International

  • May 04, 2024

    IRS Seeks More Info On Purpose Test In Buyback Tax Regs

    The IRS is seeking more information on fine-tuning a test in proposed rules on the stock buyback tax meant to assess whether the principal purpose of a U.S. subsidiary's funding purchase of its foreign parent's stock is to avoid the tax, an agency attorney said Saturday.  

  • May 03, 2024

    US Resisting More Scoping On Amount B, Economist Says

    In negotiations over the streamlined transfer pricing approach for baseline marketing and distribution functions known as Amount B, the U.S. has resisted calls for additional scoping criteria that would exclude more companies from the safe harbor, a former U.S. Treasury economist said Friday.

  • May 03, 2024

    Foreign Trust Reporting Rules Coming Soon, IRS Official Says

    The Internal Revenue Service is about to issue proposed regulations that will provide guidance on the reporting obligations for individuals who have transactions with foreign trusts, an agency official said Friday.

  • 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.

Expert Analysis

  • Enforcement Of International Tax Reporting Is Heating Up

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    Since the U.S. Supreme Court’s February decision in Bittner v. U.S. changed how penalties for failure to report offshore accounts are calculated, recent developments suggest the government is preparing to step up enforcement and vigorously pursue the collection of resulting penalties, say Daniel Silva and Agustin Ceballos at Buchalter.

  • IRS Notice Clarifies R&E Amortization, But Questions Remain

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    The IRS and Treasury Department’s recent notice clarifying the treatment of specified research and experimental expenditures under Section 174 provides taxpayers and practitioners with substantive guidance, but it misses the mark in delineating which expenditures are amortizable, say attorneys at Eversheds Sutherland.

  • 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.

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