International

  • March 12, 2024

    US, Turkey Extend Digital Services Tax Deal

    Turkey will continue to apply its digital services tax as negotiations over the Pillar One international profit reallocation agreement continue, the country said Tuesday in a joint statement with the U.S. government

  • March 12, 2024

    Man Loses Bid To Challenge US Tax Refund Fraud Extradition

    A man facing extradition to the U.S. — to stand trial on allegations that he took part in a scheme to fraudulently receive millions in tax refunds — was denied a chance to challenge the extradition by a London judge on Tuesday.

  • March 12, 2024

    EU States Likely To Treat Wealth Tax Individually, Official Says

    European Union countries are more likely to decide on wealth taxes at the national level rather than through joint legislation, although the bloc welcomed Brazil's efforts as Group of 20 chair to address inequalities globally, EU tax commissioner Paolo Gentiloni said Tuesday.

  • March 11, 2024

    FedEx Says Gov't Can't Redo $85M Foreign Tax Credit Case

    The U.S. government is trying to relitigate a Tennessee federal court's decision that sided with FedEx in a foreign tax credit dispute, the company said in asking the court to rule that it's entitled to a refund of nearly $85 million.

  • March 11, 2024

    Electronics Co. Disputes $187M Income Tax Bill From IRS

    The Internal Revenue Service erroneously increased the income tax liability of an audio electronics company by $187 million, the business argued in a U.S. Tax Court petition.

  • March 11, 2024

    Microsoft Win May Spark More Calif. Refunds, Pro Says

    Businesses that have both activity in California and foreign source income should consider whether they should file for a refund in the wake of a recent decision by the state's Office of Tax Appeals in favor of Microsoft, a practitioner said Monday.

  • March 11, 2024

    US Appeals Corporate Transparency Act Ruling To 11th Circ.

    The U.S. Department of the Treasury is moving quickly to appeal an Alabama federal judge's ruling that the Corporate Transparency Act is unconstitutional, filing a notice of appeal to the Eleventh Circuit on Monday.

  • March 11, 2024

    AML Watchdog's Guidance Urges Int'l Exchanges Of Info

    The international swapping of accurate beneficial ownership information on express trusts and other similar arrangements is key for preventing cross-border money laundering and terrorist financing, the Financial Action Task Force said Monday.

  • March 11, 2024

    EU Finance Ministers Agree On Limited Tax Makeover

    European Union finance ministers agreed Monday to a plan for a targeted makeover of their tax systems to improve the financing of business, including revisions of corporate taxes, capital gains taxes and tax breaks for interest payments.

  • March 11, 2024

    New Zealand Panel Urges 2025 Start For Global Minimum Tax

    The New Zealand Parliament should include a 2025 start date for implementing the Organization for Economic Cooperation and Development's global minimum tax plan as part of a wider bill, a government committee said Monday.

  • March 11, 2024

    Singapore Telecom Loses $201M Aussie Transfer Pricing Fight

    A Singapore telecommunications company's Australian subsidiary is liable for a tax bill of AU$304 million ($201 million), including interest and penalties, after an Australian appellate panel upheld a ruling that disallowed deductions for the subsidiary's interest payments to a Caribbean affiliate.

  • March 11, 2024

    Danish Prosecutors Open Tax Fraud Trial Against Sanjay Shah

    Prosecutors in Denmark opened the criminal trial on Monday of a British hedge fund trader accused of masterminding a £1.44 billion ($1.85 billion) tax fraud scheme. 

  • March 08, 2024

    Colombia Issues Guidance On Wealth, Environment Taxes

    Colombia's new wealth tax and adjustments to environmentally focused taxes passed in a wide-ranging 2022 bill were among the subjects of guidance published by the country's tax agency.

  • March 08, 2024

    States Must Nix Worldwide Combined Reporting, COST Says

    States showing glimmers of interest in the corporate tax reporting regime known as mandatory worldwide combined reporting are going down the wrong path as are the think tanks that support the method, the Council on State Taxation said in a report released Friday.

  • March 08, 2024

    HMRC Can Seek Identity Of Data Suit Financier

    A London court rejected on Friday an attempt to terminate U.K. government arguments for disclosing the identity of a financier backing a former U.S. citizen's claim that the transfer of some of her banking data by HM Revenue & Customs back to the U.S. violated her rights.

  • March 08, 2024

    BakerHostetler Hires Tax Partner From Moses & Singer

    BakerHostetler has added a partner from Moses & Singer LLP to its tax practice group and private wealth planning team.

  • March 08, 2024

    Taxation With Representation: Fried Frank, Latham

    In this week's Taxation with Representation, Viavi acquires Spirent, Cadence Design Systems purchases Beta Cae Systems International, and United Rentals buys Yak.

  • March 08, 2024

    ECB Urges EU Tax Measures To Boost Capital Market

    The European Central Bank has urged the bloc's finance ministers to agree on a new law on refunds on withholding tax and to eliminate the favorable treatment in national tax systems of corporate financing with debt over equity.

  • March 08, 2024

    'Non-Dom' Tax Reforms Should Keep UK Lawyers Busy

    The government's decision to reform its 200-year-old "non-dom" tax regime to raise £2.7 billion ($3.4 billion) a year presents a short-term boom for tax lawyers expecting a rush of calls from existing and future clients looking for guidance on a new set of rules.

  • March 07, 2024

    Southern Peaks Awarded $42.5M Over Peruvian Copper Deal

    Peruvian copper producer Southern Peaks Mining LP said it has won a multi-million-dollar arbitral award favoring its management subsidiary due to breaches of a sale and purchase agreement with Singaporean commodity trading company Trafigura Beheer BV over the acquisition of a mine.

  • March 07, 2024

    Don't Let Pillar 1 Die, Policy Experts Tell House Tax Panel

    Tax policy experts encouraged a U.S. House subcommittee Thursday to continue negotiations at the Organization for Economic Cooperation and Development over the taxing rights overhaul known as Pillar One and advocate for stronger double taxation relief and tougher language eliminating digital service taxes.

  • March 07, 2024

    Indian Gov't Eyes Linking Carbon Tax On Coal To Quality

    The Indian government should consider linking its carbon tax on coal to quality and price rather than weight because the current system gives an advantage to imported coal over domestic coal, the country's Ministry of Coal said Thursday.

  • March 07, 2024

    UAE Implementing Income Tax On Foreign Banks In Dubai

    Foreign banks operating in Dubai — except for those operating in one special economic jurisdiction — must pay a 20% income tax, according to a law signed by the United Arab Emirates' prime minister Thursday.

  • March 07, 2024

    Spotify Cites New Tax In Raising Subscription Fee In France

    Spotify will raise the price of subscriptions in France to what it said will be the most expensive in the European Union in response to a new French tax earmarked for the country's Center for National Music, the streaming service said Thursday.

  • March 07, 2024

    5 Indicted In €54M VAT Fraud Involving 10,000 Cars

    Authorities indicted five suspects arrested in connection with a scheme involving the international trade of more than 10,000 cars that resulted in €53.7 million ($58.7 million) in value-added tax fraud, the European Public Prosecutor's Office said.

Expert Analysis

  • How High Court Could Change FBAR Penalty Landscape

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    On Wednesday, the U.S. Supreme Court will hear Bittner v. U.S., a case that will affect many people penalized for failing to file a Report of Foreign Bank and Financial Accounts, and there are important procedural implications should the government's position be reversed, say Reuben Muller and Andreas Apostolides at Cole Schotz.

  • IRS Memo May Change IP Royalty Tax Prepayment Planning

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    A recent Internal Revenue Service advice memorandum finding a taxpayer was not permitted to prepay tax on contingent royalties after contributing intellectual property offshore is a noteworthy departure from earlier guidance that highlights potential differences between actual and deemed licenses, says William Skinner at Fenwick.

  • What IRS Funding Increase Means For Taxpayers

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    The Internal Revenue Service will first use the influx of funding from the Inflation Reduction Act to address customer support and personnel issues, but with over half the money allocated to enforcement, corporations and high-net-worth individuals will face increased scrutiny, say Patrick McCann Jr. and Jasen Hanson at Chamberlain Hrdlicka.

  • 6 Tax Considerations For Life Sciences Collaboration Deals

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    Given recent IRS guidance and changes to certain tax rates and deductions, biotech and life sciences companies entering into collaboration agreements should assess several unique taxation issues affecting matters ranging from research and development expenditures to profit-sharing terms, say attorneys at Orrick and Andersen Tax.

  • Rushed Multilateral Negotiations Caused Two-Pillar Tax Mess

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    Cracks appearing in the two pillars of the 2021 global tax plan stem from a multilateral tax policy process that rushed to issue rules without first resolving fundamental differences between countries or ensuring that the U.S., a key player, could implement them, says Jefferson VanderWolk at Squire Patton.

  • Key Considerations For Seeking Relief From Double Taxation

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    Caroline Setliffe and E. Miller Williams at Eversheds Sutherland lay out the Organization for International Cooperation and Development’s mutual agreement procedure for settling double-taxation disputes, and discuss six factors U.S. taxpayers doing business in multiple countries should consider when determining the most advantageous form of relief.

  • 2 Tax Decisions Hold Key Transfer Pricing Takeaways

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    Richard Slowinski and Stefanie Kavanagh at Alston & Bird discuss two recent decisions in cases against the IRS — Eaton Corp. from the Sixth Circuit and Medtronic from the Tax Court — that may help clarify when the agency can cancel an advance pricing agreement, but leave unanswered questions about which pricing method applies to high-value intercompany licensing transactions.

  • Digital Taxation Is Necessary, But Tough To Manage

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    The U.S. government has started to tackle complex new tax laws as the digital economy continues to grow, but this demands guidelines that will facilitate the growth while protecting investors and the government's finances, say attorneys at Cadwalader.

  • Company Considerations For Cash Award Incentives: Part 2

    Excerpt from Practical Guidance
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    Cash awards can help companies address some issues associated with equity awards to compensate employees, but due to potential downsides, they should be treated as a tool in a long-term incentive program rather than a panacea, say Denise Glagau and Kela Shang at Baker McKenzie.

  • Company Considerations For Cash Award Incentives: Part 1

    Excerpt from Practical Guidance
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    Denise Glagau and Kela Shang at Baker McKenzie discuss what companies must consider when offering cash awards outside of U.S. jurisdictions, and explain how some challenges associated with equity awards may be addressed with cash awards.

  • What AML Bill Could Mean For Firms, Funds And FinCEN

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    If passed, an amendment within Congress’ annual defense bill would expand the list of institutions subject to anti-money laundering regulations, from law firms to investment funds, creating potential rulemaking and enforcement challenges for the Financial Crimes Enforcement Network, say attorneys at Arnold & Porter.

  • Unpacking The New Stock Buyback Tax And Its Exceptions

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    Xenia Garofalo and Kyle Colonna at Eversheds Sutherland discuss provisions of the recently enacted tax on corporate stock repurchases, how its exceptions may be applied and what companies should consider when evaluating the cost of new or existing programs.

  • Inside The OECD Transfer Pricing Documentation Guidance

    Excerpt from Practical Guidance
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    The Organization for Economic Cooperation and Development's recently modified documentation guidelines can assist tax administrations in developing requirements for transfer pricing risk assessments and evaluations, and help multinational entity taxpayers demonstrate satisfaction of the arm's-length principle, says Neil Aragones at Lexis Tax.

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