International

  • September 26, 2024

    UK Cos. Claimed Nearly £1.5B In Patent Box Relief In 2022-23

    While there was a slight dip in the number of U.K. companies that elected to use the country's patent box tax regime in the 2022-23 tax year compared with the prior year, the estimated value of relief claimed jumped to nearly £1.47 billion ($1.97 billion) compared with around £1.33 billion, HM Revenue & Customs said Thursday.

  • September 26, 2024

    UK R&D Tax Credit Claims Down, But Total Relief Up £100M

    While there was an over 20% dip in research and development tax credit claims in the U.K. in the 2022-23 tax year, the total relief claimed rose to £7.5 billion ($10.1 billion), a £100 million increase, HM Revenue & Customs said Thursday.

  • September 26, 2024

    UK Corp. Tax Receipts Up 10% To £93.3B, HMRC Says

    The U.K. generated £93.3 billion ($125 billion) in corporate tax receipts in the 2023-24 tax year, a 10% increase over the prior year, HM Revenue & Customs said Thursday, pointing mainly to the increase in the country's corporation tax rate to 25% as the reason behind the bump.

  • September 26, 2024

    ECJ Backs Strong Protection For Lawyer-Client Discussions

    Confidentiality of lawyer-client communications has enhanced protection under European Union law, including in cross-border tax disclosures, the European Court of Justice ruled Thursday.

  • September 26, 2024

    OECD Publishes Streamlined Amount B Model Agreement

    The Organization for Economic Cooperation and Development published a model agreement Thursday for a simplified and streamlined approach to the Amount B portion of Pillar One, a transfer pricing plan for certain baseline marketing and distribution activities.

  • September 25, 2024

    IBM Urges Justices To Review NY Tax On Foreign Royalties

    New York's system for taxing royalty payments would be unconstitutional if every other jurisdiction adopted it, violating an internal consistency test reaffirmed by a 2015 precedent, IBM told the U.S. Supreme Court in asking it to review and overturn New York's high court ruling that allowed the tax regime.

  • September 25, 2024

    Boosting Indirect Tax Revenues Can Tackle Debt, OECD Says

    A number of countries should look to eliminate distortive tax expenses as well as increase their revenue from certain taxes to help manage debt sustainability and make their economies more supportive of growth, the Organization for Economic Cooperation and Development said Wednesday.

  • September 25, 2024

    Expect More R&D Guidance Before Regs, IRS Atty Says

    The Internal Revenue Service plans to release more guidance governing the tax treatment of research and development expenses before it formally issues proposed regulations that implement the 2017 federal tax law's changes to the incentive, an agency attorney said Wednesday.

  • September 25, 2024

    EU States Must Unify Divergent Biz Rules, Majority Says

    The European Union must double down on unifying its divergent rules for businesses in a policy proposal next year because the bloc's main competitive advantage is its single market, almost three-quarters of EU countries told the bloc's executive arm.

  • September 25, 2024

    Basis-Shifting Regs May Add Accounting Fixes, IRS Atty Says

    The Internal Revenue Service may include in upcoming proposed regulations a solution for partnership basis-shifting for taxpayers that want to adjust accounting methods so prior transactions can be compliant with economic substance laws, an agency attorney said Wednesday.

  • September 25, 2024

    Wyden Calls On 2025 Tax Bill To Include Partnership Reform

    Lawmakers should consider next year how to revise partnership tax laws to better collect on large businesses' income without harming smaller entities as Congress debates over how to address expiring tax provisions, Senate Finance Committee Chairman Ron Wyden said Wednesday.

  • September 25, 2024

    Australia Floats Updates To Amended Tax Pro Conduct Code

    After repeated pushback against changes to Australia's tax agent code of conduct, the country's Treasury proposed two further amendments Wednesday that aim to address complaints regarding corrections of false or misleading statements and disclosures of information to clients.

  • September 25, 2024

    Hong Kong, Turkey Reach Double-Tax Agreement

    Hong Kong and Turkey agreed to a treaty to prevent double taxation, which would take effect after approval by both jurisdictions' legislatures, Hong Kong's Inland Revenue Department said.

  • September 25, 2024

    French Finance Minister Signals Higher Taxes On Rich

    The new French government is considering raising taxes on the wealthy and businesses to help reduce the country's budget deficit amid concerns over debt, according to remarks by the new finance minister.

  • September 25, 2024

    Puerto Rico Seeking Input On Implementing Global Min. Tax

    Puerto Rico's Department of the Treasury is looking for public comments regarding possible implementation of the Organization for Economic Cooperation and Development's 15% global corporate minimum tax on large multinational entities.

  • September 25, 2024

    HMRC Arrests 11 Suspected Of R&D Tax Fraud

    HM Revenue & Customs arrested 11 people, including tax agents, at several locations on suspicion of defrauding research and development tax relief programs, officers said.

  • September 24, 2024

    Halliburton Tardy In Contesting $35M Deduction, US Says

    A Halliburton Co. lawsuit claiming a deduction for a $35 million payoff to a foreign country must be dismissed because the company waited too long to start its action, the U.S. told a Texas federal court.

  • September 24, 2024

    Microsoft Fights Mich. Tax Treatment Of Cost Share Payments

    Microsoft urged the Michigan Tax Tribunal to find that cost sharing agreement receipts from affiliates constituted licenses of intellectual property that should be included in its apportionment formula, arguing that the state's tax agency incorrectly followed federal transfer pricing rules in excluding the payments from its tax calculations.

  • September 24, 2024

    Digital Asset Rules Coming By Year's End, Treasury Atty Says

    The U.S. Treasury Department and the Internal Revenue Service intend to release rules "later this year" on additional reporting requirements for brokers of digital assets such as cryptocurrency and nonfungible tokens, a senior Treasury attorney said Tuesday.

  • September 24, 2024

    Abbott Seeks $24M Refund Over Transfer Pricing Adjustments

    Healthcare products giant Abbott Laboratories is owed $24.3 million for overpaid taxes after the IRS incorrectly adjusted its intragroup income and payments this year, the company told the U.S. Tax Court in a petition.

  • September 24, 2024

    IRS Wary Of Adding Complexity In Min. Tax Regs, Official Says

    The IRS opted to use existing tax rules in proposed guidance to address risks that the U.S. corporate alternative minimum tax could count offshore income twice, an agency official said Tuesday, noting a more precise method would increase complexity.

  • September 24, 2024

    Australia Floats Denying Late, Wrong Tax Interest Deductions

    Australia's government opened a consultation Tuesday on a measure that would deny tax deduction claims for interest charged on late payments of tax liabilities as well as for interest charged when incorrect self-assessments result in a shortfall of tax paid.

  • September 24, 2024

    Treasury To Allow 3 AMT Transition Methods, Official Says

    Final rules on the new corporate alternative minimum tax are expected to adopt the proposed regulations' three ways for companies to transition to the regime, and the U.S. Treasury Department is open to other ways as well, a department official said Tuesday.

  • September 24, 2024

    Exxon Claims It Beat Weak Defense In $1.8B Tax Trial

    Exxon Mobil urged a Texas federal judge to find that it defeated what it called a scattered defense by the U.S. government during a five-day bench trial in April when the company argued for a $1.8 billion tax refund on its natural gas deal with Qatar, according to newly released filings.

  • September 24, 2024

    Azerbaijan Ratifies OECD Tax Treaty Standards

    Azerbaijan ratified the Organization for Economic Cooperation and Developement's multilateral convention on base erosion and profit shifting Tuesday, which updates bilateral tax treaties of its signatories with agreed-upon standards, the OECD said.

Expert Analysis

  • Using A Children's Book Approach In Firm Marketing Content

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    From “The Giving Tree” to “Where the Wild Things Are,” most children’s books are easy to remember because they use simple words and numbers to tell stories with a human impact — a formula law firms should emulate in their marketing content to stay front of mind for potential clients, says Seema Desai Maglio at The Found Word.

  • New Crypto Reporting Will Require Rigorous Recordkeeping

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    The release of a form for reporting digital asset transactions is a pivotal moment in the Internal Revenue Service's efforts to track cryptocurrency activities that increases oversight by requiring brokers to report investor sales and exchanges, say Shaina Kamen and Max Angel at Holland & Knight.

  • Exploring An Alternative Model Of Litigation Finance

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    A new model of litigation finance, most aptly described as insurance-backed litigation funding, differs from traditional funding in two key ways, and the process of securing it involves three primary steps, say Bob Koneck, Christopher Le Neve Foster and Richard Butters at Atlantic Global Risk LLC.

  • A Vision For Economic Clerkships In The Legal System

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    As courts handle increasingly complex damages analyses involving vast amounts of data, an economic clerkship program — integrating early-career economists into the judicial system — could improve legal outcomes and provide essential training to clerks, say Mona Birjandi at Data for Decisions and Matt Farber at Secretariat.

  • A Look At New IRS Rules For Domestically Controlled REITs

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    The Internal Revenue Services' finalized Treasury Regulations addressing whether real estate investment trusts qualify as domestically controlled adopt the basic structure of previous proposals, but certain new and modified rules may mitigate the regulations' impact, say attorneys at Simpson Thacher.

  • E-Discovery Quarterly: Recent Rulings On Text Message Data

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    Electronically stored information on cellphones, and in particular text messages, can present unique litigation challenges, and recent court decisions demonstrate that counsel must carefully balance what data should be preserved, collected, reviewed and produced, say attorneys at Sidley.

  • Don't Use The Same Template For Every Client Alert

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    As the old marketing adage goes, consistency is key, but law firm style guides need consistency that contemplates variety when it comes to client alert formats, allowing attorneys to tailor alerts to best fit the audience and subject matter, says Jessica Kaplan at Legally Penned.

  • Think Like A Lawyer: Follow The Iron Rule Of Trial Logic

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    Many diligent and eager attorneys include every good fact, point and rule in their trial narratives — spurred by the gnawing fear they’ll be second-guessed for leaving something out — but this approach ignores a fundamental principle of successful trial lawyering, says Luke Andrews at Poole Huffman.

  • The Art Of Asking: Leveraging Your Contacts For Referrals

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    Though attorneys may hesitate to ask for referral recommendations to generate new business, research shows that people want to help others they know, like and trust, so consider who in your network you should approach and how to make the ask, says Rebecca Hnatowski at Edwards Advisory.

  • Unpacking The Bill To Extend TCJA's Biz-Friendly Tax Breaks

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    Attorneys at Skadden examine how a bipartisan bill currently being considered by the U.S. Senate to save the Tax Cuts and Jobs Act's tax breaks for research and development costs, and other expiring business-friendly provisions, would affect taxpayers.

  • Deciding What Comes At The End Of WTO's Digital Tariff Ban

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    Companies that feel empowered by the World Trade Organization’s recent two-year extension of the ban on e-commerce tariffs should pay attention to current negotiations over what comes after the moratorium expires, as these agreements will define standards in international e-commerce for years to come, say Jan Walter, Hannes Sigurgeirsson and Kulsum Gulamhusein at Akin Gump.

  • 4 Ways To Refresh Your Law Firm's Marketing Strategy

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    With many BigLaw firms relying on an increasingly obsolete marketing approach that prioritizes stiff professionalism over authentic connection, adopting a few key communications strategies to better connect with today's clients and prospects can make all the difference, say Eric Pacifici and Kevin Henderson at SMB Law.

  • This Earth Day, Consider How Your Firm Can Go Greener

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    As Earth Day approaches, law firms and attorneys should consider adopting more sustainable practices to reduce their carbon footprint — from minimizing single-use plastics to purchasing carbon offsets for air travel — which ultimately can also reduce costs for clients, say M’Lynn Phillips and Lisa Walters at IMS Legal Strategies.

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