International

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • May 17, 2024

    Italian Financial Police Uncover €1B Tax Credit Scam

    The Italian Financial Police placed more than 300 people under investigation after uncovering a scheme to collect more than €1 billion ($1.09 billion) in tax credits designed to promote construction and energy matters, authorities said.

  • May 17, 2024

    Transfer Pricing Deal Needed For Pillar 1, OECD Official Says

    It's crucial for countries to agree on transfer pricing policies under an international profit reallocation agreement known as Pillar One as they work toward their end-of-June deadline to sign a related multilateral treaty, an OECD official said Friday.

  • May 17, 2024

    New Dutch Gov't Outlines Range Of Tax Measures

    The incoming Dutch government has outlined numerous tax measures affecting companies and individuals in its preliminary coalition agreement, a government document showed.

  • May 17, 2024

    UK, Peru Agree To Double-Tax Treaty

    The U.K. and Peru reached a deal on a treaty to prevent double taxation after several years of discussion, the countries said Friday.

  • May 17, 2024

    Taxation With Representation: Wachtell Lipton, Freshfields

    In this week's Taxation with Representation, Nippon Life acquires Corebridge Financial, Crescent Energy buys SilverBow Resources and Uber purchases Foodpanda.

  • May 16, 2024

    Pillar 1 Faces Hard June Deadline, Ex-Treasury Official Says

    An international agreement to reallocate certain corporate profits, known as Pillar One, will likely stall if countries miss their deadline to sign a multilateral treaty by the end of June, a former U.S. Treasury official said Thursday.

  • May 16, 2024

    Australian Lawmakers OK Tougher Corporate Promoter Rules

    Australian lawmakers agreed Thursday to raise maximum penalties on corporations that promote tax avoidance schemes and to introduce a cap on deductions under its petroleum resource rent tax despite concerns from some members, according to documents published by Parliament.

  • May 16, 2024

    P&G Exec Says FDII Uncertainty May Sway Cos.' IP Decisions

    The 2017 tax overhaul's measure for foreign-derived intangible income, a regime that gives tax breaks for domestically held intellectual property, faces uncertainty that could be one factor in keeping some companies from repatriating IP, a tax executive for Procter & Gamble said Thursday.

  • May 16, 2024

    Eaton Must Give Up Personnel Docs In Transfer Pricing Probe

    Eaton must comply with an Internal Revenue Service summons for the personnel records of its foreign employees in the government's transfer pricing investigation of the multinational power management company, an Ohio federal judge ruled Thursday.

  • May 16, 2024

    African Tax Admins Promote Use Of Voluntary Disclosures

    Voluntary disclosure programs have been very effective when countries launch them in anticipation of complying with an international standard on automatic exchanges of financial account information, the African Tax Administration Forum said Thursday in guidance on the programs.

  • May 16, 2024

    Kenya Considering Global Minimum Tax, DST Replacement

    Kenya is considering legislation that would implement the Organization for Economic Cooperation and Development's corporate global minimum tax as well as repeal and replace the country's digital services tax.

  • May 16, 2024

    Germany's 2024 Tax Revenue Estimate Drops By €14B

    Germany's 2024 tax revenue estimate decreased by roughly €14 billion ($15.2 billion) to €950.3 billion from the estimate made last fall, which its finance ministry said Thursday was due to slower-than-expected economic recovery.

  • May 16, 2024

    Suspected Ringleader Of €2M Cosmetics VAT Fraud Arrested

    The suspected ringleader of a value-added tax fraud scheme at a cosmetics company that caused more than €2 million ($2.2 million) in estimated losses has been arrested by Italian police, the European Public Prosecutor's Office said Thursday.

  • May 16, 2024

    EU Tax On Excess Corp Profits Could Yield €107B, Study Says

    A European Union tax on excessive corporate profits could yield about €107 billion ($116 billion) to partly finance the common EU budget or other urgent investments, leftists in the European Parliament said Thursday.

  • May 16, 2024

    Treasury Provides Extra Relief For Bonus Energy Tax Credits

    The U.S. Treasury Department provided additional safe harbors Thursday that clean energy project developers can use to qualify for bonus tax credits for domestically sourcing their steel and aluminum parts in response to the Biden administration's new trade restrictions on solar products from China.

  • May 16, 2024

    Lithuania PM Wants Frozen Russian Assets To Help Ukraine

    Lithuania's prime minister said Thursday that Russia's frozen assets should be used to help Ukraine fight off aggression from its larger neighbor, saying that a recent European decision to use profits from frozen assets should be only a first step.

  • May 15, 2024

    Russian Gas Ex-CFO Can't Nix $44M FBAR Suit, Judge Rules

    The former chief financial officer of a Russian gas company who was sentenced to seven years in prison for hiding money in Swiss banks can't escape the government's civil suit seeking nearly $44 million in reporting penalties, a Florida federal judge ruled Wednesday.

  • May 15, 2024

    EU Court Upholds Ruling Against Spanish Ship Tax Scheme

    The European Union's General Court upheld Wednesday a European Commission ruling that a Spanish tax scheme for ships constructed in the nation's domestic shipyards was incompatible with the EU's internal market.

  • May 15, 2024

    Schulte Roth Adds Ex-Kleinberg Kaplan Partner To Tax Group

    Schulte Roth & Zabel LLP added a former Kleinberg Kaplan Wolff & Cohen PC partner with a focus on private investment funds to its tax group in New York.

  • May 15, 2024

    3 Key Takeaways From Floated Foreign Trust Reporting Rules

    Proposed rules for reporting transactions with foreign trusts recently issued by the U.S. Treasury Department provide breathing room on disclosure requirements for certain offshore retirement accounts, but leave open some questions about classification. Here, Law360 breaks down three sections of the proposed foreign trust reporting regulations.

Expert Analysis

  • Curtailing Offshore Tax-Advantaged Investment In China

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    The U.S. government's plans to establish a new outbound investment regime hold the potential to arrest Chinese companies' increasing use of offshore, tax-advantaged locations to raise capital, says David Plotinsky at Morgan Lewis.

  • Cos. May Want To Wait Out US-EU Green Incentives Fight

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    As the European Union considers measures to compete with the Inflation Reduction Act's incentives for U.S. production of clean tech, and EU and U.S. officials discuss a possible compromise, companies in the green sector should consider taking a wait-and-see approach to investment decisions, says Todd Thacker at Goldberg Segalla.

  • India's Budget Proposals May Ease Entry For Certain Sectors

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    India’s recently released budget includes proposals to facilitate doing business in Gujarat International Finance Tec-City and moderate thousands of compliance requirements, opening up new opportunities for foreign businesses in the digital infrastructure, manufacturing and renewable energy sectors, say Mukesh Butani and Seema Kejriwal at BMR Legal.

  • High Court Ax Of Atty-Client Privilege Case Deepens Split

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    The U.S. Supreme Court's recent dismissal of In re: Grand Jury as improvidently granted maintains a three-way circuit split on the application of attorney-client privilege to multipurpose communications, although the justices have at least shown a desire to address it, say Trey Bourn and Thomas DiStanislao at Butler Snow.

  • US-India Advance Pricing Resolutions Should Reassure Cos.

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    The United States' and India's tax authorities' recent resolution of a significant number of pending advance pricing agreements should reduce taxpayer uncertainty, reassure companies of the nations' good working relationship and improve India's investment environment, say Miller Williams and Caroline Setliffe at Eversheds Sutherland.

  • Stock Buyback Excise Tax Guidance A Mixed Bag For SPACs

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    Recent IRS guidance on the new stock repurchase excise tax includes a welcome exception for publicly traded special-purpose acquisition companies but does not exclude redemptions in connection with a de-SPAC transaction, and further guidance is needed to clarify ambiguities around the exception's application, say Olga Bogush and Evgeny Magidenko at ArentFox Schiff.

  • The IRS' APA Rulemaking Journey: There And Back Again

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    Attorneys at Dentons examine recent challenges in which taxpayers successfully argued Internal Revenue Service rulemaking was invalid under the Administrative Procedure Act, how tax exceptionalism and U.S. Supreme Court regulatory deference prompted such challenges, and similar challenges the agency will likely face following this line of cases.

  • ECJ Fiat Ruling Sets Clear Boundaries For EU State Aid Law

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    The European Court of Justice's recent landmark decision in Fiat v. Commission limiting the commission’s attempts to circumvent the lack of EU powers in the area of tax law has important implications in EU state aid law and beyond, say Andreas Reindl and Pietro Stella at Van Bael.

  • Unpacking The Interim Guidance On New Stock Buyback Tax

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    The U.S. Department of the Treasury and Internal Revenue Service's recent notice on applying the newly effective excise tax on stock repurchases provides much-needed clarity on the tax's scope, which is much broader than anticipated given its underlying policy rationale, say attorneys at Eversheds Sutherland.

  • IRS Will Use New Resources To Increase Scrutiny In 2023

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    The new year promises to be a busy one for the Internal Revenue Service, which is poised to apply the boost in funding provided by the Inflation Reduction Act to bolster and expand its enforcement capability, and there are four areas to watch, say attorneys at Skadden.

  • 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.

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