International
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April 12, 2024
Co. Suspected Of Laundering AU$1B To Enable Tax Fraud
Australian authorities seized AU$500,000 ($323,000) from an operation in Sydney suspected of laundering over AU$1 billion to facilitate tax fraud schemes, the authorities announced.
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April 12, 2024
4 Arrested In France In €60M VAT Fraud Probe
European Union prosecutors arrested four people in western France suspected of a €60 million ($63.6 million) value-added fraud scheme involving the transfer of goods and money between several countries inside and outside the bloc, the European Public Prosecutor's Office said Friday.
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April 12, 2024
Denmark's £1.4B Tax Fraud Trial Heads For 'Uncharted Waters'
Denmark will open its £1.4 billion ($1.7 billion) dividend fraud case in London on Monday, beginning a yearlong trial that will have wide implications for other disputes arising out of the cum-ex trading scandal that has swept Europe.
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April 12, 2024
Taxation With Representation: Freshfields, Kirkland & Ellis
In this week's Taxation with Representation, eBay acquires Collectors' Goldin auction house, Vertex Pharmaceuticals buys Alpine Immune Sciences, Vista Equity Partners purchases Model N and Tradeweb Markets buys Institutional Cash Distributors.
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April 12, 2024
Countries Late On Pillar 2 Need To Catch Up, EU Official Says
Countries within the European Union that are late implementing the global minimum tax rules need to do so soon, an official with the European Commission said Friday, adding that countries failing to do so could face fines.
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April 11, 2024
BlackRock Can't Deduct Interest On $4B, London Court Finds
Financial services firm BlackRock cannot deduct interest on $4 billion in loans it used for the 2009 purchase of Barclays Global Investors because avoiding taxes was the main reason for the way it structured the transaction, a London appeals court ruled Thursday.
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April 11, 2024
France's Anti-Money Laundering Reports Up 15% In 2023
France's anti-money laundering unit received 15% more reports of suspicious financial transactions in 2023 compared with 2022, continuing a trend that has resulted in a seven-fold increase in such reports over the past decade, the country's finance ministry said Thursday.
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April 11, 2024
Int'l Salesman Stuck With FBAR Fines For Swiss Account
An agricultural salesman earning money in Ukraine willfully hid a Swiss bank account from the IRS that neither his accountant nor his wife knew about, a Nebraska federal judge said Thursday in upholding more than $600,000 in reporting penalties against him.
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April 11, 2024
Tax Controversy Quintet Joins Bradley Arant In Atlanta
Bradley Arant Boult Cummings LLP announced that it hired a five-person tax controversy team from Chamberlain Hrdlicka White Williams & Aughtry highlighted by the addition of three experienced partners, including two former Internal Revenue Service trial attorneys.
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April 11, 2024
Proskauer Adds Kirkland Partner For Tax, Estate Issues
Proskauer Rose LLP has added to its private client services department a partner from Kirkland & Ellis LLP who specializes in developing domestic and international tax and estate plans for clients with very high net worth, the firm announced.
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April 11, 2024
Australia Considering Build-To-Rent Tax Break Increases
Australia is seeking public input on a plan to increase tax breaks for builders constructing rental properties in the country while also introducing conditions to qualify for those breaks.
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April 11, 2024
Swiss Bank Probe May Prompt IRS To Revive Disclosure Effort
Senate Finance Committee Chairman Ron Wyden's latest investigation into the Swiss banking industry may apply further pressure to federal law enforcement officials to revive a program designed to encourage taxpayers' voluntary compliance in disclosing income held overseas to the IRS.
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April 11, 2024
EU Parliament Advances Small Biz Single File Tax Plan
Small businesses in the European Union would be able to file a single tax return with the administration of the business' head office instead of with every member country where the entity operates under a proposal approved by the European Parliament.
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April 11, 2024
Adviser Urges ECJ To Annul Nix Of UK's CFC Tax Breaks
The European Union's General Court erred by relying on controlled foreign company rules in Great Britain when it found that U.K. corporate tax breaks were illegal, an adviser to the bloc's highest court said Thursday in urging the reversal of that ruling.
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April 11, 2024
OECD Plans More Guidance On Global Min. Tax, Official Says
The Organization for Economic Cooperation and Development will issue further guidance on the global minimum corporate tax, a top official from the organization said Thursday, and another official defended a backstop provision of the minimum tax.
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April 10, 2024
Plastic Surgeon Owes $7.7M From Offshore Scheme, US Says
A now-retired plastic surgeon owes the Internal Revenue Service more than $7.7 million after he ran an offshore employee leasing scheme and he and his wife transferred nearly all their assets to their then-11-year-old daughter, who is now a lawyer, the government told an Ohio federal court.
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April 10, 2024
Australia's Tax Office Seeks Input On Risk-Weighted Assets
The Australian Taxation Office is seeking comments on a paper about how it measures the risk-weighted assets of a foreign bank's Australian branch when applying thin capitalization rules, the ATO announced.
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April 10, 2024
EU Parliament Wants Transfer Pricing Rules To Apply Sooner
The European Parliament voted Wednesday to adopt new transfer pricing rules that would take effect one year earlier than previously planned, sending the proposal to the European Union's council of member countries for consideration.
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April 10, 2024
IRS' DOJ Referral Rules 'A Disaster,' Sen. Whitehouse Says
The IRS protocols for referring cases to the U.S. Department of Justice are "a disaster" for enforcing laws against bankers and other actors who help U.S. taxpayers evade taxes, Sen. Sheldon Whitehouse said Wednesday during a hearing on offshore tax evasion before the Senate Budget Committee.
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April 10, 2024
Belgium's Anticipated Green Tax Break Carries Some Doubts
A proposal working its way through the Belgian Parliament would create opportunities for investors in green and sustainable technologies, but questions about the long-term durability of the measure, which would offer an expanded deduction for such investments, could weigh on its popularity and effectiveness.
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April 10, 2024
EU Gave €46B In State Aid As Tax Breaks In 2022
European Union countries gave their companies tax breaks worth about €46 billion ($49.4 billion) in state aid in 2022, some to weather the fallout from the Ukraine war and the COVID-19 pandemic and other aid to promote infrastructure projects or environmental protection, a European Commission report said.
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April 09, 2024
Treasury Proposes Long-Awaited Stock Buyback Tax Rules
The U.S. Treasury Department proposed a pair of long-awaited rules Tuesday that detail the calculation and reporting of a new excise tax assessed to publicly traded corporations that recently bought back their own shares of stock on the open market.
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April 09, 2024
Healthcare Co. Can't Sue Ex-Exec For Causing Canada Tax Hit
A Colorado federal judge shot down a pharmacy automation company's suit alleging its former chief commercial officer cost it nearly CA$1.2 million ($907,000) in Canadian taxes by not telling his employer he had moved out of the country, saying the company hasn't shown it suffered any damage as a result.
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April 09, 2024
Poland Adopts Digital Platform Reporting Rules
Poland's Council of Ministers approved a measure Tuesday implementing the European Union's tax information reporting procedures for digital platform operators, known as DAC7, the country's tax authority said.
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April 09, 2024
UK Court Affirms Sweet VAT Ruling For Jumbo Marshmallows
Jumbo-size marshmallows are not candy like regular marshmallows because they're meant to be roasted, so they qualify for a value-added tax exemption for food, the U.K. Upper Tribunal ruled in upholding a lower court's findings.
Expert Analysis
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Corporate Reporting Considerations As Tax Meets ESG
With the U.S. Securities and Exchange Commission filing season upon us amid increasing pressure for greater transparency around effective tax rates and tax strategies, multinational companies must decide how they will approach voluntary tax reporting and prepare their responses if they want to control the narrative, say Michael Lebovitz and Jenny Austin at Mayer Brown.
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The Highs And Lows Of Tax Controversy In 2021
Lawrence Hill at Steptoe & Johnson reviews the ups and downs of tax controversy practice in 2021, including the continued effects of the pandemic, troubling decisions on attorney-client privilege and an IRS comeback on transfer pricing.
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Lessons From IRS For A New HMRC Whistleblowing Model
Andrew Park at Andersen considers whether the public interest would be better served in allowing the U.K.'s tax enforcers, HM Revenue & Customs, to offer larger and more certain cash incentives to people blowing the whistle on tax misdemeanors — similar to the IRS model for whistleblowers.
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The Benefits Of Competent Authority In Int'l Tax Disputes
Multinational enterprises seeking relief from double taxation in a changing international tax landscape should consider utilizing the competent authority process, which provides both taxpayers and domestic tax regulators an efficient and effective means of dispute resolution, say David Farhat and Eman Cuyler at Skadden.
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How OECD Transfer Tax Initiative Affects Smaller Businesses
Small and midsize enterprises with cross-border transactions need to consider redefining tax strategies and operational models in light of the Organization for Economic Cooperation and Development's base erosion and profit shifting initiative, even though the agency's new tax guidelines are aimed at large multinational enterprises, says Ganesh Ramaswamy at Kreston Rangamani.
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What The New OECD Double-Tax Procedure Statistics Tell Us
Monique van Herksen and Clive Jie-A-Joen at Simmons & Simmons consider the Organization for Economic Cooperation and Development’s recent report on double taxation cases resolved in 2020 under the mutual agreement procedure process, and examine whether the process has improved dispute resolution mechanisms since its implementation five years ago.
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Navigating FCPA Risks Of Minority-Owned Joint Ventures
The U.S. Department of Justice and U.S. Securities and Exchange Commission will likely continue to focus on third-party risks under the Foreign Corrupt Practices Act, so companies with minority-owned joint ventures should take several steps to mitigate related compliance challenges, say Ben Kimberley at The Clorox Company and Addison Thompson at Covington.
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Questions To Ask If Doing Business In A Corruption Hot Spot
Businesses facing new scrutiny after the U.S. Department of Justice's recently announced task force for combating human trafficking in Central America, the release of the Pandora Papers and continuing fallout from 2019's Panama Papers, should address compliance risks by having employees ask three questions about every transaction, say attorneys at White & Case.
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How The Global Tax Agreement Could Backfire For Biden
If the $3.5 trillion spending package fails, the federal tax code will not conform to the recent 15% global minimum tax agreement spearheaded by the U.S., which would embarrass the Biden administration and could lead to retaliatory tax measures by other nations, says Alex Parker at Capitol Counsel.
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Pandora Papers Reveal Need For Greater Tax Enforcement
The recent Pandora Papers leak is a reminder of the importance of transparency laws and proper funding for enforcement efforts against tax evasion as bad actors increasingly operate in the shadows, says Daren Firestone and Kevin Crenny at Levy Firestone.
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Parsing New Int'l Tax Reporting Rules For Pass-Throughs
Attorneys at Grant Thornton unpack the Internal Revenue Service’s new pass-through entity reporting requirements for international tax matters and the accompanying guidance for penalty relief, and suggest how companies should prepare for what may be the most significant change to the partnership compliance function in decades.
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A Look At Global Tax Enforcement Developments: Part 2
Excerpt from Practical Guidance
Sean Craig at LexisNexis examines recent investigations by the Joint Chiefs of Global Tax Enforcement and their impact on U.S. taxpayers, as well as the growing significance of transfer pricing disputes and policies for future enforcement.
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A Look At Global Tax Enforcement Developments: Part 1
Excerpt from Practical Guidance
Sean Craig at LexisNexis looks at how international initiatives, such as the Joint Chiefs of Global Tax Enforcement, are addressing cryptocurrency-related tax evasion, and how the COVID-19 pandemic and increasing demands for governmental welfare programs are driving global tax policy.