International

  • March 14, 2024

    Nine In 10 Finnish Cos. Report Positive Attitude To Taxation

    Nine of 10 Finnish companies have a positive attitude toward taxation, according to a survey announced Thursday by Finland's Tax Administration.

  • March 14, 2024

    IRS' Signals On Economic Substance Doctrine Draw Scrutiny

    The Internal Revenue Service's recent legal success asserting a doctrine to invalidate transactions in tax law enforcement matters may embolden the government to broaden that argument's reach, and lawyers are concerned it doesn't properly apply to transfer pricing matters.

  • March 14, 2024

    EU Law No Hindrance To Interest Rule, Says ECJ Adviser

    European Union law does not preclude national legislation restricting the ability of taxpayers to deduct interest on a loan that is taken out for non-commercial reasons, an adviser to the bloc's Court of Justice found Thursday.

  • March 13, 2024

    Disney, IBM Seeking Tax Loophole, NY High Court Judge Says

    Disney and IBM's attempt to take New York tax deductions on royalties received from foreign affiliates is "the biggest loophole" that could be created under a former tax statute, a New York high court judge said Wednesday during oral arguments in disputes involving both companies.

  • March 13, 2024

    Siemens Asks Tax Court To Toss $1.2B IRS Bill

    A U.S. subsidiary of German technology company Siemens is pushing the U.S. Tax Court to throw out $1.16 billion in tax deficiencies and penalties the IRS has imposed, saying the agency relied on invalid rules in denying a deduction.

  • March 13, 2024

    JCT Indicates Pillar 1 Is Bad Deal For US, GOP Lawmakers Say

    An analysis of the Organization for Economic Cooperation and Development's Pillar One taxing rights overhaul by congressional scorekeepers makes clear the plan should not receive U.S. support because it would disadvantage U.S. multinationals and federal tax revenue, Republican leaders of Congress' taxwriting committees said Wednesday.

  • March 13, 2024

    Longtime Stradley Ronon Tax Partner Joins Grant Thornton

    Following more than a quarter-century practicing law with Stradley Ronon Stevens & Young LLP, longtime tax attorney Chris Scarpa decided to change career paths, joining accounting firm Grant Thornton LLP.

  • March 13, 2024

    EU Seeks Comments On Double-Tax Dispute Framework

    The European Commission is asking businesses and citizens to weigh in on the European Union's framework for resolving cross-border disputes within the bloc regarding double taxation, the commission said Wednesday.

  • March 13, 2024

    Australia Asking Stakeholders For Goals For New Tax Treaties

    Australia is working to expand its tax treaty network by crafting new agreements with Brazil and Ukraine, as well as updating three other treaties, and is seeking public feedback on what they should cover, its Treasury said Wednesday.

  • March 13, 2024

    EU Parliament Backs Overhaul Of Customs Laws

    A revamp of the European Union's customs code that aims to simplify handling of most imported goods while focusing checks on potentially illicit and tax-dodging shipments was approved by the European Parliament on Wednesday.

  • March 12, 2024

    Irish Co. Can Claim €28M In Foreign Royalty Tax Deductions

    Ireland's tax office wrongfully denied a company €27.8 million ($30.4 million) in tax deductions it had claimed for royalty withholding tax imposed on its income by foreign jurisdictions, the country's Tax Appeals Commission said in a determination released Tuesday.

  • March 12, 2024

    IRS Mulling Partnership Foreign Currency Rules, Official Says

    The Internal Revenue Service will likely propose rules that would provide additional guidance to partnerships for determining taxable income or loss with respect to certain affiliates that conduct business in a foreign currency, an agency official said Tuesday.

  • March 12, 2024

    Calif. Man Agrees To Pay Nearly $500K In FBAR Penalties

    A California man agreed to pay almost $500,000 in penalties, late fees and interest for failing to report his bank accounts in the Bahamas on his tax forms, according to a stipulated order entered by a California federal court.

  • March 12, 2024

    OECD Suggests Ways Romania Can Boost Tax Revenue

    Romania's tax revenue is too low to fund ongoing government spending, and its government should work on changes to its income and value-added tax systems to alter that, the Organization for Economic Cooperation and Development said Tuesday.

  • March 12, 2024

    Tax Officials Say Data Needed To Coax Politicians Into Pillar 2

    The biggest challenge developing countries face in implementing the 15% global minimum tax is persuading politicians, which would be easier if more of them had access to data showing which companies are in-scope, tax officials said Tuesday during an OECD conference.

  • March 12, 2024

    PwC Must Come Clean About Tax Scandal, Aussie Sens Say

    PwC must name the partners who shared confidential drafts of tax laws, release its internal report on the matter and go further than modest self-regulation, Australian senators told Law360 on Tuesday in response to the firm announcing reforms to its governance structure.

  • March 12, 2024

    Netherlands, Bangladesh Reach Deal To Update Tax Treaty

    The Netherlands said Tuesday that it signed an updated double-tax treaty with Bangladesh that broadens the taxing rights of the South Asian country.

  • March 12, 2024

    Businessman Hid $20M In Swiss Accounts, US Says

    A Brazilian-American businessman hid $20 million from the Internal Revenue Service over 35 years using accounts at Swiss banks including UBS and Credit Suisse, the U.S. government said in a criminal complaint that accuses him of conspiring to defraud the U.S. and lying to authorities.

  • March 12, 2024

    US, Turkey Extend Digital Services Tax Deal

    Turkey will continue to apply its digital services tax as negotiations over the Pillar One international profit reallocation agreement continue, the country said Tuesday in a joint statement with the U.S. government

  • March 12, 2024

    Man Loses Bid To Challenge US Tax Refund Fraud Extradition

    A man facing extradition to the U.S. — to stand trial on allegations that he took part in a scheme to fraudulently receive millions in tax refunds — was denied a chance to challenge the extradition by a London judge on Tuesday.

  • March 12, 2024

    EU States Likely To Treat Wealth Tax Individually, Official Says

    European Union countries are more likely to decide on wealth taxes at the national level rather than through joint legislation, although the bloc welcomed Brazil's efforts as Group of 20 chair to address inequalities globally, EU tax commissioner Paolo Gentiloni said Tuesday.

  • March 11, 2024

    FedEx Says Gov't Can't Redo $85M Foreign Tax Credit Case

    The U.S. government is trying to relitigate a Tennessee federal court's decision that sided with FedEx in a foreign tax credit dispute, the company said in asking the court to rule that it's entitled to a refund of nearly $85 million.

  • March 11, 2024

    Electronics Co. Disputes $187M Income Tax Bill From IRS

    The Internal Revenue Service erroneously increased the income tax liability of an audio electronics company by $187 million, the business argued in a U.S. Tax Court petition.

  • March 11, 2024

    Microsoft Win May Spark More Calif. Refunds, Pro Says

    Businesses that have both activity in California and foreign source income should consider whether they should file for a refund in the wake of a recent decision by the state's Office of Tax Appeals in favor of Microsoft, a practitioner said Monday.

  • March 11, 2024

    US Appeals Corporate Transparency Act Ruling To 11th Circ.

    The U.S. Department of the Treasury is moving quickly to appeal an Alabama federal judge's ruling that the Corporate Transparency Act is unconstitutional, filing a notice of appeal to the Eleventh Circuit on Monday.

Expert Analysis

  • 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.

  • IRS' Tax Gap Statistics Don't Paint A Full Compliance Picture

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    The Internal Revenue Service's recent report indicating a widening tax gap sheds important light on tax compliance, underlines key pressure points and provides insights into how tax administration could be improved; but tax gap estimates also have their limits, says Joyce Beebe at Rice University.

  • How High Court Could Change FBAR Penalty Landscape

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    On Wednesday, the U.S. Supreme Court will hear Bittner v. U.S., a case that will affect many people penalized for failing to file a Report of Foreign Bank and Financial Accounts, and there are important procedural implications should the government's position be reversed, say Reuben Muller and Andreas Apostolides at Cole Schotz.

  • IRS Memo May Change IP Royalty Tax Prepayment Planning

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    A recent Internal Revenue Service advice memorandum finding a taxpayer was not permitted to prepay tax on contingent royalties after contributing intellectual property offshore is a noteworthy departure from earlier guidance that highlights potential differences between actual and deemed licenses, says William Skinner at Fenwick.

  • What IRS Funding Increase Means For Taxpayers

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    The Internal Revenue Service will first use the influx of funding from the Inflation Reduction Act to address customer support and personnel issues, but with over half the money allocated to enforcement, corporations and high-net-worth individuals will face increased scrutiny, say Patrick McCann Jr. and Jasen Hanson at Chamberlain Hrdlicka.

  • 6 Tax Considerations For Life Sciences Collaboration Deals

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    Given recent IRS guidance and changes to certain tax rates and deductions, biotech and life sciences companies entering into collaboration agreements should assess several unique taxation issues affecting matters ranging from research and development expenditures to profit-sharing terms, say attorneys at Orrick and Andersen Tax.

  • Rushed Multilateral Negotiations Caused Two-Pillar Tax Mess

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    Cracks appearing in the two pillars of the 2021 global tax plan stem from a multilateral tax policy process that rushed to issue rules without first resolving fundamental differences between countries or ensuring that the U.S., a key player, could implement them, says Jefferson VanderWolk at Squire Patton.

  • Key Considerations For Seeking Relief From Double Taxation

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    Caroline Setliffe and E. Miller Williams at Eversheds Sutherland lay out the Organization for International Cooperation and Development’s mutual agreement procedure for settling double-taxation disputes, and discuss six factors U.S. taxpayers doing business in multiple countries should consider when determining the most advantageous form of relief.

  • 2 Tax Decisions Hold Key Transfer Pricing Takeaways

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    Richard Slowinski and Stefanie Kavanagh at Alston & Bird discuss two recent decisions in cases against the IRS — Eaton Corp. from the Sixth Circuit and Medtronic from the Tax Court — that may help clarify when the agency can cancel an advance pricing agreement, but leave unanswered questions about which pricing method applies to high-value intercompany licensing transactions.

  • Digital Taxation Is Necessary, But Tough To Manage

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    The U.S. government has started to tackle complex new tax laws as the digital economy continues to grow, but this demands guidelines that will facilitate the growth while protecting investors and the government's finances, say attorneys at Cadwalader.

  • Company Considerations For Cash Award Incentives: Part 2

    Excerpt from Practical Guidance
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    Cash awards can help companies address some issues associated with equity awards to compensate employees, but due to potential downsides, they should be treated as a tool in a long-term incentive program rather than a panacea, say Denise Glagau and Kela Shang at Baker McKenzie.

  • Company Considerations For Cash Award Incentives: Part 1

    Excerpt from Practical Guidance
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    Denise Glagau and Kela Shang at Baker McKenzie discuss what companies must consider when offering cash awards outside of U.S. jurisdictions, and explain how some challenges associated with equity awards may be addressed with cash awards.

  • What AML Bill Could Mean For Firms, Funds And FinCEN

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    If passed, an amendment within Congress’ annual defense bill would expand the list of institutions subject to anti-money laundering regulations, from law firms to investment funds, creating potential rulemaking and enforcement challenges for the Financial Crimes Enforcement Network, say attorneys at Arnold & Porter.

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