International

  • December 13, 2024

    CFC Tax Issues Can't Be Solved Via Treaties, Officials Say

    Bilateral treaties between the U.S. and other countries where a controlled foreign corporation may face withholding tax issues aren't able to effectively resolve those disputes, Internal Revenue Service and Treasury officials said Friday.

  • December 13, 2024

    IRS Mulls Turning Off Foreign Currency Rules For CFCs

    The Internal Revenue Service is in the early stages of considering whether foreign currency gain or loss recognition rules could be turned off in certain situations for controlled foreign corporations, an agency official said Friday.

  • December 13, 2024

    Halliburton Consistent On Claims For $35M Refund, Court Told

    Halliburton has not changed its reasons for claiming a tax refund on a $35 million payment it made to a foreign government to protect its employees from harassment, the company told a Texas federal court, saying the U.S. wrongly accused it of a flip-flop.

  • December 13, 2024

    Taxation With Representation: Kirkland, Davis Polk, Wachtell

    In this week's Taxation With Representation, Google and TPG Rise Climate partner with Intersect Power, Gen Digital Inc. acquires MoneyLion Inc., Patient Square Capital acquires Patterson Companies Inc., and the Buffalo Bills and Miami Dolphins sell minority ownership shares to private equity firms.

  • December 13, 2024

    Canada 2-Month Sales Tax Holiday Begins Saturday

    A two-month goods-and-services tax holiday in Canada on certain goods such as gifts and restaurant meals will begin Saturday after having passed the Senate and receiving royal ascension.

  • December 13, 2024

    Contractor Loses Bail For Texting Alleged Tax Cheat Allies

    A District of Columbia federal judge revoked bail for a former defense contractor accused of running a $350 million tax-evasion scheme that prosecutors call one of the largest in U.S. history, after the government said he'd been texting his alleged co-conspirators.

  • December 13, 2024

    Loper Bright May Influence Tax Less, IRS Chief Counsel Says

    The U.S. Supreme Court decision this year overturning a decades-long standard to defer to federal agencies' regulatory interpretations has encouraged the Internal Revenue Service to better explain its rules, its outgoing chief counsel said Friday.

  • December 12, 2024

    IRS Wants Choice Retained In Dual Loss Rules, Official Says

    The Internal Revenue Service is working to preserve flexibility for taxpayers in rules aimed at preventing companies from using the same economic loss twice after concerns were raised about how the rules could negatively interact with the Pillar Two global minimum tax, an official said Thursday.

  • December 12, 2024

    IRS Seeks Feedback On Limits In Previous Taxed Profit Rules

    The Internal Revenue Service will consider whether rules included in recently proposed guidance on previously taxed earnings and profits to limit instances where U.S. multinationals may use basis to offset gain are too restrictive, an official said Thursday.

  • December 12, 2024

    CJEU Upholds €1.8M Tax On Volvo Group In Belgium

    Belgium can impose a "fairness tax" totaling €1.8 million ($1.9 million) on nonresident companies without a permanent office in the country, the Court of Justice of the European Union said Thursday.  

  • December 12, 2024

    2nd Circ. Won't Rethink Dual Citizen's FBAR Penalties

    The Second Circuit will not review its September decision finding that a dual U.S.-French citizen is liable for tax penalties for failing to file reports of foreign bank and financial accounts, the court said Thursday.

  • December 12, 2024

    Swiss To End Credit Offsetting India's Tax Treaty Snub

    The Swiss government will no longer offer a credit to taxpayers designed to offset India's rejection of Swiss claims to benefits offered in other Indian tax treaties because India's top court decided to uphold its government's position, according to a notice.

  • December 12, 2024

    German Fund Managers Charged In €45M Cum-Ex Scheme

    Two fund managers have been charged in Germany for "particularly serious" tax evasion over their alleged role in a €45 million ($47 million) cum-ex dividend tax fraud, prosecutors confirmed Thursday.

  • December 12, 2024

    IRS Hopes To Issue Amount B Pricing Guidance Within Weeks

    Treasury is working to finish its guidance on the simplified transfer pricing approach to baseline marketing and distribution known as Amount B by the end of the year, a U.S. official said Thursday.

  • December 12, 2024

    Treasury Seeks To Pause Anti-Laundering Law Injunction

    The U.S. Treasury Department asked a Texas federal judge to pause his nationwide preliminary injunction of the Corporate Transparency Act pending an appeal of his recent decision that found Congress likely overstepped its constitutional authority when it wrote the anti-money laundering law.

  • December 12, 2024

    Less Than Half Of Latin America Sees Taxes As Contributions

    Only 47% of surveyed Latin American taxpayers consider their taxes as a contribution to the overall good of society as opposed to a cost they are forced to pay, the Organization for Economic Cooperation and Development said Thursday, saying the figure was below the global average.

  • December 12, 2024

    Gibraltar Considering Global Minimum Tax Bill

    Gibraltar's Parliament is considering the implementation of two parts of the Organization for Economic Cooperation and Development's 15% global corporate minimum income tax on large multinational entities making over €750 million ($786 million) annually.

  • December 12, 2024

    Mexico To Join Int'l Pricing Program In 2025, Official Says

    Mexico plans in 2025 to join the International Compliance Assurance Program, a multilateral effort to resolve transfer pricing issues, an official from that country's tax authority said Thursday.

  • December 12, 2024

    Trader Sentenced To 12 Years For Cum-Ex Fraud In Denmark

    A Danish court sentenced a British hedge fund trader to 12 years in prison on Thursday after finding him guilty of defrauding the country's tax authority by masterminding a nine billion kroner ($1.3 billion) cum-ex fraud scheme.

  • December 11, 2024

    More Facts Needed In RJ Reynolds Tax Row, Mich. Court Says

    More facts are needed on whether part of a $4.9 billion sale of trademarks by R.J. Reynolds to a Japanese company should be taxable in Michigan, a state court said Wednesday, declining to rule immediately.

  • December 11, 2024

    Exxon Tax Ruling Doesn't Help Liberty Global, 10th Circ. Told

    Liberty Global cannot use a recent ruling that allowed Exxon Mobil a tax deduction for interest payments to claim a deduction for dividends that arose from its intragroup shuffling of a Belgian affiliate, the U.S. government told the Tenth Circuit on Wednesday.

  • December 11, 2024

    Irish Ruling Cuts Shareholder's Capital Gains Tax By €2.2M

    A shareholder who gave all his shares in a company to several entities will save €2.2 million ($2.3 million), as Ireland's Tax Appeals Commission said Wednesday that the disposal happened in multiple transactions, qualifying for a discounted capital gains tax rate.

  • December 11, 2024

    Estonia Passes 2% Tax To Fund Russia-Ukraine War Spending

    Estonia's Parliament passed a temporary 2% tax Wednesday, earmarked to cover increased defense spending for the Russia-Ukraine war, choosing to go a different route to raise funds than neighboring Lithuania and Latvia.

  • December 11, 2024

    Adidas Says European Offices Raided In EU Tax Investigation

    Authorities are searching Adidas AG's offices in Germany and Austria for evidence of tax evasion following a five-year investigation by customs authorities in the European Union, the company told Law360 on Wednesday.

  • December 11, 2024

    Netherlands Gov't Reports $5.3B Drop In Tax Avoidance

    The Dutch government said Wednesday that it has seen tax avoidance drop by €5 billion ($5.3 billion) since the imposition of two European Union directives targeting low-tax corporate structures and practices.

Expert Analysis

  • 5 Litigation Funding Trends To Note In 2024

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    Over the next year and beyond, litigation funding will continue to evolve in ways that affect attorneys and the larger litigation landscape, from the growth of a secondary market for funded claims, to rising interest rates restricting the availability of capital, says Jeffery Lula at GLS Capital.

  • 4 Legal Ethics Considerations For The New Year

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    As attorneys and clients reset for a new year, now is a good time to take a step back and review some core ethical issues that attorneys should keep front of mind in 2024, including approaching generative artificial intelligence with caution and care, and avoiding pitfalls in outside counsel guidelines, say attorneys at HWG.

  • What The Law Firm Of The Future Will Look Like

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    As the legal landscape shifts, it’s become increasingly clear that the BigLaw business model must adapt in four key ways to remain viable, from fostering workplace flexibility to embracing technology, say Kevin Henderson and Eric Pacifici at SMB Law Group.

  • 4 PR Pointers When Your Case Is In The News

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    Media coverage of new lawsuits exploded last year, demonstrating why defense attorneys should devise a public relations plan that complements their legal strategy, incorporating several objectives to balance ethical obligations and advocacy, say Nathan Burchfiel at Pinkston and Ryan June at Castañeda + Heidelman.

  • Unpacking The Proposed Production Tax Credit Regulations

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    Recently proposed tax regulations for claiming the U.S. clean-energy manufacturers' production credit under Internal Revenue Code Section 45X are less stringent than many had feared but fail to define a fundamental eligibility requirement, say Casey August and Jared Sanders at Morgan Lewis.

  • 10 Considerations For Litigating A New York Tax Case

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    While some of New York’s recently adopted corporate tax regulations are likely to face legal challenges, aggrieved taxpayers should answer certain questions before deciding to embark on the tax litigation process, say Cyavash Ahmadi and Jeffrey Friedman at Eversheds Sutherland.

  • Law Firm Strategies For Successfully Navigating 2024 Trends

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    Though law firms face the dual challenge of external and internal pressures as they enter 2024, firms willing to pivot will be able to stand out by adapting to stakeholder needs and reimagining their infrastructure, says Shireen Hilal at Maior Consultants.

  • Attorneys' Busiest Times Can Be Business Opportunities

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    Attorneys who resolve to grow their revenue and client base in 2024 should be careful not to abandon their goals when they get too busy with client work, because these periods of zero bandwidth can actually be a catalyst for future growth, says Amy Drysdale at Alchemy Consulting.

  • How Attorneys Can Be More Efficient This Holiday Season

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    Attorneys should consider a few key tips to speed up their work during the holidays so they can join the festivities — from streamlining the document review process to creating similar folder structures, says Bennett Rawicki at Hilgers Graben.

  • How Clients May Use AI To Monitor Attorneys

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    Artificial intelligence tools will increasingly enable clients to monitor and evaluate their counsel’s activities, so attorneys must clearly define the terms of engagement and likewise take advantage of the efficiencies offered by AI, says Ronald Levine at Herrick Feinstein.

  • The Pop Culture Docket: Judge D'Emic On Moby Grape

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    The 1968 Moby Grape song "Murder in My Heart for the Judge" tells the tale of a fictional defendant treated with scorn by the judge, illustrating how much the legal system has evolved in the past 50 years, largely due to problem-solving courts and the principles of procedural justice, says Kings County Supreme Court Administrative Judge Matthew D'Emic.

  • Breaking Down High Court's New Code Of Conduct

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    The U.S. Supreme Court recently adopted its first-ever code of conduct, and counsel will need to work closely with clients in navigating its provisions, from gift-giving to recusal bids, say Phillip Gordon and Mateo Forero at Holtzman Vogel.

  • Legal Profession Gender Parity Requires Equal Parental Leave

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    To truly foster equity in the legal profession and to promote attorney retention, workplaces need to better support all parents, regardless of gender — starting by offering equal and robust parental leave to both birthing and non-birthing parents, says Ali Spindler at Irwin Fritchie.

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