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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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.
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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.