International

  • July 31, 2024

    EU Seeks Feedback On Effectiveness Of Anti-Avoidance Law

    The European Commission said Wednesday that it is looking for feedback on how the European Union's anti-tax avoidance directive has fared since going into force in 2020, in particular concerning the bloc-wide implementation of the OECD's global minimum corporate tax standards.

  • July 31, 2024

    French Politician Wants VAT Cut For Repairs To Churches

    A French politician is asking the European Commission to consider expanding the scope of rate reductions for value-added taxes to include the renovation of historic monuments, including churches, according to a letter released Wednesday.

  • July 30, 2024

    IRS Spinoff Guidance Raises Practical Concerns, NY Attys Say

    Recent IRS guidance narrowing the corporate spinoff transactions that revenue officials will approve as tax-free ahead of time doesn't adequately consider the practical and commercial factors involved in these transactions, the New York State Bar Association's Tax Section said Tuesday.

  • July 30, 2024

    Israeli Man Seeks To Avoid Discovery In $3.6M FBAR Case

    A federal court should not order the Israeli founder of a pet toy company to show cause for defying its discovery orders in the U.S. government's $3.6 million case over his failure to report foreign bank accounts because he is ending his defense, his attorneys said Tuesday.

  • July 30, 2024

    Kyocera Chides Gov't Attack On Jurisdiction In $7M Tax Case

    The government's attempt to defeat a South Carolina federal court's jurisdiction is improper because it relies on a roughly $44 million assessment lodged months after electronics maker Kyocera filed an amended complaint for a $7 million federal tax refund, according to the company.

  • July 30, 2024

    Ropes & Gray Adds Partner To Int'l Tax Practice

    Ropes & Gray LLP recently added a tax adviser with a wealth of experience navigating transactions, funds and investments for clients as a partner in its New York office, the firm said.

  • July 30, 2024

    Chubb Says It Would Be Harmed By US-Swiss Treaty

    Chubb and its shareholders would be significantly harmed by the terms of a proposed new bilateral tax treaty between the U.S. and Switzerland because it would be denied tax relief despite having been domiciled in Switzerland for over 15 years, the global insurer said in a letter released Tuesday.

  • July 30, 2024

    Husch Blackwell Hires UB Greensfelder Partner In St. Louis

    Several years after Husch Blackwell LLP's newest partner, Garrett Reuter Jr., graduated from law school, he joined Greensfelder Hemker & Gale PC to work alongside his late father. Now, he's bringing clients he grew up watching his father work with, to a new platform.

  • July 30, 2024

    UK Healthcare Ex-Directors Banned For £30M In Unpaid Taxes

    Two former directors of a defunct U.K. healthcare company are banned from holding executive positions at any business after failing to pay more than £30 million ($38.5 million) in taxes, the government's insolvency agency said Tuesday.

  • July 30, 2024

    Israel Moving To Adopt Portion Of Global Minimum Tax

    Israel's Ministry of Finance said it is working to adopt a portion of the Organization for Economic Cooperation and Development's 15% global minimum tax on large multinational entities starting in 2026 while delaying consideration of two other portions.

  • July 30, 2024

    Tax Pros Vent Displeasure At EU Disclosure Law

    Tax professionals commenting on a European Union disclosure law by the deadline Tuesday vented long-held displeasure at the measure, which requires tax preparers to reveal cross-border strategies.

  • July 30, 2024

    Pension Tax Reform Could Unlock £100B For UK Growth

    Changing how pensions are taxed in the U.K. could potentially unlock more than £100 billion ($128 billion) for domestic investment over the next five years, according to a recent analysis by a pensions consultancy.

  • July 29, 2024

    Utah Biz Groups Latest To Challenge Corp. Disclosure Law

    Several small-business associations in Utah became the latest group to challenge the Corporate Transparency Act's disclosure requirements, telling a federal court Monday the statute violates several constitutional provisions, including the guarantee of due process.

  • July 29, 2024

    Immigrants Paid $96.7B In Taxes In 2022, ITEP Study Says

    Unauthorized immigrants paid $96.7 billion in federal, state, and local taxes in 2022 but received few benefits in return, according to a new study released Monday, whose authors said granting such taxpayers work authorization would boost tax revenue and economic activity.

  • July 29, 2024

    Sites Should Pay Sport Fishing, Archery Import Tax, GAO Says

    Congress should make U.S. online marketplaces responsible for any sport fishing and archery excise taxes owed on consumer import sales they're involved with, the Government Accountability Office said in a report released Monday.

  • July 29, 2024

    UK Seeks Input On Rule Targeting Min. Tax's Safe Harbor

    HM Revenue & Customs opened a consultation Monday seeking comments on an anti-arbitrage rule to help prevent large multinational companies from exploiting the safe harbor provision in the Organization for Economic Cooperation and Development's global minimum tax.

  • July 29, 2024

    ECJ Nixes Swedish Dividends Tax On Foreign Pension Funds

    Sweden can't collect a withholding tax on dividends distributed by Swedish companies to public pension funds abroad while exempting its own public funds because that is inconsistent with European Union law requiring the free movement of capital, the European Court of Justice said Monday.

  • July 29, 2024

    France Restricts Access To Beneficial Ownership Registry

    France is dialing back access to its beneficial ownership information registry by introducing what it is calling a filtering system that limits the previously entirely public database starting Wednesday, the French Finance Ministry said Monday.

  • July 29, 2024

    Gov't Consults On Tax Hikes For Fund Managers, Non-Doms

    Chancellor Rachel Reeves said Monday that an autumn Budget planned for Oct. 30 will include feature selected tax rises, a warning accompanied by strong hints from HM Treasury that fund managers and non-domicile taxpayers could take a bigger hit.

  • July 29, 2024

    EU's Highest Court Upholds Disclosure Law

    The European Union's highest court on Monday upheld the bloc's law requiring tax advisers to report potentially aggressive cross-border tax arrangements, rejecting a challenge from Belgian tax attorneys who said their country's implementation of the EU's DAC6 law violated European law.

  • July 26, 2024

    G20 Declines To Back Brazil's Plan For A Minimum Wealth Tax

    Finance ministers from the Group of 20 nations declined to back Brazil's proposal for an agreement on individual wealth taxation similar to the global corporate minimum tax, instead issuing a statement Friday that opted for softer language about cooperation.

  • July 26, 2024

    Biz Groups Call Corp. Transparency Act Unconstitutional

    The U.S. government has failed to show how the Corporate Transparency Act meets narrow exceptions to the Fourth Amendment's search warrant requirements, a group of small businesses told a Michigan federal court Friday in contending that the statute is unconstitutional.  

  • July 26, 2024

    Denmark's Tax Losses From Evasion Fell 70%, Study Says

    Denmark's tax losses from offshore evasion by individuals dropped 70% following the implementation of the automatic exchange of banking information between tax authorities, researchers found in a study of the Danish Tax Agency's data.

  • July 26, 2024

    Chile Considering New Tax Compliance Measures

    Chile's Senate Finance Committee approved a tax compliance measure that includes creating an anonymous whistleblower process related to tax crimes, a lifting of bank secrecy measures and an overall modernization of the country's revenue agency, the country's Ministry of Finance said.

  • July 26, 2024

    Denmark Says Pension Plans Misread Law In $2B Fraud Case

    U.S. pension plans accused by Denmark's tax agency of participating in a $2.1 billion fraud scheme involving withholding tax refunds are misconstruing Danish law as it applies to the ownership of shares, the agency told a New York federal court.

Expert Analysis

  • How Japan's Implementation May Change The Pillar 2 Debate

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    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.

  • Foreign Tax Credit Proposal Is Some Help, But More Is Needed

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    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.

  • IRS' Tax Gap Statistics Don't Paint A Full Compliance Picture

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    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.

  • How High Court Could Change FBAR Penalty Landscape

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    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.

  • IRS Memo May Change IP Royalty Tax Prepayment Planning

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    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.

  • What IRS Funding Increase Means For Taxpayers

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    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.

  • 6 Tax Considerations For Life Sciences Collaboration Deals

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    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.

  • Rushed Multilateral Negotiations Caused Two-Pillar Tax Mess

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    Cracks appearing in the two pillars of the 2021 global tax plan stem from a multilateral tax policy process that rushed to issue rules without first resolving fundamental differences between countries or ensuring that the U.S., a key player, could implement them, says Jefferson VanderWolk at Squire Patton.

  • Key Considerations For Seeking Relief From Double Taxation

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    Caroline Setliffe and E. Miller Williams at Eversheds Sutherland lay out the Organization for International Cooperation and Development’s mutual agreement procedure for settling double-taxation disputes, and discuss six factors U.S. taxpayers doing business in multiple countries should consider when determining the most advantageous form of relief.

  • 2 Tax Decisions Hold Key Transfer Pricing Takeaways

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    Richard Slowinski and Stefanie Kavanagh at Alston & Bird discuss two recent decisions in cases against the IRS — Eaton Corp. from the Sixth Circuit and Medtronic from the Tax Court — that may help clarify when the agency can cancel an advance pricing agreement, but leave unanswered questions about which pricing method applies to high-value intercompany licensing transactions.

  • Digital Taxation Is Necessary, But Tough To Manage

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    The U.S. government has started to tackle complex new tax laws as the digital economy continues to grow, but this demands guidelines that will facilitate the growth while protecting investors and the government's finances, say attorneys at Cadwalader.

  • Company Considerations For Cash Award Incentives: Part 2

    Excerpt from Practical Guidance
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    Cash awards can help companies address some issues associated with equity awards to compensate employees, but due to potential downsides, they should be treated as a tool in a long-term incentive program rather than a panacea, say Denise Glagau and Kela Shang at Baker McKenzie.

  • Company Considerations For Cash Award Incentives: Part 1

    Excerpt from Practical Guidance
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    Denise Glagau and Kela Shang at Baker McKenzie discuss what companies must consider when offering cash awards outside of U.S. jurisdictions, and explain how some challenges associated with equity awards may be addressed with cash awards.

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