International

  • April 23, 2024

    DC Circ. Backs Tax Penalties Against Swiss Couple

    A Swiss couple who incurred $500,000 in penalties for failing to report millions of dollars they held in Swiss bank accounts can't get out of paying, the D.C. Circuit ruled Tuesday, rejecting their argument that the IRS didn't properly approve the fines.

  • April 23, 2024

    Int'l Pricing Pact Guidance Is Coming Soon, IRS Official Says

    Updated Internal Revenue Service guidance that would help multinational corporations pursue advance pricing agreements will likely be released in a few months, an agency official said Tuesday.

  • April 23, 2024

    Disney, IBM Stuck With Tax On Royalties, NY Top Court Holds

    New York's highest court rejected Disney and IBM's arguments that the state unconstitutionally denied their attempts to take tax deductions on royalties received from foreign affiliates, holding Tuesday that the law at issue didn't discriminate against interstate commerce.

  • April 23, 2024

    EV Levy Could Blunt Swiss Climate Plan Pains, Report Says

    The first report on the long-term fiscal impact of climate change mitigation measures in Switzerland, released Tuesday, projects a major negative impact on public funds as certain tax sources dry up, but a planned replacement levy on electric vehicles could lessen that effect.

  • April 23, 2024

    Irish Minister Warns Corp. Tax Windfall Still Shrouds Deficit

    Ireland's budget is projected to have an €8.6 billion ($9.2 billion) surplus this year, but the country's finance minister again cautioned Tuesday that without the slowly decreasing windfall corporate tax receipts there would actually be a deficit.

  • April 23, 2024

    Tax Experts Want Cut To Healthcare Insurance Levy

    Tax experts on Tuesday urged the U.K. government to partially suspend a levy on healthcare insurance products, after it revealed record premium tax revenue of £8.1 billion ($10.1 billion) last year.

  • April 23, 2024

    Talk Of Int'l Wealth Tax Fuels Debate On UN Vs. OECD

    Discussion of an international tax on the world's wealthiest individuals has intensified a debate about whether international tax policy would be better steered by the Organization for Economic Cooperation and Development or the United Nations.

  • April 23, 2024

    EU Parliament OKs Extending Duty-Free Imports From Ukraine

    The European Parliament approved the suspension of the European Union's customs duties and quotas on Ukrainian imports into the EU for one year until June 2025 on Tuesday, overcoming discord in March over farm imports that threatened the deal.

  • April 22, 2024

    Scotiabank Fights To Keep Peru VAT Claim Alive

    The Bank of Nova Scotia urged the World Bank's international arbitration institution in recently released documents not to dismiss the arbitration of its value-added tax dispute against Peru, saying the case raises issues of fact.

  • April 22, 2024

    Congress Can Enact Corp. Transparency, Orgs Tell 11th Circ.

    Congress is empowered to require American companies to report their beneficial owners to the federal government because there is ample evidence they've previously been used to fund hostile foreign actors, evade sanctions and traffic drugs, two think tanks told the Eleventh Circuit in an amici brief.

  • April 22, 2024

    Partnership Can't Claim $22.7M Loss, Tax Court Says

    The U.S. Tax Court on Monday upheld the IRS' decision to deny a $22.7 million loss deduction claimed by a Connecticut partnership, finding that underlying transactions involving a bankrupt Brazilian company's debt obligations amounted to a disguised property sale.

  • April 22, 2024

    Sweden Proposes Tax Breaks Ahead Of Budget Negotiations

    The Swedish Finance Ministry proposed adjusting its so-called expert tax incentive, which businesses use to attract external workers, among a series of tax changes offered up Monday.

  • April 22, 2024

    Trader Behind £1.4B Tax Fraud Thought Trades Were Valid

    A British trader accused of being the mastermind of a fraudulent trading scheme that cost Denmark's tax authority £1.4 billion ($1.7 billion) genuinely believed that the trades worked, his lawyer told a London court on Monday.

  • April 22, 2024

    Finland Discovers €30M In Undeclared Crypto Profits

    Finnish taxpayers made at least €30 million ($32 million) in undeclared cryptocurrency trade profits in 2022, Finland's tax authority said Monday, reminding taxpayers to include such profits in their filings this year.

  • April 22, 2024

    UAE Considering R&D Tax Break, Seeks Feedback

    The United Arab Emirates is seeking public input to help design a possible research and development tax incentive proposal to help drive innovation and growth, its Ministry of Finance said.

  • April 22, 2024

    Austria Eatery Busted 2nd Time On Tax Evasion Suspicion

    A Chinese restaurant in Austria was busted for a second time on suspicion of evading taxes, this time in the amount of €135,000 ($144,000), the country's finance minister announced, declaring that "the Austrian state cannot be an 'all you can eat' buffet for tax fraudsters."

  • April 22, 2024

    EU Probes Tax Breaks To Chinese Solar Panel Companies

    The European Commission has started two investigations into suspected tax breaks and other possibly illegal foreign subsidies to Chinese solar panel companies bidding for public contracts in Romania, notices in the EU's Official Journal showed Monday.

  • April 19, 2024

    KPMG Supports Aussie Pillar 2 Plan, With Reservations

    KPMG supports Australia's plans to implement the OECD's Pillar Two global minimum corporate tax plan in principle, the accounting firm said Friday, but it has some concerns, including with how often the government diverts from the organization's wording.

  • April 19, 2024

    UN Should Eye Unitary Taxes, DSTs For Tax Pact, Report Says

    Governments should use the United Nations tax convention as an opportunity to advance the overhaul of nexus away from transfer pricing and toward formulary apportionment, including digital services taxes, to achieve unitary taxation on corporate profits, scholars at the Brookings Institution said Friday in a report.

  • April 19, 2024

    UK Tax Pros Worried Public Unaware Of Crypto Tax Liabilities

    With the growing interest in crypto-asset trading, a group representing tax professionals in the U.K. said Friday that it is concerned HM Revenue & Customs isn't doing enough to make the public aware of its tax obligations, particularly with the lowered capital gains exemption.

  • April 19, 2024

    IRS Previews New Digital Assets Reporting Form

    The Internal Revenue Service released a draft of a form brokers will have to use for the first time to disclose their digital asset sales to the agency, including instructions for taxpayers whose transactions are subject to the reporting requirements. 

  • April 19, 2024

    DC Circ. Gives Expat's Challenge To GILTI Another Chance

    A D.C. federal court was wrong to dismiss an expatriate attorney's challenge to the global intangible low-taxed income regulations without addressing his argument that he had no other legal avenue, the D.C. Circuit said Friday as it remanded the case to the lower court.

  • April 19, 2024

    Polsinelli Adds Shareholder To Tax Credit Practice In Dallas

    An attorney who spent more than a decade developing a niche practice specializing in tax credit financing has moved her practice to Polsinelli PC's Dallas office after five years at Munsch Hardt Kopf & Harr PC.

  • April 19, 2024

    India Signs Record Amount Of Advance Pricing Agreements

    India's Central Board of Direct Taxes entered into a record 125 advance pricing agreements with Indian taxpayers in fiscal year 2023-24, a 31% increase compared with the previous year, the authority said.

  • April 19, 2024

    Taxation With Representation: Kirkland, Cleary, O'Melveny

    In this week's Taxation With Representation, Resideo Technologies Inc. announced plans to buy Snap One Holdings Corp., APi Group said it bought an elevator maintenance company, Prysmian said it agreed to purchase Encore Wire, and Sayari said it closed on an investment from TPG.

Expert Analysis

  • What To Make Of IRS' New Advance Pricing Guidance

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    Recent guidance on the IRS' goals for its advance pricing agreement system provides helpful insight into review and decision-making procedures for advance pricing agreement requests, but it also raises questions about the IRS' objectives, say Richard Slowinski and Stefanie Kavanagh at Alston & Bird.

  • Reserved Investor Fund Would Plug Gap In UK Finance Market

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    The reserved investor fund recently proposed by HM Treasury has the potential to be a welcome tax-efficient addition to the U.K.’s canon of products for real estate investments, with attractive features for companies and, in particular, large asset managers, say lawyers at Herbert Smith.

  • The Reciprocal Tax Bill Is A Warning Shot At Pillar 2

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    A bill recently introduced in the House of Representatives to reciprocally tax countries deemed to have imposed discriminatory taxes on U.S. citizens and businesses takes aim at countries implementing the global minimum tax treaty known as Pillar Two, with which the U.S. has not complied, says Alan Cole at the Tax Foundation.

  • What Tax-Exempt Orgs. Need From Energy Credit Guidance

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    Guidance clarifying the Inflation Reduction Act’s credit regime, expected from the U.S. Department of the Treasury this summer, should help tax-exempt organizations determine the benefits of clean energy projects and integrate alternative energy investments into their activities, say attorneys at Morgan Lewis.

  • How Foreign Info Return Penalty Case May Benefit Taxpayers

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    The U.S. Tax Court's recent decision that the Internal Revenue Service cannot penalize taxpayers for failing to file foreign corporation information returns may give similarly situated taxpayers an opportunity to also avoid penalties, provided they protect their rights before the decision is overturned or mooted by legislation, say attorneys at Arnold & Porter.

  • The Nuts And Bolts Of IRS Domestic Content Tax Credit

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    Recent IRS guidance provides specifics on how renewable energy projects can qualify for bonus tax credits by meeting U.S. domestic content rules, but also creates a qualification framework that will be complicated for project developers to navigate, say Scott Cockerham and Wolfram Pohl at Orrick.

  • Taxing The Digital Economy: The Good, The Bad And The Ugly

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    U.S. tech companies should watch for important developments in international taxation, including the resolution of Apple's decade-old state aid case, growing frustration with the Organization for Economic Cooperation and Development's global tax plan and adoption of the digital services tax instead, says Joyce Beebe at Rice University's Baker Institute for Public Policy.

  • Big Tax Changes For Multinational Cos. In Budget Proposal

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    The Biden administration’s fiscal year 2024 budget proposes changes that would materially alter decades-old Internal Revenue Code provisions, requiring a shift in multinational corporations' tax planning strategies comparable to that required after enactment of the Tax Cuts and Jobs Act, say Xenia Garofalo and Kyle Colonna at Eversheds Sutherland.

  • Senate Credit Suisse Report Puts Attention On Banks, Trusts

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    The Senate Finance Committee's recent finding that Credit Suisse violated a plea agreement struck over its role in enabling offshore tax evasion has important ramifications for banks and trusts, including how they onboard, document and report on transactions relevant to U.S. reporting requirements, say Will Barry and Ian Herbert at Miller & Chevalier.

  • Seeking IRS Accountability For Faulty Microcaptive Notice

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    Like the taxpayers in Standard Insurances v. U.S. seeking to expand earlier wins in microcaptive insurance cases that limit IRS use of improperly obtained information, others should consider ways to hold the agency accountable and provide incentive for it to follow the law going forward, says Joshua Smeltzer at Gray Reed.

  • Biden Admin. Proposals Both Encourage And Thwart EV Adoption

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    While the Biden administration has been aggressively focused on promoting electric vehicles from the start, its recently issued guidance on EV tax credits and its restrictive new auto emissions proposal create a sense of implementation whiplash that may frustrate manufacturers and consumers, says Levi McAllister at Morgan Lewis.

  • The Key Issues Keeping Transfer Pricing A Top Tax Concern

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    Several challenges preventing a global economic reemergence from the pandemic era are making practitioners reevaluate commonly used transfer pricing models, and embrace new technologies and ways of doing business, say Farnaz Amini and Sophia Castro Jurado at Marcum.

  • 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.

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