International

  • 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.

  • 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.

Expert Analysis

  • 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.

  • Cos. May Want To Wait Out US-EU Green Incentives Fight

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    As the European Union considers measures to compete with the Inflation Reduction Act's incentives for U.S. production of clean tech, and EU and U.S. officials discuss a possible compromise, companies in the green sector should consider taking a wait-and-see approach to investment decisions, says Todd Thacker at Goldberg Segalla.

  • India's Budget Proposals May Ease Entry For Certain Sectors

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    India’s recently released budget includes proposals to facilitate doing business in Gujarat International Finance Tec-City and moderate thousands of compliance requirements, opening up new opportunities for foreign businesses in the digital infrastructure, manufacturing and renewable energy sectors, say Mukesh Butani and Seema Kejriwal at BMR Legal.

  • High Court Ax Of Atty-Client Privilege Case Deepens Split

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    The U.S. Supreme Court's recent dismissal of In re: Grand Jury as improvidently granted maintains a three-way circuit split on the application of attorney-client privilege to multipurpose communications, although the justices have at least shown a desire to address it, say Trey Bourn and Thomas DiStanislao at Butler Snow.

  • US-India Advance Pricing Resolutions Should Reassure Cos.

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    The United States' and India's tax authorities' recent resolution of a significant number of pending advance pricing agreements should reduce taxpayer uncertainty, reassure companies of the nations' good working relationship and improve India's investment environment, say Miller Williams and Caroline Setliffe at Eversheds Sutherland.

  • Stock Buyback Excise Tax Guidance A Mixed Bag For SPACs

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    Recent IRS guidance on the new stock repurchase excise tax includes a welcome exception for publicly traded special-purpose acquisition companies but does not exclude redemptions in connection with a de-SPAC transaction, and further guidance is needed to clarify ambiguities around the exception's application, say Olga Bogush and Evgeny Magidenko at ArentFox Schiff.

  • The IRS' APA Rulemaking Journey: There And Back Again

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    Attorneys at Dentons examine recent challenges in which taxpayers successfully argued Internal Revenue Service rulemaking was invalid under the Administrative Procedure Act, how tax exceptionalism and U.S. Supreme Court regulatory deference prompted such challenges, and similar challenges the agency will likely face following this line of cases.

  • ECJ Fiat Ruling Sets Clear Boundaries For EU State Aid Law

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    The European Court of Justice's recent landmark decision in Fiat v. Commission limiting the commission’s attempts to circumvent the lack of EU powers in the area of tax law has important implications in EU state aid law and beyond, say Andreas Reindl and Pietro Stella at Van Bael.

  • Unpacking The Interim Guidance On New Stock Buyback Tax

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    The U.S. Department of the Treasury and Internal Revenue Service's recent notice on applying the newly effective excise tax on stock repurchases provides much-needed clarity on the tax's scope, which is much broader than anticipated given its underlying policy rationale, say attorneys at Eversheds Sutherland.

  • IRS Will Use New Resources To Increase Scrutiny In 2023

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    The new year promises to be a busy one for the Internal Revenue Service, which is poised to apply the boost in funding provided by the Inflation Reduction Act to bolster and expand its enforcement capability, and there are four areas to watch, say attorneys at Skadden.

  • How Japan's Implementation May Change The Pillar 2 Debate

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    Japan’s outline of proposed legislation adopting a primary component of the Organization for Economic Cooperation and Development's 15% global minimum tax will increase pressure on countries — including the U.S. — that have not committed to adopting Pillar Two, says Takato Masuda of Nishimura & Asahi.

  • Foreign Tax Credit Proposal Is Some Help, But More Is Needed

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    New foreign tax credit regulations proposed by the U.S. Treasury Department provided some measure of relief on cost recovery and royalty withholding, two of the most troublesome aspects of the 2021 final foreign tax credit regulations, but the final regulations are still harmful to many taxpayers, making litigation inevitable, say attorneys at Fenwick.

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