International
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May 06, 2024
Austrian Tax Investigations Collected €49M In 2023
Austrian tax investigators carried out 210 investigations in 2023, securing a total of €48.86 million ($52.6 million) in back taxes, with perpetrators possibly owing as much as €100 million in fines, the country's finance ministry said Monday.
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May 06, 2024
EU Court Asked To Rule On Italian Nix Of Biz Tax Deductions
The European Union's highest court was asked to rule on Italy's policy denying Italian parent companies certain tax deductions of corporate taxes paid by their subsidiaries in other EU countries, a question arising from an Italian bank's court challenge, a document published Monday showed.
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May 06, 2024
Macron-Backed Group Backs G20 Wealth Tax In Election Pitch
A group campaigning in the European Parliament elections that is backed by French President Emmanuel Macron supports a wealth tax in the world's largest economies, according to a campaign platform published Monday.
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May 04, 2024
IRS Seeks More Info On Purpose Test In Buyback Tax Regs
The IRS is seeking more information on fine-tuning a test in proposed rules on the stock buyback tax meant to assess whether the principal purpose of a U.S. subsidiary's funding purchase of its foreign parent's stock is to avoid the tax, an agency attorney said Saturday.
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May 03, 2024
US Resisting More Scoping On Amount B, Economist Says
In negotiations over the streamlined transfer pricing approach for baseline marketing and distribution functions known as Amount B, the U.S. has resisted calls for additional scoping criteria that would exclude more companies from the safe harbor, a former U.S. Treasury economist said Friday.
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May 03, 2024
Foreign Trust Reporting Rules Coming Soon, IRS Official Says
The Internal Revenue Service is about to issue proposed regulations that will provide guidance on the reporting obligations for individuals who have transactions with foreign trusts, an agency official said Friday.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
Expert Analysis
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Advancing The Democratic Tax Agenda In 2021
Even with a divided government starting next year, Democrats will have a major effect on tax policy, pursuing legislative compromises and regulatory changes in service of President-elect Joe Biden's tax plan, and potentially reversing many Trump administration initiatives, say Russell Sullivan and Radha Mohan at Brownstein Hyatt.
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M&A Poised For Growth In The Biden Era
The M&A market is well positioned for recovery and growth under a Biden administration and divided Congress, which will likely gain control over the coronavirus pandemic, pass a stimulus package, and provide greater transparency in antitrust enforcement, say attorneys at Debevoise.
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Final BEAT Regs Still Contain Pitfalls For Taxpayers
Recently finalized U.S. Department of the Treasury regulations retain a taxpayer-friendly election allowing corporations to waive deductions to avoid the base erosion and anti-abuse tax, but neglect to include recourse for companies that waive more deductions than necessary, say attorneys at Ropes & Gray.
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Post-Election Tax Policy Scenario 3: A Divided Government
Attorneys at Brownstein Hyatt consider whether Democrats and Republicans will find common ground on tax policies and legislation regarding COVID-19 relief, domestic research and manufacturing, pension and retirement savings, foreign taxation of U.S. companies, and infrastructure development if the upcoming election results in a divided government.
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Post-Election Tax Policy Scenario 2: A Democratic Sweep
Russell Sullivan and Radha Mohan at Brownstein Hyatt consider former Vice President Joe Biden’s perspective that a better economy addresses income inequality, and the likelihood of passing specific tax measures in the event of a Democratic sweep, despite varying party perspectives.
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Post-Election Tax Policy Scenario 1: A Republican Sweep
Attorneys at Brownstein Hyatt analyze tax policies implemented by the Trump administration, such as the Tax Cuts and Jobs Act, and consider what will be on the agenda if Republicans gain full control of both the legislative and executive branches in the election.
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Defensive Strategies For High-Net-Worth Individual Tax Audits
When representing high-net-worth individuals in a tax audit, defensive strategies that cooperate with the examiner and respond to government requests should reflect the overarching goal of preserving client objections, privileges, limitations periods and any other rights in case there is future litigation, says Patrick McCann at Chamberlain Hrdlicka.
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Canadian Tax Ruling Signals Cross-Border Structure Security
After the Tax Court of Canada's recent ruling in AgraCity v. The Queen that the company's arm's-length tax arrangements with a foreign subsidiary were legitimate, and a similar result in a different matter, Canadian taxpayers can have confidence that their cross-border related party transaction structures will be upheld, says Matt Billings at Duff & Phelps.
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Preparing The Next Generation Of Female Trial Lawyers
To build the ranks of female trial attorneys, law firms must integrate them into every aspect of a case — from witness preparation to courtroom arguments — instead of relegating them to small roles, says Kalpana Srinivasan, co-managing partner at Susman Godfrey.
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Mentorship Is Key To Fixing Drop-Off Of Women In Law
It falls to senior male attorneys to recognize the crisis female attorneys face as the pandemic amplifies an already unequal system and to offer their knowledge, experience and counsel to build a better future for women in law, says James Meadows at Culhane Meadows.
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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.