International
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May 22, 2024
UK Dependency To Implement Pillar 2 Starting In 2025
The island of Jersey, a U.K. crown dependency, said it would implement the international minimum tax for large corporations known as Pillar Two, with the law taking effect next year.
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May 21, 2024
Nixing Green Energy Tax Perks Would Be Tough For Trump
Former President Donald Trump has vowed to scrap Democrats' signature 2022 climate law should he get reelected in November, but following through on that campaign promise could prove difficult amid bipartisan support for many of the law's clean energy tax incentives and a potentially divided Congress.
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May 21, 2024
Wyden Expands Pharma Tax Investigation With Pfizer Inquiry
Senate Finance Committee Chairman Ron Wyden asked Pfizer to provide details on its tax practices to explain how the drug company has consistently paid tax rates that are significantly lower than the corporate tax rate in a letter released by the committee Tuesday.
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May 21, 2024
CohnReznick Adds PwC Partner To International Tax Practice
CohnReznick has a new principal in its international tax practice who previously served as a partner at PwC, the firm announced.
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May 21, 2024
22 States Tell 11th Circ. Corp. Transparency Act Goes Too Far
The federal Corporate Transparency Act unconstitutionally displaces state authority and its enforcement would economically harm states and their residents, attorneys general from 22 states told the Eleventh Circuit, urging it to uphold a ruling that struck down the law.
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May 21, 2024
Yellen Says US Can't Support Global Tax On Billionaires
Treasury Secretary Janet Yellen said the U.S. can't support Brazil's proposal for the Group of 20 nations to endorse pursuing a multilateral agreement to tax billionaires' wealth at a minimum rate.
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May 21, 2024
Italy Needs To Adjust Tax Credits To Limit Debt, IMF Says
While generous Italian tax regimes such as credits for home improvements have helped the country's economy rebound quickly from the pandemic, they also pose a risk to the country's debt burden and need to be adjusted, the International Monetary Fund said.
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May 21, 2024
Strategic Hiring Was The New Normal For BigLaw In 2023
The 400 largest law firms by headcount in the U.S. grew more slowly in 2023 than in the previous two years, while Kirkland & Ellis LLP surpassed the 3,000-attorney threshold, according to the latest Law360 ranking.
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May 21, 2024
The Law360 400: Tracking The Largest US Law Firms
The legal market expanded more tentatively in 2023 than in previous years amid a slowdown in demand for legal services, especially in transactions, an area that has been sluggish but is expected to quicken in the near future.
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May 21, 2024
Portuguese Cos. Appeal EU Court Ruling On Tax Breaks
Three Portuguese companies have appealed a European Union court's judgment backing a European Commission decision that demanded repayment of tax breaks considered to have been illegal, documents published Tuesday showed.
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May 21, 2024
EU Adopts Decision To Send Russian Profits To Ukraine
European Union countries adopted a formal decision Tuesday to transfer the net income from frozen and immobilized Russian state assets to EU funds for rebuilding Ukraine and buying arms for the war-torn country, a news release said.
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May 21, 2024
I Am An Honest Man, British Trader Tells £1.4B Fraud Trial
Sanjay Shah, a former hedge fund owner who is accused of defrauding Denmark's tax authority out of £1.4 billion ($1.8 billion), told a London court on Tuesday that he is an "honest man" who traded using a legal "loophole."
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May 21, 2024
IMF Report Warns UK Against More Tax Cuts
The United Kingdom should refrain from additional tax cuts unless they are credibly shown to boost economic growth and are offset by measures to cut the deficit, the International Monetary Fund said Tuesday.
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May 20, 2024
Transparency Act Violates Constitution, Groups Tell 11th Circ.
The Corporate Transparency Act's reporting requirements violate the Fifth Amendment's protection against self-incrimination and other constitutional provisions, libertarian think tank Cato Institute and others said Monday in urging the Eleventh Circuit to uphold an Alabama district court's ruling against the law.
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May 20, 2024
India's Top Court Says Accounting Body Can Limit Tax Audits
India's regulatory association for accountants has the authority to limit the amount of tax audits performed by an individual accountant to 60, the Supreme Court of India ruled — even as it canceled ongoing disciplinary proceedings over the restriction because of inconsistent enforcement.
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May 20, 2024
IRS Guidance Plan Should Cover Corp. AMT, AICPA Says
The Internal Revenue Service should provide guidance on the definitions and applications of the 15% corporate alternative minimum tax, among other topics, the American Institute of Certified Public Accountants said in comments published by the agency Monday.
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May 20, 2024
Turkey Will Introduce 15% Global Minimum Tax, Minister Says
The Turkish government will introduce the 15% global minimum corporate tax and will not provide any incentives that would allow companies to pay a lower rate, the country's finance minister told its public broadcaster Monday.
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May 20, 2024
Isle Of Man Commits To Portion Of Global Minimum Tax
The Isle of Man plans to introduce legislation implementing the qualified domestic minimum top-up tax portion of the OECD's Pillar Two directive starting in 2025 but is less committed to adopting the income inclusion rule, the island's Treasury said Monday.
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May 20, 2024
HMRC Lays Out Registration Rules For Pillar 2
Companies covered by the U.K.'s implementation of the Organization for Economic Cooperation and Development's Pillar Two global minimum tax directive must register with HM Revenue & Customs within six months of the accounting period that makes them eligible, the agency said Monday.
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May 20, 2024
US, Argentina To Carry Out 1st FATCA Info Exchange
The Internal Revenue Service approved cybersecurity measures by Argentina in a step that clears the way for the first automatic information exchange under the Foreign Account Tax Compliance Act between the two countries in September, Argentina's revenue service said Monday.
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May 17, 2024
Med Device Co. Allowed $160M In Deductions, Tax Court Told
A tax code provision in place before the 2017 federal tax overhaul changed it allows a medical device manufacturer to claim more than $160 million in deductions for dividends despite the government's attempt to apply the law retroactively, company counsel told the U.S. Tax Court on Friday.
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May 17, 2024
Michigan Doctor Seeks Release From Contempt In FBAR Fight
A Michigan doctor incarcerated for civil contempt in a case in which he was ordered to repay more than $1 million in penalties for failure to report foreign accounts should be freed because he can no longer satisfy the terms of his release, he told a Michigan federal court.
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May 17, 2024
Koch-Tied Group Says Transparency Law Offends Federalism
The Corporate Transparency Act is unconstitutional because it does not regulate interstate commerce yet mandates that state-registered entities disclose personal information, a conservative group affiliated with the billionaire Koch brothers told the Eleventh Circuit on Friday.
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May 17, 2024
Credit Suisse Can't Reverse $21.3M Biz Loss Denial
Credit Suisse cannot carry forward $21.3 million in business losses from 2015-2017 to its 2018 Michigan tax return, a state appeals court said, letting stand a ruling that the bank miscalculated its business income from those years on its returns.
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May 17, 2024
New Domestic Content Guidance May Boost Energy Credits
The U.S. Treasury Department's new guidance on bonus tax credits for clean energy projects that source domestic-made materials and components aims to simplify the process for determining eligibility and spur more development to get those extra incentives.
Expert Analysis
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Long Road Ahead For Biden's Individual Tax Hike Proposal
Dustin Stamper at Grant Thornton provides insight into President Joe Biden's recently proposed individual tax increases to pay for his American Families Plan, and explains how competing interests among congressional Democrats and Republicans may shape the final provisions and prolong their implementation.
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What Value-Added Tax Might Look Like In The US
Christiaan Van Der Valk and Charles Maniace at Sovos consider the value-added tax, a primary source of revenue for many countries, and what it might mean for the U.S. were it implemented to raise funds for large-scale federal initiatives such as President Joe Biden's infrastructure plan.
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US Needs Better, Nonpunitive Approach To Greening Trade
Instead of imposing tariffs on goods produced where foreign governments have assisted in cleaning up the environment, the U.S. should make trade policy green by helping industries reduce their environmental impact and encouraging every foreign government to do the same, say Elliot Feldman and Michael Snarr at BakerHostetler.
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What OECD Scrutiny Means For Anti-Corruption In Brazil
Attorneys at Paul Hastings examine how an unprecedented standing subgroup recently created by the Organization for Economic Cooperation and Development to monitor Brazil's anti-corruption efforts reflects significant uncertainty regarding the country's commitment to enforcement, and what companies can do to address foreign bribery risk and strengthen compliance programs.
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The International Outlook For US Border Carbon Adjustments
The Biden administration may see enacting a border carbon adjustment system as a good way to advance climate goals and protect domestic industries and jobs, but any such plan must take into account the need to respect existing international trade agreements, say attorneys at Akin Gump.
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The Domestic Landscape For US Border Carbon Adjustments
With the Biden administration possibly eyeing border carbon adjustments on imported goods as a means to mitigate climate change, attorneys at Akin Gump discuss such policies' potential benefits to domestic businesses, and the political and technical challenges to their enactment in the U.S.
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Prepare For Global Collaboration In Crypto Tax Enforcement
Recent Internal Revenue Service victories involving John Doe summonses served on cryptocurrency exchanges — and statements by the Joint Chiefs of Global Tax Enforcement about global collaboration in cryptocurrency-related tax investigations — should prompt assessment of prior virtual currency transactions and remediation before an enforcement agency shows up at the door, say attorneys at McDermott.
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10 Things to Know About US Competent Authority Assistance
Taxpayers should consider seeking U.S. competent authority assistance to help eliminate double taxation from a transfer pricing adjustment, especially now that the competent authorities are resolving cases virtually and more quickly, say attorneys at Thompson & Knight.
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US Advance Pricing Agreements, Amid COVID And Before
Steptoe & Johnson's Matthew Frank, former director of the U.S. Advance Pricing Agreement Program, shares insights from an Internal Revenue Service report revealing an uptick in APA completions amid the pandemic, discusses trends over the program's 30-year history, and suggests ways taxpayers and the IRS could bolster program participation.
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Choosing A Branch Or Subsidiary For Overseas Expansion
Samuel Pollack and Naoko Watanabe at Baker McKenzie examine the corporate and U.S. tax law considerations involved in deciding whether a branch or subsidiary is the most efficient way to expand operations overseas, now that recent Treasury regulations clarified the complicated international tax regime created by the Tax Cuts and Jobs Act.
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Key Tax Concerns For Foreign Investors In US Private Equity
Paul D'Alessandro at Bilzin Sumberg examines important tax questions foreigners interested in U.S. private equity investments should ask in advance, including whether the investment will produce active or passive income, be subject to gains tax, and have U.S. estate tax consequences.
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Surveying Global Tax Updates For Sovereign Wealth Investors
As the market transitions to a post-pandemic phase, sovereign wealth fund and other foreign institutional investors must evaluate how recent U.S., EU and U.K. tax changes may affect their private fund investments, say attorneys at Morgan Lewis.
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Coke, 3M Tax Cases May Not Settle Blocked Income Debate
Even if the challenged U.S. Department of the Treasury regulation on blocked income is struck down by the U.S. Tax Court in the pending Coca-Cola and 3M cases, the obligations of a taxpayer that had, but failed to avail itself of, alternative means to secure payment will remain an open question, say Matthew Frank and Amanda Varma at Steptoe & Johnson.