International

  • April 26, 2024

    Ireland Received Nearly €24B In Corp. Taxes In 2023

    Corporations paid Ireland €23.8 billion ($25.5 billion) in taxes in 2023, a 5.3% increase over 2022, making corporate tax receipts the second-largest tax revenue generator in the country, according to the Irish revenue department.

  • April 26, 2024

    PwC Australia Appoints 6 Partners To Guide Scandal Rebound

    PwC Australia announced that it has elected six partners to its governance board as the firm continues to attempt to rebound in the wake of its scandal involving the leak of Australian government documents.

  • April 26, 2024

    HMRC Says Tax Digitalization Plan Will Generate £6.4B

    HM Revenue & Customs said its program to modernize U.K. tax filing is expected to generate £6.38 billion ($7.97 billion) in additional revenue through 2034 after projections last year put it at £3.9 billion.

  • April 26, 2024

    Poland Seeks Input On Bill To Enact Minimum Tax

    Poland, one of a handful of European Union countries that have delayed implementing the Organization for Economic Cooperation and Development's Pillar Two global minimum tax plan, introduced a proposal for public comment that would enact the regime.

  • April 26, 2024

    Abbott Labs' $417M IRS Bill Isn't Wrong, Tax Court Told

    The Internal Revenue Service denied allegations by Abbott Laboratories that it incorrectly increased the global healthcare giant's income, resulting in a $417 million tax bill, in answering Abbott's lawsuit filed with the U.S. Tax Court.

  • April 26, 2024

    Top EU Judge Sees Lower Court Becoming Like Tax Court

    The lower court of the European Union, the General Court, will over time become a venue that specializes in some tax matters after a reform is put into place, the EU's top judge has said.

  • April 26, 2024

    HSBC Beats Investors' £1.3B Disney Film Scheme Fraud Case

    HSBC fended off on Friday a £1.3 billion ($1.6 billion) fraud claim brought by hundreds of investors who alleged the bank misled them into financing a Disney movie tax relief scheme it developed which turned out to be worthless.

  • April 25, 2024

    Romanian Sanctions On Fuel Violate EU Law, Court Says

    A Romanian law imposing sanctions of €77,000 ($83,000) — 21 times the usual rate of taxation — on fuel placed back into storage is so extreme it violates European Union law, the EU's top court said Thursday.

  • April 25, 2024

    Dutch Tax Authority Aiming To Beef Up Data Security

    The Netherlands' tax authority is introducing more data protection measures based on suggestions from a KPMG report commissioned after signs of possible security threats within the tax administration, it said Thursday.

  • April 25, 2024

    Workers' Effective Tax Rates In OECD Countries Rise Again

    The effective tax rates on labor income in the majority of Organization for Economic Cooperation and Development member countries rose for the second year in a row in 2023, thanks in part to continued inflation, the OECD said Thursday.

  • April 25, 2024

    OECD Says Latvia Must Shift Tax Burden, Limit Fuel Subsidies

    Latvia needs to shift its tax burden off labor and onto other forms of income such as property, and to eliminate harmful subsidies and tax practices around fossil fuels, the Organization for Economic Cooperation and Development said Thursday.

  • April 25, 2024

    OECD Consolidates Past Pillar 2 Guidance Into Single Doc

    The Organization for Economic Cooperation and Development published administrative guidance Thursday that consolidates past publications on the interpretation and application of the international minimum tax agreement known as Pillar Two, which countries began implementing this year.

  • April 25, 2024

    EU Parliament Gives Final Approval To AML Package

    The European Parliament has given the final go-ahead to a package of laws to fight money laundering and terrorist financing, creating a single rule book and establishing a dedicated agency for the bloc.

  • April 25, 2024

    Ministers From 4 Countries Back Billionaire Tax

    Government ministers from Germany, Spain, South Africa and Brazil said Thursday that they have backed a global plan to ensure that billionaires pay a minimum amount of tax, arguing that the move is necessary to make the tax system more equitable.

  • April 24, 2024

    EU Court Won't Disturb Spanish Tax Break Rulings

    A Spanish company on Wednesday lost its attempt to legitimize a tax scheme declared illegal by the European Commission when the European Union's General Court rejected its appeal, refusing to disturb prior decisions in the long-running dispute.

  • April 24, 2024

    GOP Reps Seek IRS Nonprofit Info After China Reports

    House Ways and Means Republicans asked the Internal Revenue Service to provide information about how it monitors tax-exempt organizations for possible violations of their status after reports China may be funding and improperly influencing nonprofits, according to a letter sent Wednesday.

  • April 24, 2024

    Treasury Limits Reach Of Look-Through Rule In Final Regs

    The U.S. Treasury Department finalized regulations Wednesday that retain but narrow the scope of a proposal to, in a manner of speaking, look through the corporate owners of real estate investment entities to determine whether they are domestically controlled.

  • April 24, 2024

    Tax Pros Suggest How HMRC Can Assess Digitalization Effort

    HM Revenue & Customs should abide by a set of benchmarks when evaluating tests of its digitalization program for income tax self-assessment forms, two groups representing U.K. tax professionals said.

  • April 24, 2024

    Ex-England Footballer Banned As Director For Unpaid Tax

    Former England football international John Barnes has been banned from being a company director after his business failed to pay more than £190,000 ($236,000) in tax, a U.K. government agency announced on Wednesday.

  • April 24, 2024

    Papua New Guinea Commits To Automatic Tax Info Exchange

    Papua New Guinea has committed to enacting the Organization for Economic Cooperation and Development's standard for automatic exchange of financial account information in tax matters by September 2027, the OECD said Wednesday.

  • April 24, 2024

    EU Keeps Gibraltar, Panama, UAE On AML Blacklist

    Gibraltar, Panama and the United Arab Emirates should remain on the European Union's blacklist of high-risk countries for money laundering, the European Parliament said, stopping the EU from following the lead of a global organization promoting standards for countries to fight those crimes.

  • April 24, 2024

    EU Expected To OK Withholding Tax, Digital VAT Laws In May

    European Union finance ministers are expected to agree on a new withholding tax refund law and a package to modernize value-added tax reporting at their May 14 meeting, an EU official said Wednesday, speaking on the condition of anonymity.

  • April 24, 2024

    EU Says 3 States Aren't Correctly Following AML Law

    The European Commission said Wednesday that three European Union countries — Ireland, France and Latvia — aren't correctly implementing the bloc's laws against money laundering, meaning that the countries now have two months to correct the shortcomings.

  • April 23, 2024

    Treasury Says Aussie Royalty Ruling Contradicts US, OECD

    Australia's updated draft ruling regarding when payments for the rights to distribute software would be considered royalties conflicts with OECD and U.S. standards on the treatment of such deals, a U.S. Department of the Treasury official said in a letter made public Tuesday.

  • April 23, 2024

    Biz Ownership Law Constitutional, Lawmakers Tell 11th Circ.

    The Corporate Transparency Act is a garden-variety exercise of Congress' powers to address threats to national security, foreign affairs, commerce and tax collection, five Democratic lawmakers told the Eleventh Circuit, disputing a ruling that the law is unconstitutional.

Expert Analysis

  • Preparing Your Legal Department For Pillar 2 Compliance

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    Multinational entities should familiarize themselves with Pillar Two of the Organization for Economic Cooperation and Development’s BEPs 2.0 project and prepare their internal legal tracking systems for related reporting requirements that may go into effect as early as January, says Daniel Robyn at Ernst & Young.

  • What Large Language Models Mean For Document Review

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    Courts often subject parties using technology assisted review to greater scrutiny than parties conducting linear, manual document review, so parties using large language models for document review should expect even more attention, along with a corresponding need for quality control and validation, say attorneys at Sidley.

  • Participating In Living History Makes Me A Better Lawyer

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    My role as a baron in a living history group, and my work as volunteer corporate counsel for a book series fan association, has provided me several opportunities to practice in unexpected areas of law — opening doors to experiences that have nurtured invaluable personal and professional skills, says Matthew Parker at the Nebraska Department of Health and Human Services.

  • Private Equity Owners Can Remedy Law Firms' Agency Issues

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    Nonlawyer, private-equity ownership of law firms can benefit shareholders and others vulnerable to governance issues such as disparate interests, and can in turn help resolve agency problems, says Michael Di Gennaro at The Law Practice Exchange.

  • How Taxpayers Can Prep As Justices Weigh Repatriation Tax

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    The U.S. Supreme Court might strike down the 2017 federal tax overhaul's corporate repatriation tax in Moore v. U.S., so taxpayers should file protective tax refund claims before the case is decided and repatriate previously taxed earnings that could become entangled in dubious potential Section 965 refunds, say Jenny Austin and Gary Wilcox at Mayer Brown.

  • OFAC Designation Prosecutions Are Constitutionally Suspect

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    Criminal prosecutions based on the Office of Foreign Assets Control’s sanctions-related listing decisions — made with nearly unfettered discretion through an opaque process — present several constitutional issues, so it is imperative that courts recognize additional rights of review, say Solomon Shinerock and Annika Conrad at Lewis Baach.

  • How The OECD Global Tax Proposal Could Affect M&A

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    Following agreement on the Organization for Economic Cooperation and Development’s Pillar Two proposal to introduce a global minimum tax, domestic implementation is expected to have a significant impact on international M&A transactions, with financial modeling, deal structuring, risk allocation and joint venture arrangements likely to be affected, say lawyers at Freshfields.

  • UK Shares-Tax Proposals Offer Long-Awaited Modernization

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    The U.K. government's recent consultation on the introduction of a new tax on transactions in securities raises detailed legal and practical issues, but the prospect of a single digital stamp tax offering both streamlined legislation and administration will be welcomed, say Zoë Arnautov and Mark Sheiham at Simmons & Simmons.

  • IRS Foreign Tax Credit Pause Is Welcome Course Correction

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    A recent IRS notice temporarily suspending application of 2022 foreign tax credit regulations provides wanted relief for the many U.S. multinational companies and other taxpayers that otherwise face the risk of significant double taxation in their international operations, say attorneys at Mayer Brown.

  • IRS Criminal Probe Spells Uncertainty For Malta Pension Plans

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    The IRS’ recent scrutiny of Malta pension plan arrangements — and its unusual issuance of criminal administrative summonses — confirms that it views many of these plans as illegal tax evasion schemes, and the road ahead will not be smooth and steady for anyone involved, say attorneys at Kostelanetz.

  • IRS Announcement Will Aid Cos. In Buyback Tax Planning

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    Recent IRS transitional guidance regarding current requirements for reporting and payment of the stock repurchase excise tax will help corporate taxpayers make decisions about records retention and establishing reserves for future tax payments, say Xenia Garofalo and Kyle Colonna at Eversheds Sutherland.

  • Flawed Analysis Supports Common Law Tax Deficiency Ruling

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    The Colorado federal district court’s recent decision in Liberty Global, holding that the U.S. Department of Justice may assert a common law tax claim without the notice of tax deficiency required by the Internal Revenue Code, relies on a contorted reading of the statute and irrelevant case law, say Loren Opper and Christie Galinski at Miller Canfield.

  • Review Of Repatriation Tax Sets Justices On Slippery Slope

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    The U.S. Supreme Court’s recent decision to review the constitutionality of the repatriation tax in Moore v. U.S. has implications for many tax rules involving unrealized amounts and could leave the court on the brink of invalidating large swaths of the Internal Revenue Code, say attorneys at Eversheds Sutherland.

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