International

  • May 03, 2024

    HMRC Director Rejoins KPMG To Boost Tax Dispute Offering

    A former deputy director at HM Revenue & Customs has returned to KPMG as director of KPMG Law's tax disputes teams, the firm has announced.

  • May 03, 2024

    Africa Seeks Early UN Reform On Transfer Pricing, Exchanges

    Legally binding protocols that reform transfer pricing and exchange of information to the benefit of all countries where multinational corporations operate should be developed simultaneously with the U.N. framework convention on global tax, the U.N.'s African bloc, India and others said Friday.

  • May 03, 2024

    Estonia Implements 2 EU Tax Laws After Delays

    Estonia officially enacted two European Union-wide tax measures that it was late putting into national law, both relating to the OECD's standards for global minimum taxation of large companies.

  • May 03, 2024

    Aussie Treasury Seeks Input On Powers After PwC Scandal

    With investigations into PwC Australia's leak of classified tax plan documents ongoing, the Australian government is asking the public whether it thinks its regulatory powers over tax and accounting firms are sufficient, its Treasury announced Friday.

  • May 03, 2024

    New Fiscal Rules Force EU Countries To Limit Deficits

    New European Union fiscal rules that recently kicked in will force EU countries to restrict public budget deficits by better balancing tax revenues with government spending, the European Commission said Thursday.

  • May 03, 2024

    US Trade Position Seen Contradicting Stance In Pillar 1 Talks

    The U.S. trade representative's withdrawal of support for digital trade proposals has caused tax policy observers to worry that the U.S. position on trade is undermining that of U.S. Treasury Department officials negotiating a taxing rights overhaul at the OECD known as Pillar One.

  • May 03, 2024

    Finland's Stance On Swiss Treaty Recalls Ended Portugal Deal

    Finland's plan to renegotiate its tax treaty with Switzerland in response to concerns about pension tax avoidance has some observers worried that the country will cancel that accord as it did a treaty with Portugal in recent years.

  • May 03, 2024

    Taxation With Representation: Skadden, Wachtell, Davis Polk

    In this week's Taxation With Representation, L'Occitane International said its executive director and chair is leading an offer to buy the company's shares he doesn't already own, UMB Financial agreed to purchase Heartland Financial USA, Medline said it agreed to acquire Ecolab's global surgical solutions business and The Mosaic Co. said it agreed to sell its stake in a phosphate production joint venture.

  • May 03, 2024

    IRS Can Assess Foreign Info Disclosure Penalty, DC Circ. Says

    The D.C. Circuit on Friday overturned a major U.S. Tax Court ruling that had struck down the Internal Revenue Service's authority to assess and administratively collect penalties from taxpayers for failing to file an information return on their interests in a foreign corporation.

  • May 03, 2024

    Final EV Tax Credit Regs Add New Battery Tracing Test

    The U.S. Treasury Department unveiled final regulations Friday for the up to $7,500 electric vehicle tax credit that include a more detailed process for automakers to trace the battery supply chain to qualify for the credit's domestic content requirements.

  • May 03, 2024

    German's Austrian Ski Holiday Ends With Arrest In VAT Probe

    A German citizen on a skiing holiday in Austria was arrested over a large-scale value-added tax fraud scheme, the Finance Ministry in Vienna said in a statement on Friday.

  • May 02, 2024

    Claimed Panama Papers Leaker Fights To Hide ID In €5M Suit

    A person claiming to be the Panama Papers leaker told a federal court they would fear for their life if the court made them disclose their identity in a €5 million ($6.3 million) suit against Germany, protesting a magistrate judge's suggestion that the suit be tossed because the person wouldn't identify themselves.

  • May 02, 2024

    IRS To Boost Audit Rates By 50% On Wealthy, Werfel Says

    The Internal Revenue Service plans to nearly triple audit rates on corporations with assets over $250 million and increase audit rates by more than 50% on wealthy taxpayers with more than $10 million in total positive income by 2026, Commissioner Daniel Werfel said Thursday.

  • May 02, 2024

    Latest Stock Buyback Tax Rules May Still Have Wide Reach

    The U.S. Treasury Department recently floated regulations that narrow an earlier proposal aimed at preventing foreign-parented corporations from circumventing a new excise tax on stock buybacks, but the regulations still characterize avoidance in ways that could include routine intercompany transactions.

  • May 02, 2024

    HMRC Asked To Investigate Firm On Dodging Sanctions

    HM Revenue & Customs should investigate a German-owned garage door manufacturer for violating sanctions by importing products from Belarus into the U.K., but instead authorities brushed off the case and now the company might receive a license, a U.K. lawmaker said.

  • May 02, 2024

    Canada Budget Seeks To Establish Corp. Min. Tax Standards

    Budget proposals submitted to Canada's Parliament by the finance minister would implement the Organization for Economic Cooperation and Development's global corporate minimum tax standards as part of the country's overarching budget plans.

  • May 02, 2024

    OECD-Asia Group Helping Reform Agenda, OECD Head Says

    A group that brings together countries from the mostly Western Organization for Economic Cooperation and Development and Southeast Asia to discuss issues, including tax, is helping countries make changes, the head of the OECD said Thursday.

  • May 02, 2024

    Airlines Slam Increase In German Air Passenger Tax

    The increase in Germany's air passenger tax on May 1 will weaken the country's economy and damage the aviation industry's ability to cut down on its carbon use, an airline group said on Thursday.

  • May 01, 2024

    No Relief For Fla. Adviser Convicted In $80M Trading Scam

    The Eleventh Circuit on Wednesday affirmed the conviction of a Florida investment adviser who bilked more than $80 million from the hundreds of people he persuaded to invest in a fraudulent company, after concluding he was not in custody when he made statements to the police.

  • May 01, 2024

    Middle East, North African Gov'ts Back UN For Corp. Tax Talks

    Governments should make a high-level commitment to address corporate tax reform within the United Nations' framework convention on international tax cooperation, an intergovernmental group of Middle Eastern and North African countries said Wednesday.

  • May 01, 2024

    Think Tank Says 'Distortive' DSTs Not The Right Way Forward

    As jurisdictions around the world continue to struggle with how to adequately tax the increasingly digital economy, they should look to expand their consumption taxes, not enact digital services taxes, the Tax Foundation said.

  • May 01, 2024

    Liberty Global Defends $109M Tax Refund Bid In 10th Circ.

    Telecommunications giant Liberty Global urged the Tenth Circuit to revive the company's $109 million tax refund bid, arguing a lower court rejected the claim by wrongly disregarding intercompany transactions that are permitted under legislation involving the repatriation of foreign profits.

  • May 01, 2024

    UN Must Improve Corp. Tax Rules, Platforms, Some Gov'ts Say

    Governments must commit to improving existing corporate tax rules and platforms created at the OECD within the terms of reference for a United Nations framework convention on global tax cooperation, two tax officials who participated in drafting those rules said Wednesday.

  • May 01, 2024

    HMRC Simplifies Late Filing Penalties For Digital Filers

    U.K. taxpayers voluntarily filing their personal income tax returns using a program intended to modernize the country's tax system will receive more leniency and access to a simpler penalty structure in cases of late filing, HM Revenue & Customs said.

  • May 01, 2024

    Hong Kong Proposes Amended Automatic Info Exchange List

    Hong Kong is considering adjusting the list of countries it automatically exchanges financial information with by subtracting nine jurisdictions and adding 11, which the country's tax authority said is in line with recommendations from the Organization for Economic Cooperation and Development.

Expert Analysis

  • EU Climate Plan Should Involve Taxing Pollution, Not Borders

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    In order to crack down on greenhouse gas emissions, the European Union proposes to levy carbon emissions at its borders and to overhaul its long-standing energy tax framework, but the latter would hold polluters directly accountable, giving it the better chance for success, says Rebecca Christie at Bruegel.

  • Prepare For Global Tax Regime's New Biz Dispute Risks

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    Companies should take steps to mitigate the business dispute risks of the new international tax framework, which over a hundred countries agreed to in July, as implementing the new regime will be expensive and require substantial organizational restructuring efforts, says Tim McCarthy at Dykema.

  • Prepare For More Audits Of Tax Info And Withholding Filings

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    Financial institutions and other corporate taxpayers should focus compliance efforts on tax information reporting and withholding, given recent indications from the Biden administration that the IRS will increase enforcement, and the administration's need to fund its infrastructure plan and other costly initiatives, say attorneys at Mayer Brown.

  • Anti-Boycott Compliance Still Key In UAE Business Dealings

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    Notwithstanding recent amendments to U.S. anti-boycott laws that reflect the United Arab Emirates' withdrawal from the Arab boycott of Israel, companies doing business in the UAE and elsewhere still need to maintain effective anti-boycott compliance programs to avoid reporting violations or penalties, says Howard Weissman at Miller Canfield.

  • 9th Circ. Adds Pressure To Reject Substance Over Form

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    The Ninth Circuit’s recent decision rejecting taxes on a family's Roth IRA payments that were made through a foreign sales corporation represents a refreshing trend among federal appeals courts to reject substance-over-form principles and instead look to congressional intent, say Lawrence Hill and Caitlin Tharp at Steptoe & Johnson.

  • Will The OECD Plan Fix International Taxation?

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    Lilian Faulhaber at Georgetown Law breaks down the Organization for Economic Cooperation and Development’s plan for international tax reform, recently joined by 130 countries, and whether it will solve the problems it was designed to address, including the need for multinational companies to pay their fair share of taxes in the digitized world economy.

  • What Biden's Tax Proposals May Mean For Int'l Private Clients

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    Jennifer Wioncek and Paul D’Alessandro at Bilzin Sumberg discuss the U.S. Department of the Treasury's recently released explanation of the Biden administration's tax proposals and how the changes would affect income and wealth transfer planning for international private clients.

  • What Crypto Holders Can Learn From Early-2000s Tax Scandal

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    The Internal Revenue Service’s recent push to gather information about cryptocurrency accounts is similar to its Swiss bank account investigations of the early 2000s, which should prompt taxpayers to consider voluntarily disclosing transactions before they are individually targeted for enforcement, say Timothy Wagner and Thomas Barnard at Baker Donelson.

  • International Tax Reform's Implications For Transfer Pricing

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    As the Organization for Economic Cooperation and Development overhauls the global tax rules on base erosion and profit shifting, and the Biden administration rolls out new U.S. tax proposals, multinational enterprises need to prepare for the effects of these tax changes on their transfer pricing structures, say Mandy Li and Shuang Feng at MGO.

  • Justices' Preemptive Tax Challenge Ruling Shows Divisions

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    The U.S. Supreme Court's recent decision in CIC Services v. Internal Revenue Service reveals divisions among the justices about when potentially burdensome tax regulations can be challenged, making the holding less clear and less valuable, say George Isaacson and David Swetnam-Burland at Brann & Isaacson.

  • Takeaways From 2 New FBAR Rulings

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    In light of two recent California federal court decisions, capping penalties for nonwillful violations of foreign bank account reporting but broadening the willfulness standard, U.S. taxpayers must be vigilant about understanding their reporting obligations, and prepare for the Internal Revenue Service to target willful conduct, which yields much higher penalties, say Friedemann Thomma and Marianna Felshtiner at Venable.

  • El Salvador's Use Of Bitcoin Complicates US Commercial Law

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    El Salvador recently became the first country to recognize Bitcoin as currency, presenting significant implications for U.S. commercial law as the development will likely trigger the cryptocurrency to now fall within the definition of "money" under the Uniform Commercial Code, say Joe Carlasare and Eric Fogel at SmithAmundsen.

  • Justices' Nod To Preemptive Tax Challenges May Caution IRS

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    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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