial Law
El Salvador recently became the first country to recognize Bitcoin as currency, presenting significant implications for U.S. commercial law as the development will likely trigger the cryptocurrency to now fall within the definition of "money" under the Uniform Commercial Code, say Joe Carlasare and Eric Fogel at SmithAmundsen.
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Justices' Nod To Preemptive Tax Challenges May Caution IRS
The U.S. Supreme Court's recent decision in CIC Services v. Internal Revenue Service, allowing pre-enforcement challenges of tax reporting rules despite the Anti-Injunction Act, is likely to make the U.S. Department of the Treasury more careful about its own compliance obligations under the Administrative Procedure Act, says Robert Carney at Caplin & Drysdale.
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Let's End The Offshoring Of US Patents
Congress should work toward removing the loophole that allows companies to avoid U.S. taxes by moving their patents offshore, and ensure profits are taxed where the sales take place, says Sen. Patrick Leahy, D-Vt.
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Long Road Ahead For Biden's Individual Tax Hike Proposal
Dustin Stamper at Grant Thornton provides insight into President Joe Biden's recently proposed individual tax increases to pay for his American Families Plan, and explains how competing interests among congressional Democrats and Republicans may shape the final provisions and prolong their implementation.
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What Value-Added Tax Might Look Like In The US
Christiaan Van Der Valk and Charles Maniace at Sovos consider the value-added tax, a primary source of revenue for many countries, and what it might mean for the U.S. were it implemented to raise funds for large-scale federal initiatives such as President Joe Biden's infrastructure plan.
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US Needs Better, Nonpunitive Approach To Greening Trade
Instead of imposing tariffs on goods produced where foreign governments have assisted in cleaning up the environment, the U.S. should make trade policy green by helping industries reduce their environmental impact and encouraging every foreign government to do the same, say Elliot Feldman and Michael Snarr at BakerHostetler.