International

  • March 26, 2024

    US EV Subsidies Discriminatory, China Tells WTO

    Domestic production rules for U.S. electric vehicles to qualify for subsidies under the Inflation Reduction Act are discriminatory, the Chinese Ministry of Commerce said Tuesday, announcing it had filed a complaint with the World Trade Organization.

  • March 26, 2024

    Decision Postponed On EU Withholding Tax Proposal

    An attempt by European Union finance ministers to agree on a new withholding tax refund law has been postponed from their meeting on April 12, an agenda published Tuesday showed.

  • March 25, 2024

    Philippines Plastic Bag Tax Would Generate $560M, Gov't Says

    A proposed weight-based tax on single-use plastic bags would catch the Philippines up with major economies and generate an estimated 31.52 billion Philippine pesos ($560 million) in its first three years, the country's Department of Finance said Monday.

  • March 25, 2024

    Nigeria Charges Binance With Tax Evasion, Says Exec Fled

    Nigeria's tax authority filed criminal tax evasion charges against Binance, one of the world's largest cryptocurrency exchanges, and two of its executives, one of whom escaped custody Monday, according to state-owned media.

  • March 25, 2024

    €92M Cross-Border Fuel VAT Fraud Case Under Investigation

    Authorities are investigating three Italian citizens based around the world for their roles in a value-added tax fraud scheme involving oil sales that led to an estimated €92 million ($99.7 million) in damages, the European Public Prosecutor's Office said Monday.

  • March 25, 2024

    Offshore Payments Aren't Taxable Services, UK Court Rules

    Two U.K. residents aren't liable for taxes tied to certain payments from an affiliated offshore company to a third-party foreign corporation, a British appeals court ruled Monday, finding the underlying transactions didn't amount to services that would trigger taxation.

  • March 25, 2024

    EU Court Asked To Rule On VAT On Transfer Pricing Payment

    A Romanian appellate court asked the European Union's Court of Justice to rule on whether payments to a Belgian parent company from a Romanian associated company to align profits under OECD transfer pricing guidelines fall within the scope of value-added tax, a document published Monday showed.

  • March 25, 2024

    PwC Australia Hires New Chief People Officer Amid Scandal

    PwC Australia hired a new chief people officer as part of the firm's plan to rebuild trust following its scandal involving the leak of Australian government documents, the firm announced Monday.

  • March 25, 2024

    EU Report Praises Dutch Efforts To Stop Tax Avoidance

    Recent efforts in the Netherlands to tackle corporate tax avoidance are working, according to a report from the European Commission published Monday, which added that a new measure taking effect this year would help make the Netherlands less attractive for tax avoidance practices. 

  • March 22, 2024

    Businessman Indicted Over Hiding Of $20M In Swiss Accounts

    A Brazilian-American businessman accused by the government in a criminal complaint of hiding $20 million from the Internal Revenue Service over 35 years by using Swiss bank accounts was indicted by a federal grand jury in Miami and charged with tax evasion, according to a Florida federal court.

  • March 22, 2024

    UN Needs To Clarify Path For Tax Framework, Dutch Say

    The United Nations' ad hoc committee tasked with determining a global tax framework must clarify the goals of its project "as soon as possible," the Netherlands' government said in a letter that included suggestions on how the body could proceed.

  • March 22, 2024

    Holland & Knight Hires Caplin & Drysdale Member In DC

    Holland & Knight LLP has boosted its Washington-based tax team, hiring a Caplin & Drysdale Chtd. member who first joined his former firm 25 years ago from the U.S. Department of the Treasury.

  • March 22, 2024

    EU Leaders OK Sending Russian Assets' Revenue To Ukraine

    European Union leaders expressed support for a proposal to transfer the net income from frozen and immobilized Russian state assets to EU funds for rebuilding Ukraine and buying arms for that country, according to a statement issued Friday.

  • March 22, 2024

    UK Tax Avoidance Scheme Promoter Fined £900K

    A Liverpool-based company that promoted a tax avoidance scheme to medical professionals must pay a £900,000 ($1.1 million) penalty, according to a tribunal ruling published by HM Revenue and Customs on Friday.

  • March 22, 2024

    US Unlikely To Move On Hungary Tax Treaty, Official Says

    Hungary's low corporate tax rate and other policies will likely prevent the U.S. government from resuming negotiations on a stalled 2010 tax treaty after terminating its existing Hungarian treaty in early 2023, an IRS official said Friday.

  • March 22, 2024

    UK Seeking Feedback On 2027 Carbon Border Tax Plan

    HM Revenue & Customs and HM Treasury are seeking feedback on the U.K.'s plan to introduce a carbon border tax on certain carbon-intensive imports by 2027.

  • March 22, 2024

    EU Leaders Seek Limited Tax Revamp To Boost Capital Market

    European Union leaders urged all bloc policymakers Friday to pursue a plan to improve business financing, including a targeted makeover of the tax systems in the member countries regarding corporate taxes, capital gains and tax breaks for interest payments.

  • March 21, 2024

    Treasury Hoping Pillar 2 Guidance Favors R&D Tax Credits

    The U.S. Treasury Department is looking for future administrative guidance on the international minimum tax agreement known as Pillar Two to give favorable treatment to U.S. research and development tax credits, but it will likely come with guardrails, a Treasury official said Thursday.

  • March 21, 2024

    GoDaddy Can't Block Transfer Of $4 Million Set Aside For VAT

    A consortium that sold shares of an internet company to GoDaddy.com can receive a $4 million transfer of escrow funds that GoDaddy claimed were instead needed to pay value-added tax on the share sale, a Dutch court ruled.

  • March 21, 2024

    UN Could Enhance Global Tax Agenda Setting, Officials Say

    The United Nations could play an important role in shaping the agenda for global tax negotiations so it better reflects the priorities and concerns of developing countries, a variety of tax officials said Thursday during a conference.

  • March 21, 2024

    IRS Proposes Exceptions For 3rd-Party Summons Notices

    The IRS proposed rules Thursday that would allow some exceptions to a requirement that the agency notify taxpayers within 45 days before issuing summonses to third parties in tax assessment and collection cases, including for certain time-sensitive examinations.

  • March 21, 2024

    EU Countries Bash Deal On Duty-Free Imports From Ukraine

    Several European Union countries objected to the agreement among EU lawmakers to extend the suspension of the bloc's custom duties and quotas on Ukrainian imports, criticizing a lack of caps on agricultural products.

  • March 21, 2024

    Australia Seeking Input On Global Minimum Tax Bills

    Australia's Treasury is seeking public feedback on three draft bills published Thursday that would implement the Organization for Economic Cooperation and Development's global corporate minimum tax.

  • March 21, 2024

    Wyden Probes Swiss Bank's Ties To Billionaire Under Scrutiny

    The Senate Finance Committee's Democratic majority launched an inquiry into Swiss bank Pictet Group's involvement with a U.S. billionaire under criminal investigation, raising questions about the bank's deferred prosecution agreement and $123 million fine by the U.S. Justice Department, committee Chairman Ron Wyden announced Thursday.

  • March 21, 2024

    Quintairos Prieto Taps Atlanta Atty To Lead New Tax Group

    Quintairos Prieto Wood & Boyer PA said it had created a tax division that will be led by an Atlanta-based partner who has guided clients on civil and criminal tax law, reinforcing its national expertise in litigation, regulatory and corporate law matters.

Expert Analysis

  • 5th Circ. Ruling Reminds Attys That CBP Can Search Devices

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    The Fifth Circuit’s recent Malik v. Department of Homeland Security decision adds to the chorus of federal courts holding that border agents don’t need a warrant to search travelers’ electronic devices, so attorneys should consider certain special precautions to secure privileged information when reentering the U.S., says Jennifer Freel at Jackson Walker.

  • 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.

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