International
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June 03, 2024
Tax Convictions Withstand Poor Counsel Claim, 4th Circ. Says
A North Carolina man's claim of ineffective counsel is not sufficient reason to vacate his convictions for filing false tax returns and obstructing an official proceeding in a case involving $2.1 million in unreported income sent from Bermuda entities, the Fourth Circuit ruled.
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June 03, 2024
Texas Oil Co. Says IRS Hasn't Paid $36M Promised Refund
The Internal Revenue Service has promised to pay a Texas oil company more than $36 million in tax refunds and credits for the 2009 tax year but has failed to do so, the company told a federal court.
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June 03, 2024
African Gov'ts Made Big Gains From Data Swaps In 2023
African tax authorities made huge headway last year in using the international standard for exchange of information on request to find additional revenues of €2.2 billion ($2.4 billion), which is more than over the past 13 years combined, the OECD reported Monday.
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June 03, 2024
UK Liberal Democrats Call For Buyback Tax, Tripling DST
The U.K. Liberal Democrat party called for a 4% share buyback tax on the 100 largest corporations on the stock market as well as for tripling the country's 2% digital services tax, with the additional revenue generated to be earmarked to benefit schoolchildren.
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June 03, 2024
South Korea Extending Tax Breaks For Growing Businesses
Companies in South Korea that graduate from being considered small and medium enterprises to middle-market enterprises will see the grace period that allows them to continue to receive tax breaks granted to smaller entities extended, the country's finance ministry said Monday.
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June 03, 2024
7 Arrested In €18M Italian VAT Fraud Ring
Financial police in Italy arrested seven suspects Monday in connection with a value-added tax fraud scheme involving beverages that resulted in losses of €18 million ($19.6 million), the European Public Prosecutor's Office said.
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June 03, 2024
EU Court Asked To Rule On Belgian Tax On Dividends
A Belgian court asked the European Union's highest court to rule on whether the country can tax dividends transferred from a subsidiary to a parent company, despite an EU law apparently prohibiting this, a document published Monday showed.
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June 01, 2024
Blockbuster Summer: 10 Big Issues Justices Still Must Decide
As the calendar flips over to June, the U.S. Supreme Court still has heaps of cases to decide on issues ranging from trademark registration rules to judicial deference and presidential immunity. Here, Law360 looks at 10 of the most important topics the court has yet to decide.
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May 31, 2024
3M Tells 8th Circ. IRS Used Invalid Regs For $24M Allocation
Multinational conglomerate 3M reiterated Friday its bid for the Eighth Circuit to reverse a U.S. Tax Court decision allowing the IRS to allocate nearly $24 million from the company's Brazilian affiliate, arguing the agency's adjustment relied on substantively invalid regulations.
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May 31, 2024
IRS Guidance Narrows Spinoffs Available For Preapproval
Recent IRS guidance limiting the types of spinoff transactions that revenue officials will approve as tax-free ahead of time leaves practitioners and corporations to determine whether to pursue certain intercompany reorganizations without the agency's blessing.
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May 31, 2024
Ex-UBS Exec Owes $4.7M In FBAR Penalties, Court Told
A former CEO of Swiss bank UBS' North American group faces a $4.7 million tax bill that the U.S. claims is due because he did not report his foreign bank accounts or assets, according to a suit filed in Connecticut federal court.
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May 31, 2024
US, Bulgaria Sign Country-By-Country Reporting Agreement
The U.S. and Bulgaria signed an agreement Friday on the automatic exchange of country-by-country reports between the nations, Bulgaria's Ministry of Finance said.
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May 31, 2024
Latin American Tax Transparency Generates €2.1B In 5 Years
Tax transparency measures such as exchanges of financial information in Latin American countries have generated nearly €2.1 billion ($2.3 billion) in additional revenue over the past five years, according to an Organization for Economic Cooperation and Development report.
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May 31, 2024
Calif. Man Owes 6 Years Of FBAR Penalties, IRS Tells Court
A Californian has failed to pay foreign bank account reporting penalties he was assessed that were tied to a business he owed in Mexico for six years, the Internal Revenue Service told a federal court.
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May 31, 2024
Taxation With Representation: Cravath, Cleary, Fried Frank
In this week's Taxation With Representation, T-Mobile buys United States Cellular Corp.'s wireless operations, Energy Transfer plans to buy WTG Midstream, ConocoPhillips acquires Marathon Oil, and Goldman Sachs Alternatives raises over $20 billion for its direct lending strategy.
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May 31, 2024
Denmark's New VAT System Cuts Errors By 30%, Agency Says
A new Danish value-added tax reporting system that digitally cross-checks with data for European Union trade has reduced errors by about 30%, Denmark's tax agency said Friday.
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May 31, 2024
EU Eyes Permanent End To Vanuatu Visa Waiver
The European Commission said Friday that it wants to permanently end visa-free access for nationals of Vanuatu to the European Union because the EU says the island nation hasn't addressed risks in its investor citizenship programs.
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May 30, 2024
EU Court Rejects Appeal Over Spanish Port Tax Breaks
The European Union's Court of Justice on Thursday upheld a lower court ruling that corporate tax exemptions Spain extended to seaports were illegal state aid, brushing aside arguments that a more thorough economic analysis was warranted to prove the tax breaks bestowed an unfair advantage.
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May 30, 2024
Aussie State's Parliament Urges Taxing Consulting Cos.
Large companies that provide consulting services to the New South Wales government should be required to pay taxes on their company earnings along with payroll taxes on partnership earnings, according to a report from the Australian state's Parliament.
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May 30, 2024
Qatar Signs Double-Tax Agreements With Saudi Arabia, UAE
Qatar signed two agreements Thursday to prevent double taxation and tax evasion, one with Saudi Arabia and the other with the United Arab Emirates.
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May 30, 2024
Later Pillar 1 Due Date Set For June As Tax Talks Wrap Up
Diplomats agreed this week to finalize a treaty for reallocating some of large companies' tax payments and setting standards to simplify some transfer pricing in lower-income countries by June 30 after having missed a March deadline, according to a statement published Thursday by the OECD.
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May 30, 2024
Ex-KPMG Manager Joins Davis+Gilbert As Tax Partner
A former managing director at KPMG has joined New York law firm Davis+Gilbert LLP as a tax partner in its corporate and transactions practice, Davis+Gilbert announced.
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May 30, 2024
Tax Pros Agree With HMRC's Mandatory Agent Reporting Plan
Two groups representing tax professionals in the U.K. have agreed with a proposed rule requiring practitioners to register with HM Revenue & Customs while also supporting a secondary rule that would require membership with a professional body.
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May 30, 2024
Russian Gas Ex-CFO Says $44M FBAR Penalty Is Excessive
The former chief financial officer of a Russian gas company who was sentenced to seven years in prison for hiding money in Swiss banks told a Florida federal court that the $44 million in foreign account reporting penalties the government is seeking is illegally high.
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May 30, 2024
Panama Papers Leak Led To $283M In Swedish Tax Revenue
The Swedish Tax Agency said Thursday it has corrected the tax assessments of roughly 100 people and companies connected to the so-called Panama Papers leak, capturing roughly 3 billion Swedish kronor ($283 million) in added tax revenue.
Expert Analysis
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US-India Advance Pricing Resolutions Should Reassure Cos.
The United States' and India's tax authorities' recent resolution of a significant number of pending advance pricing agreements should reduce taxpayer uncertainty, reassure companies of the nations' good working relationship and improve India's investment environment, say Miller Williams and Caroline Setliffe at Eversheds Sutherland.
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Stock Buyback Excise Tax Guidance A Mixed Bag For SPACs
Recent IRS guidance on the new stock repurchase excise tax includes a welcome exception for publicly traded special-purpose acquisition companies but does not exclude redemptions in connection with a de-SPAC transaction, and further guidance is needed to clarify ambiguities around the exception's application, say Olga Bogush and Evgeny Magidenko at ArentFox Schiff.
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The IRS' APA Rulemaking Journey: There And Back Again
Attorneys at Dentons examine recent challenges in which taxpayers successfully argued Internal Revenue Service rulemaking was invalid under the Administrative Procedure Act, how tax exceptionalism and U.S. Supreme Court regulatory deference prompted such challenges, and similar challenges the agency will likely face following this line of cases.
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ECJ Fiat Ruling Sets Clear Boundaries For EU State Aid Law
The European Court of Justice's recent landmark decision in Fiat v. Commission limiting the commission’s attempts to circumvent the lack of EU powers in the area of tax law has important implications in EU state aid law and beyond, say Andreas Reindl and Pietro Stella at Van Bael.
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Unpacking The Interim Guidance On New Stock Buyback Tax
The U.S. Department of the Treasury and Internal Revenue Service's recent notice on applying the newly effective excise tax on stock repurchases provides much-needed clarity on the tax's scope, which is much broader than anticipated given its underlying policy rationale, say attorneys at Eversheds Sutherland.
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IRS Will Use New Resources To Increase Scrutiny In 2023
The new year promises to be a busy one for the Internal Revenue Service, which is poised to apply the boost in funding provided by the Inflation Reduction Act to bolster and expand its enforcement capability, and there are four areas to watch, say attorneys at Skadden.
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How Japan's Implementation May Change The Pillar 2 Debate
Japan’s outline of proposed legislation adopting a primary component of the Organization for Economic Cooperation and Development's 15% global minimum tax will increase pressure on countries — including the U.S. — that have not committed to adopting Pillar Two, says Takato Masuda of Nishimura & Asahi.
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Foreign Tax Credit Proposal Is Some Help, But More Is Needed
New foreign tax credit regulations proposed by the U.S. Treasury Department provided some measure of relief on cost recovery and royalty withholding, two of the most troublesome aspects of the 2021 final foreign tax credit regulations, but the final regulations are still harmful to many taxpayers, making litigation inevitable, say attorneys at Fenwick.
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IRS' Tax Gap Statistics Don't Paint A Full Compliance Picture
The Internal Revenue Service's recent report indicating a widening tax gap sheds important light on tax compliance, underlines key pressure points and provides insights into how tax administration could be improved; but tax gap estimates also have their limits, says Joyce Beebe at Rice University.
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How High Court Could Change FBAR Penalty Landscape
On Wednesday, the U.S. Supreme Court will hear Bittner v. U.S., a case that will affect many people penalized for failing to file a Report of Foreign Bank and Financial Accounts, and there are important procedural implications should the government's position be reversed, say Reuben Muller and Andreas Apostolides at Cole Schotz.
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IRS Memo May Change IP Royalty Tax Prepayment Planning
A recent Internal Revenue Service advice memorandum finding a taxpayer was not permitted to prepay tax on contingent royalties after contributing intellectual property offshore is a noteworthy departure from earlier guidance that highlights potential differences between actual and deemed licenses, says William Skinner at Fenwick.
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What IRS Funding Increase Means For Taxpayers
The Internal Revenue Service will first use the influx of funding from the Inflation Reduction Act to address customer support and personnel issues, but with over half the money allocated to enforcement, corporations and high-net-worth individuals will face increased scrutiny, say Patrick McCann Jr. and Jasen Hanson at Chamberlain Hrdlicka.
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6 Tax Considerations For Life Sciences Collaboration Deals
Given recent IRS guidance and changes to certain tax rates and deductions, biotech and life sciences companies entering into collaboration agreements should assess several unique taxation issues affecting matters ranging from research and development expenditures to profit-sharing terms, say attorneys at Orrick and Andersen Tax.