International
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July 12, 2024
Alvarez & Marsal Appoints Managing Director Of Tax Group
Alvarez & Marsal Tax LLC appointed an experienced negotiator of tax incentives as managing director to the firm's corporate transformation tax group, the firm announced.
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July 12, 2024
EU Chair Doesn't Expect Energy Tax Deal This Year
The new chair of European Union finance ministers doesn't expect to reach agreement on a landmark energy taxation law in the next half-year, anticipating only exploratory talks, an official from Hungary's EU presidency said Friday.
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July 11, 2024
House GOP Urges USTR To Probe Canada Digital Services Tax
The U.S. trade representative should immediately launch an investigation into Canada's recently enacted digital services tax and determine if trade actions are necessary to protect American interests, U.S. House Ways and Means Republicans said in a letter Thursday.
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July 11, 2024
ABA Attys Seek To Avoid Reporting Foreign Trust Loans
The American Bar Association's tax, real estate and trust attorneys are seeking to prevent the U.S. Treasury Department from tightening reporting requirements for the exemption of loans from foreign trusts, which are often used by wealthy families and in succession planning, according to a consultation response.
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July 11, 2024
Brazilian Tax Agency Probes Refund Fraud Scheme
Brazilian federal tax authorities and police said Thursday they had conducted a search-and-seizure operation related to the investigation of an income tax refund fraud scheme.
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July 11, 2024
Ex-Leaders Ask Biden For Int'l Coordination On Billionaire Tax
President Joe Biden should get behind Brazil's proposal for the Group of 20 nations to coordinate a minimum tax on billionaires, nearly 20 former presidents and prime ministers from countries such as Canada, France and South Korea said in an open letter.
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July 11, 2024
IRS Proposes 'Basket Contracts' As Listed Transactions
The Internal Revenue Service proposed rules Thursday that would flag so-called basket option contracts as potentially abusive listed transactions, imposing additional reporting requirements under the threat of penalty for individuals and businesses involved in such arrangements.
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July 11, 2024
IRS, OECD Officials Detail Expansion Of AI In Tax Work
The Internal Revenue Service and Organization for Economic Cooperation and Development are making great progress in adopting artificial intelligence in tax administration, representatives of both organizations said Thursday.
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July 11, 2024
Israel Says Resident Hid $5.5M In Offshore Bank Accounts
An Israeli resident was released under restrictive conditions Thursday after the government alleged he failed to report foreign bank accounts that held more than 20 million shekels ($5.5 million), according to a statement from the Israel Tax Authority.
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July 11, 2024
Tax Haven Biz Revenues Per Worker Still Far Outpace Norm
Companies recorded median revenues per employee of $1.6 million in low-tax jurisdictions like Ireland, the Cayman Islands and Hong Kong and around $300,000 in all other jurisdictions in 2021, a difference that has narrowed since 2017, the OECD said Thursday.
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July 11, 2024
Biz Officials Call For Simpler Tax Rules In Light Of Pillar 2
Business representatives said Thursday that tax compliance rules need to be simplified as new minimum tax rules, known as Pillar Two, are added to the existing regime.
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July 11, 2024
Failure Of Pillar 1 Would Yield Worse Alternatives, Panel Says
A failure of the Pillar One agreement to reallocate corporate taxing rights would lead to alternatives that are worse, with the return of national digital services taxes worldwide, tax officials and academics said Thursday.
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July 10, 2024
Engineer Who Faced Export Charges Cops To Tax Counts
A Chinese-born engineer has pled guilty to two counts of filing a false tax return related to allegations that he and his wife omitted gross income from their tax returns between 2015 and 2019, after Texas federal prosecutors initially charged the couple with export violations and fraud.
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July 10, 2024
Portugal Enacts Pillar 2 As Part Of Economic, Tax Package
Portugal's Council of Ministers approved the minimum tax provision known as Pillar Two in a package of economic and tax measures designed to boost the country's economic growth, the council announced.
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July 10, 2024
OECD Publishes Pillar 2 Technical Reporting Language Draft
The Organization for Economic Cooperation and Development published a draft of technical details required to digitally input and disseminate information required for Pillar Two global minimum tax returns Wednesday.
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July 10, 2024
Americans Overseas Ask for Clarity In Foreign Trust Regs
An advocacy group representing U.S. citizens living abroad urged the U.S. Treasury Department to clarify proposed rules for reporting transactions with foreign trusts, contending that guidance should explain which common pension arrangements are exempt from disclosure obligations.
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July 10, 2024
Curtis Mallet-Prevost To Open Law Office In Saudi Arabia
Curtis Mallet-Prevost Colt & Mosle LLP has obtained a license to practice law in the Kingdom of Saudi Arabia, the firm announced this week.
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July 10, 2024
HMRC, CPS Beat Financier's Claim Over Botched Prosecution
HM Revenue and Customs and the Crown Prosecution Service have beaten claims of malicious prosecution and misfeasance in public office by a corporate financier following a failed criminal fraud case, with a judge finding that they had enough evidence to pursue him.
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July 10, 2024
French Left's Tax Pledges May Go Unfulfilled
The tax policy pledges put forward by the leftist bloc of parties that won the most seats in France's legislative election may not be fulfilled given the bloc's failure to win an outright majority.
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July 10, 2024
India's High Court Nixes Challenge To Taxing Of Tour Vehicles
The Indian Supreme Court dismissed a group of petitions challenging border taxes imposed by state governments on tour company vehicles because it said the litigation should have begun in a different court.
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July 10, 2024
Attempts To Scrap EU Tax Veto Are Useless, Hungary Says
Attempts by European Union countries to try to remove the requirement of unanimity for delicate policy decisions such as tax law and adding new EU member states are futile, Hungary's minister for European affairs said Wednesday.
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July 09, 2024
House Panel OKs Tax Breaks For More Education Expenses
The House Ways and Means Committee sent several education-related tax bills to the full House of Representatives on Tuesday, including legislation that would make additional elementary and secondary school expenses eligible for tax-advantaged education savings accounts.
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July 09, 2024
Irish Budget To Allocate €1.4B To Fund Tax Measures in 2025
The Irish government on Tuesday published the details of its €8.3 billion ($9 billion) budget for 2025, including €1.4 billion set aside to fund tax measures.
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July 09, 2024
India High Court Says Rights To Sell Liquor Aren't Taxed
The rights to sell the alcoholic beverage arrack are not taxed because the liquor vendors who purchase them do not fit into the definition of "buyer" under Indian tax law, the Supreme Court of India ruled.
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July 09, 2024
Finnish Tax Take Drops Amid Slowing Real Estate Market
The Finnish government's tax revenue declined 0.4% last year to €42.3 billion ($45.7 billion) as collections from levies on real estate purchases and car registrations each declined by more than 20%, the country's tax authority said Tuesday in a news release.
Expert Analysis
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Prepare For Global Tax Regime's New Biz Dispute Risks
Companies should take steps to mitigate the business dispute risks of the new international tax framework, which over a hundred countries agreed to in July, as implementing the new regime will be expensive and require substantial organizational restructuring efforts, says Tim McCarthy at Dykema.
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Prepare For More Audits Of Tax Info And Withholding Filings
Financial institutions and other corporate taxpayers should focus compliance efforts on tax information reporting and withholding, given recent indications from the Biden administration that the IRS will increase enforcement, and the administration's need to fund its infrastructure plan and other costly initiatives, say attorneys at Mayer Brown.
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Anti-Boycott Compliance Still Key In UAE Business Dealings
Notwithstanding recent amendments to U.S. anti-boycott laws that reflect the United Arab Emirates' withdrawal from the Arab boycott of Israel, companies doing business in the UAE and elsewhere still need to maintain effective anti-boycott compliance programs to avoid reporting violations or penalties, says Howard Weissman at Miller Canfield.
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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.