International

  • April 09, 2024

    France, Luxembourg Extend Old Tax System To 2023 Income

    French residents working in Luxembourg don't yet have to account for a new system for avoiding double taxation included in an updated treaty between the two countries, but there will a final extension for the previous system, the French finance ministry said Tuesday.

  • April 09, 2024

    Greece Adopts Global Minimum Tax Directive After Pressure

    Greece has officially implemented the global corporate minimum tax spearheaded by the Organization for Economic Cooperation and Development, after being reprimanded this year by the European Commission.

  • April 09, 2024

    EU Lawmakers OK Revised Deal On Imports From Ukraine

    European Union lawmakers agreed on a revised deal to extend the suspension of the bloc's customs duties and quotas on Ukrainian imports until June 2025 after some EU countries had rejected a previous deal.

  • April 09, 2024

    Adviser Group Wants Limitations Added To EU Disclosure Law

    A group that represents tax advisers in Europe said Tuesday that it wants the European Union's executive branch to add limitations to a major disclosure law designed to combat cross-border tax evasion, saying the law puts too high a burden on them.

  • April 09, 2024

    Labour Party Pledges £5.1B Tax Crackdown If Elected

    Britain's opposition Labour Party pledged Tuesday to raise £5.1 billion ($6.5 billion) by closing tax loopholes and cracking down on tax avoidance schemes if it wins the next election, expected later this year.

  • April 08, 2024

    Tax Court Upholds $11M In Foreign Reporting Penalties

    The U.S. Tax Court on Monday mostly upheld $11 million in foreign reporting penalties against a man who admitted he hid money overseas, but the court declined to overturn its ruling that the IRS lacks authority to assess certain foreign reporting penalties.

  • April 08, 2024

    CPAs Want Treasury To Delay Beneficial Ownership Registry

    The U.S. Department of the Treasury should delay enforcement of beneficial ownership information reporting requirements while courts hear cases challenging the Corporate Transparency Act, the American Institute of Certified Public Accountants and 54 state CPA societies said.

  • April 08, 2024

    Siblings Sentenced Over £1M UK Film Tax Fraud

    Two brothers who fraudulently filed for more than £1 million ($1.3 million) in U.K. film and value-added tax refunds for movies actually made in the U.S. — and in one case, never existed — were each sentenced Monday to seven years in prison, HM Revenue & Customs said.

  • April 08, 2024

    EU Tax Single Filing Would Aid Small-Biz Trade, Official Says

    A proposal allowing small businesses in the European Union to file a single tax return with the administration of the business' head office as opposed to with every member country where the entity does business would cut compliance costs and encourage trade, an EU official said.

  • April 08, 2024

    EU Expansion Question Shines Light On Tax Voting Procedure

    The question of whether the European Union should expand beyond its current 27 member countries is putting the spotlight on the bloc's voting practices, raising concerns that the current unanimity requirement for tax policy changes would become unmanageable with a larger group.

  • April 05, 2024

    Monopolies Will Raise Prices Under Minimum Tax, Expert Says

    The 15% global minimum tax will worsen the problems that monopolistic companies impose on economies because raising taxes on a company that lacks competition will lead it to raise prices, an academic expert on tax havens said Friday during a conference.

  • April 05, 2024

    Ireland Issues Example Of Dividend Exemption Proposal

    The Ireland Department of Finance released a hypothetical example Friday to help guide further discussions on the country's planned implementation of a participation exemption from Irish corporation tax for foreign dividends.

  • April 05, 2024

    Irish Finance Dept. Seeks 2 Sovereign Funds For Tax Surplus

    The Irish Department of Finance introduced a bill that would establish two sovereign wealth funds in Ireland as a way to take advantage of the country's surplus generated in part by corporate windfall taxes.

  • April 05, 2024

    Contrasts Emerge Between Taiwan Tax Bill, Regular Treaties

    A bill pending in the Senate would lay the groundwork for double-tax relief and other treaty-like arrangements with Taiwan, but the unique legislative process and relatively reduced content could cast uncertainty over the unofficial accord's ultimate fate.

  • April 05, 2024

    UK Urges Delay In Claiming Pensions Until Rules Change

    The U.K. tax authority has warned people to delay claiming their pensions until after Saturday, when the lifetime allowance is abolished, while the government clarifies technical changes to the legislation.

  • April 05, 2024

    EU Executive To Probe Complaint About Hungarian Retail Tax

    The European Commission will look into a complaint it received about a Hungarian tax on the retail sector, the European Union's executive branch confirmed Friday.

  • April 05, 2024

    18 Crime Gangs Specialize In VAT Fraud, Europol Says

    Eighteen major criminal gangs in the European Union specialize in value-added tax fraud, having end-to-end control over the entire criminal process, the EU's law enforcement agency said Friday.

  • April 05, 2024

    Taxation With Representation: Latham, Simpson Thacher

    In this week's Taxation with Representation, Endeavor and Nuvei each go private, SLB purchases ChampionX and Liberty Media Corp. buys Dorna Sports SL.

  • April 04, 2024

    Snell & Wilmer Adds Former McDermott Partner In Dallas

    A former McDermott Will & Emery partner and tax specialist has joined Snell & Wilmer's Dallas office to advise clients on cross-border transactions, particularly in Latin America and Mexico.

  • April 04, 2024

    Companies In Limbo As IRS Mulls Waiver For 15% Book Tax

    Corporations preparing for their quarterly estimated taxes are uncertain about paying a 15% alternative minimum tax due on April 15, since the Internal Revenue Service granted waivers last year and has yet to release proposed regulations that officials have promised since October.

  • April 04, 2024

    IRS Penalties Proper In $11B Amgen Dispute, Tax Court Says

    The Internal Revenue Service properly authorized penalties included in a tax bill of nearly $11 billion that drugmaker Amgen is challenging, the U.S. Tax Court said Thursday.

  • April 04, 2024

    Ireland Would Need Big Tax Hike For Unification, Study Says

    The costs of a theoretical reunification of Northern Ireland with the rest of Ireland would be between 5% and 10% of the country's gross national income, which would likely need to be made up with a "dramatic" increase in taxes, a study released Thursday said.

  • April 04, 2024

    Attys Awarded $1.5M In Fees On Tax Disclosure Suit

    Attorneys who won a $4.5 million settlement for a class of investors claiming a Chinese startup misrepresented its tax liability will receive their requested $1.5 million in attorney fees, a New York federal judge ruled.

  • April 04, 2024

    Mayer Brown Adds Former KPMG Tax Specialist In London

    Mayer Brown has added a former KPMG tax professional to its London office to advise clients on asset management and fund matters in the U.S., Europe and the Middle East, the firm announced.

  • April 04, 2024

    Singapore Co.'s Properties Transfer Ruled Capital Transaction

    The transfer of properties between a Singapore company and a related company as part of a corporate restructuring would constitute a capital transaction, the country's Inland Revenue Authority said, making the swap tax-exempt.

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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