International
-
May 13, 2024
Estonia Objecting To VAT Proposal On 'Neutrality' Grounds
Estonia is objecting to a proposed overhaul of European Union value-added tax rules because the proposal doesn't respect the principle of "neutrality," the country's finance minister said Monday, casting doubt on the fate of the proposal, which needs agreement by all 27 EU countries to pass.
-
May 13, 2024
EU Chair Offers Compromise To Clinch Withholding Tax Deal
The chair of European Union finance ministers offered last-minute concessions to try to persuade holdouts the Czech Republic and Poland to agree to a withholding tax refund law, a document published Monday showed.
-
May 11, 2024
Gov't Urges 8th Circ. To Uphold 3M's $24M Pricing Adjustment
The U.S. government asked the Eighth Circuit to uphold a U.S. Tax Court decision allowing the IRS to allocate nearly $24 million from 3M's Brazilian affiliate, arguing the company's appeal involves misplaced reliance on a U.S. Supreme Court decision.
-
May 10, 2024
5 Goals Gov'ts Have For The UN Tax Convention
Transfer pricing, country-by-country reporting, wealth taxation, the digital economy and the participation of developing countries in negotiations are topics governments at the United Nations said they want to address during the first session on drafting terms of reference for the Framework Convention on International Tax Cooperation.
-
May 10, 2024
Austria Eyes Fines For Fake Invoices Used In Tax Fraud
People creating false invoices in Austria could face fines of up to €100,000 ($108,000) as the country looks to crack down on tax fraud involving fictitious businesses, the country's Ministry of Finance said Friday.
-
May 10, 2024
DC Tax Atty Can't Use Ch. 7 To Ditch Depo In $19M Theft Suit
A corporate D.C. tax attorney accused of bilking a former client out of $19 million via a captive insurance scam will be deposed, despite a stay in the Maryland federal case against him and his firm after both filed for bankruptcy.
-
May 10, 2024
Use Of AI For Tax Comment Letters Poses Ethical Quandaries
While artificial intelligence can streamline the process of conducting a comprehensive review of complex, IRS-proposed federal tax regulations, tax attorneys must be aware of professional and ethical considerations when using it to help draft comment letters to submit to the agency.
-
May 10, 2024
Australia Looks To Tweak Tax Exemption For US Entertainers
Australia wants public comments on a proposal that would simplify the elimination of withholding taxes for U.S. entertainers who make $10,000 or less — or the Australian equivalent — in the country in a given year, the Australian Taxation Office said.
-
May 10, 2024
Calif. OTA In Untested Area On Ruling That Biz Wants Binding
A decision by California's Office of Tax Appeals that Microsoft can include 100% of the dividends from foreign affiliates in its California sales factor denominator pleased businesses, who now want the OTA to designate the opinion as precedential, thus binding on it and the state Franchise Tax Board.
-
May 10, 2024
Osborne Clarke Lawyer To Face Tribunal Over Zahawi SLAPP
An Osborne Clarke LLP partner who represented Nadhim Zahawi could face a disciplinary tribunal over allegations that he used intimidatory warnings in an attempt to silence a critic who was probing the former Conservative chancellor's tax affairs.
-
May 09, 2024
Mich. Doctor Ordered To Stay In Jail Until Assets Repatriated
A Michigan doctor fighting accusations that he failed to report his foreign bank accounts will stay in jail, as a federal court declined to release him Thursday when he didn't comply with an order to deposit over $1 million to cover the judgment against him.
-
May 09, 2024
Pop Star Shakira's €6.6M Spanish Tax Fraud Case Dropped
A Spanish court dropped a case alleging that Colombian pop superstar Shakira had willfully defrauded the country of €6.6 million ($7.1 million) worth of taxes in 2018, multiple news outlets reported Thursday.
-
May 09, 2024
Pension Plans Want Witness Stopped In $2B Danish Dispute
U.S. pension plans accused by Denmark's tax authority of committing $2.1 billion in fraud against the European country by taking illegal refunds on dividends asked a New York federal court to reject the authority's request to depose a witness who pled guilty in Denmark.
-
May 09, 2024
Voluntary Carbon Credit Trades Will Trigger UK VAT
Transactions involving voluntary carbon credits in the U.K. will be assessed value-added tax starting in September, HM Revenue & Customs said Thursday.
-
May 09, 2024
IRS Turning to Final PFIC Rules This Year, Official Says
The Internal Revenue Service expects to "begin in earnest" this year on final regulations for partnerships that hold stock in passive foreign investment companies, including guidance that would treat partnerships as an aggregate of their partners, an agency official said Thursday.
-
May 09, 2024
Country Adjustment Would Undermine Common EU Tax Base
Allowing countries within the European Union to adjust companies' allocated tax base under proposed rules would undermine the rules' goal of streamlining the corporate tax base, according to business groups.
-
May 08, 2024
DOJ Says Man Owes $6.2M After Failing To Report Foreign Biz
A man owes tax penalties of $6.2 million to the U.S. after failing to disclose his ownership interests in two foreign entities from 1997 to 2004, the government told a California federal court Wednesday.
-
May 08, 2024
Biz Groups Tell 10th Circ. Economic Substance Doesn't Apply
The economic substance doctrine doesn't apply when a business considers tax in making a choice between two legally permissible alternatives, two organizations told the Tenth Circuit in their briefs supporting Liberty Global's position in its $109 million tax refund bid.
-
May 08, 2024
4th Circ. Asks If High Court Ruling Bars Credit Suisse Tipster
A Fourth Circuit panel questioned Wednesday whether a U.S. Supreme Court ruling prevented it from reviving a whistleblower case by a former Credit Suisse employee alleging the bank helped U.S. citizens evade taxes after paying a $2.6 billion criminal penalty.
-
May 08, 2024
Auto Cos. Brace For EV Battery Compliance Hurdles
New federal regulations aimed at shoring up the domestic electric vehicle manufacturing supply chain give automakers a much-needed two-year cushion to navigate a compliance minefield, and to figure out how to reinvigorate the recent waning consumer demand for electric vehicles.
-
May 08, 2024
Africa Should Solve Own Tax Problems, Nigerian Official Says
The solutions to Africa's taxation challenges should come from those actually on the continent, not the Western world, the chairman of Nigeria's tax authority said at an African Tax Administration Forum meeting, the authority said Wednesday.
-
May 08, 2024
EGC Won't Annul EU Decision To Toss Spanish Tax Scheme
The European General Court will not annul a European Commission decision that a Spanish tax scheme for vessels built in its domestic shipyards must be abandoned because it was incompatible with the European Union's internal market, according to a judgment released Wednesday.
-
May 08, 2024
Ambulance Co.'s Former Owner Gets 6 Years For Tax Evasion
The former owner of an ambulance company was sentenced to more than six years in federal prison for failing to pay employment taxes to the federal government and obstructing the Internal Revenue Service as it tried to collect, according to Virginia federal court documents.
-
May 08, 2024
A Foley Hoag Co-Chair Joins Litigation Firm As Name Partner
Litigation and dispute resolution firm Elliott Kwok Levine & Jaroslaw LLP will operate under a new name after welcoming as its newest name partner a former federal prosecutor who most recently co-chaired Foley Hoag LLP's white-collar crime and government investigations practice.
-
May 08, 2024
UN To Publish Draft Terms Of Reference For Tax Pact In June
National governments agreed Wednesday to publish the first draft of terms of reference for the United Nations Framework Convention on International Tax Cooperation for a two-week consultation during the week beginning June 3.
Expert Analysis
-
Tax Takeaways From India's Proposed Budget
Consultants at Deloitte discuss the tax implications of India's latest budget proposals, including the potential benefits for foreign portfolio investors and offshore funds migrating to India's new international financial services center, and the possible rise of M&A costs.
-
A Tough Road Ahead for Democrats' Ambitious Policy Agenda
While Democrats in Congress are well on their way to enacting an initial COVID-19 relief bill, they will face challenges when pivoting to President Joe Biden's Build Back Better goals for job creation and economic revitalization, say Russell Sullivan and Radha Mohan at Brownstein Hyatt.
-
Coca-Cola Tax Ruling Offers 5 Lessons For Multinationals
The U.S. Tax Court's decision that Coca-Cola owes more than $3.3 billion in taxes is instructive on important transfer pricing concepts, including those regarding intercompany agreements, the arm's-length standard and tax certainty, says Justin Radziewicz at Duff & Phelps.
-
Start Preparing For Germany's Corporate Sanctions Act
Germany’s soon-to-be-adopted Corporate Sanctions Act carries a presumption of mandatory prosecution but also a defense in cases where reasonable precautions fail to prevent nonmanagers from committing crimes, so companies should start putting such compliance programs into place now, say attorneys at Arnold & Porter.
-
Analyzing Illegality Defense Trend In Investor-State Arbitration
Cairn Energy v. India, a recent Permanent Court of Arbitration case, highlights the growing trend of states alleging illegal investor conduct to challenge tribunal jurisdiction or investor claim admissibility, say Caline Mouawad at Chaffetz Lindsey and Jessica Beess und Chrostin at Covington.
-
Small Biz Should Self-Advocate For Tax Relief Under Biden
Small and medium-sized businesses have significant potential for achieving regulatory relief from the U.S. Department of the Treasury and other federal agencies during the Biden administration, but to do so they must define their priorities, leverage two federal statutes that require the Treasury to protect them and make their voices heard through communal e-advocacy, says Monte Silver at Silver & Co.
-
Consider Mutual Agreement Procedures For Double Tax Relief
Taxpayers wary of using mutual agreement procedures for double taxation relief should revisit the process, which is more straightforward than many believe, lest they miss out on tax savings, says Monique van Herksen of Simmons & Simmons.
-
A Road Map For US Involvement In Europe's Cum-Ex Probe
The dividend arbitrage trading strategy known as cum-ex continues to face regulatory scrutiny in Europe, and stateside regulators may soon follow suit with the U.S. Securities and Exchange Commission’s recent American depositary receipt probe as a guide for enforcement, says Joshua Ray at Rahman Ravelli.
-
Congress Should Make TCJA Income Definition Permanent
Congress should not allow the Tax Cuts and Jobs Act's definition of adjusted taxable income, which includes depreciation and amortization, to expire in 2022 because it would discourage debt-free investment, running counter to the law's intent, says George Callas at Steptoe & Johnson.
-
OECD Delays Are Imperiling Digital Tax Deal
As the Organization for Economic Cooperation and Development continues to push back its deadline for a digital tax overhaul, countries are beginning to pursue unilateral solutions and the negotiations are turning political, decreasing the likelihood of an agreement, says Joyce Beebe at Rice University.
-
Mitigating IRS Cryptocurrency Enforcement Risk In 2021
The IRS seems poised to shift focus in 2021 from education to enforcement of virtual currency tax laws, and noncompliant taxpayers should consider whether they are eligible to file amended returns or voluntary disclosures to mitigate the risk of civil penalties, criminal investigation or prosecution, say Don Fort and Lawrence Sannicandro at Kostelanetz & Fink.
-
2020's Key Tax Controversy Developments
Andrew Roberson and Kevin Spencer at McDermott highlight 2020's key tax controversy developments, offering their perspective on important tax decisions, the Internal Revenue Service’s cooperative audit program, informal tax return amendment procedures, Large Business & International Division campaigns, and handling virtual appeals conferences during the pandemic.
-
Justices Likely To Shield Treasury From Preemptive Action
Recent U.S. Supreme Court oral arguments in CIC Services v. Internal Revenue Service suggest the court will resolve a circuit split by ruling the Anti-Injunction Act shields the U.S. Department of the Treasury from preemptive challenges — bad news for those hoping to challenge unfavorable regulations, says Monte Silver at Silver & Co.