International

  • June 28, 2022

    US Residency Form Accepted In Ireland For Tax Benefits

    Ireland will allow U.S. residents claiming certain tax benefits available under a treaty between the two countries to certify their residency with a form of documentation issued by the U.S. government, according to updated guidance Irish tax authorities published Tuesday.

  • June 28, 2022

    Cisco Shareholders Ask For Vote On Reporting Global Taxes

    Greater Manchester Pension Fund asked Cisco to let shareholders vote on publicly reporting workers, payroll, revenues, profits and taxes in every country in which it operates, a U.K. firm representing the pension fund told Law360 on Tuesday.

  • June 28, 2022

    Microsoft Shareholders Ask For Vote On Releasing Tax Data

    A Danish pension fund asked Microsoft to let shareholders vote on publicly reporting its workers, payroll, revenue, profits and taxes in every country where the company operates, a U.K. corporate advisory firm told Law360 on Tuesday.

  • June 28, 2022

    OECD Mulling Gov't-Only Dispute Panels, US Official Says

    The U.S. and OECD are considering how to compose review panels tasked with settling disputes under the global tax overhaul's reallocation of taxing rights given the broad support for limiting the panels to government officials, a Treasury official said Tuesday.

  • June 28, 2022

    IRS Defers Applying Some Qualified Derivative Payment Rules

    The Internal Revenue Service plans to keep some requirements for reporting what are called qualified derivative payments from taking effect until 2025, according to an agency notice published Tuesday.

  • June 28, 2022

    Denmark Asks Court To Keep $2.1B US Pension Tax Fraud Suit

    Several U.S. pension plans shouldn't be allowed to escape a suit from Denmark's tax agency claiming they committed a $2.1 billion fraud, the agency told a New York federal court, arguing the case doesn't impermissibly implicate foreign tax laws.

  • June 28, 2022

    Rising Star: Latham's Matthew Dewitz

    Latham & Watkins LLP partner Matthew Dewitz advised T-Mobile's blockbuster $59 billion merger with Sprint, Endeavor Group Holdings' acquisition of Ultimate Fighting Championship and Ortho Clinical Diagnostics in its acquisition by COVID-19 test-maker Quidel, earning him a spot among the tax attorneys under age 40 honored by Law360 as Rising Stars.

  • June 28, 2022

    IRS Gives Guidance On Seeking Superfund Tax List Changes

    The Internal Revenue Service released guidance Tuesday for requesting that a substance be added to or removed from a list of taxable substances under the reinstated Superfund chemical excise taxes.

  • June 27, 2022

    Transport Co.'s Australian Tariff Case Sent Back To Tribunal

    The Federal Court of Australia on Monday sent a dispute over tariff relief sought by a subsidiary of the multinational transportation company Alstom SA back to an administrative tribunal, saying the tribunal failed to make the necessary findings of fact.

  • June 27, 2022

    Ireland Revises Tax Guidance On Defunct Retirement Vehicles

    New tax guidance from Ireland's tax authority reflects the abolishment of a type of retirement product called an approved minimum retirement fund.

  • June 27, 2022

    Rising Star: Fried Frank's Shane C. Hoffmann

    Shane C. Hoffmann of Fried Frank Harris Shriver & Jacobson LLP has navigated the complex tax law implications of business deals for major clients in several transactions, earning him a spot among the tax law practitioners under age 40 honored as Law360 Rising Stars.

  • June 27, 2022

    Fintech Firm Wise Says CEO Being Probed By FCA

    Money transfer giant Wise announced on Monday that its chief executive, Kristo Käärmann, is being investigated by the Financial Conduct Authority after he appeared on a list of deliberate tax defaulters.

  • June 24, 2022

    Crypto Cases Attract IRS, Other Agencies, NY Prosecutor Says

    Criminal investigations in the cryptocurrency space — for example, a bitcoin probe that led to recent money laundering charges — have allure across the law enforcement spectrum, including the Internal Revenue Service, a federal prosecutor said Friday.

  • June 24, 2022

    Australia Says Crypto Not Taxable As Foreign Currency

    Australia will continue to exclude cryptocurrency from a tax on foreign currency, an official with the country's Ministry of the Treasury said.

  • June 24, 2022

    India Clarifies Exceptions To Cryptocurrency Tax

    Guidance issued by India's Central Board of Direct Taxes clarified exceptions to a withholding tax recently levied on cryptocurrency transactions.

  • June 24, 2022

    UK Adding Tie-Breaker Clause To Some Tax Treaties

    The U.K. on Friday agreed to a tie-breaker clause in its tax treaty with Jersey, ensuring that entities are taxed in the jurisdiction where they are managed — a clause it said will be applied to several other such agreements.

  • June 24, 2022

    Hong Kong Waives Fees On Biz, Individual Tax Payment Plans

    Hong Kong will waive surcharges on arrangements allowing businesses and individuals to make tax payments in installments, according to a government announcement.

  • June 24, 2022

    Taxation With Representation: Wachtell, Fenwick, Davis Polk

    In this week's Taxation With Representation, Zendesk plans to be bought by investors, Mondelēz International struck a deal to buy Clif Bar & Co., TPG will take Convey Health Solutions private, and Gurnet Point Capital and Patient Square Capital will acquire Radius Health.

  • June 24, 2022

    Canada Adds Tax On Luxury Vehicles, Introduces Tax Relief

    Federal budget measures adopted in Canada levy new taxes on luxury vehicles, among other goods, and provide tax relief to some homeowners and businesses, according to the Canadian Parliament's website.

  • June 24, 2022

    Rising Star: Cravath's Andrew T. Davis

    Andrew T. Davis of Cravath Swaine & Moore LLP has played a lead role in structuring billion-dollar acquisitions across the globe, including transactions involving companies based in Australia and the Netherlands, earning him a spot among the tax attorneys under age 40 honored by Law360 as Rising Stars.

  • June 23, 2022

    HMRC Reports £32B Lost To Tax Compliance Failures

    HM Revenue & Customs on Thursday reported £32 billion ($39 billion) lost to tax compliance failures for 2020-2021, or 5.1% of total estimated liabilities, a percentage it said was unchanged from the previous year.

  • June 23, 2022

    Int'l Task Force Seeks Input On Beneficial Ownership Guidance

    The Financial Action Task Force, a global money laundering and terrorist financing watchdog, is asking for public comments on a proposed revision of standards for the transparency and beneficial ownership of legal arrangements such as trusts, it announced Thursday.

  • June 23, 2022

    Money Laundering Watchdog Takes Malta Off Gray List

    The Financial Action Task Force removed Malta from its so-called gray list of countries lacking sufficient enforcement against money laundering and terrorist financing, according to the intergovernmental organization's website.

  • June 23, 2022

    Pandemic Sped Up Digitization Of Tax Systems, OECD Says

    The COVID-19 pandemic hastened the adoption of online tax filing and other digital services across the globe while at the same time driving down tax revenue collections, according to an Organization for Economic Cooperation and Development report published Thursday.

  • June 23, 2022

    States Progress In Training Staff On Transfer Pricing Issues

    Louisiana and other states are successfully using third-party consultants to train auditors to handle complex transfer pricing matters and administer expedited results in transfer pricing disputes, the state's revenue secretary and a consultant said.

Featured Stories

  • FDII Controversies Likely To Bubble Up This Year

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    A deduction available for foreign-derived intangible income leaves several questions up to taxpayers' judgment when it comes to calculating the benefit, which will likely lead to disputes this year in the IRS appeals process or in court, tax lawyers said.

  • The Law360 400: Tracking The Largest US Law Firms

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    As the legal market adjusted to pressures of a global pandemic and saw demand for complex legal services soar, many law firms spent 2021 locked in a fierce war for talent to meet ever-expanding client needs.

  • Will BigLaw Regret Its Hiring Spree As The Economy Softens?

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    The largest 200 law firms in the U.S. boosted their headcount by an average of 5.6% in 2021 — the steepest increase in five years, according to the Law360 400. Here's a look at what those numbers mean and where firms may be headed if the economy slows in the coming year.

Expert Analysis

  • Is NJ's Voluntary Transfer Pricing Initiative Really Voluntary?

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    The New Jersey Division of Taxation's voluntary transfer pricing audit initiative promises penalty abatement to taxpayers that elect to participate and agree to the division's proposed adjustments, but the effective penalties associated with nonparticipation raise questions about the program's voluntary nature, say attorneys at McDermott.

  • Global Tax Chiefs Should Look To US Whistleblower Programs

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    As the Joint Chiefs of Global Tax Enforcement develops its international whistleblower program to address tax evasion and money laundering schemes in new areas like cryptocurrency, it should take lessons from highly successful U.S. programs on which features to include and pitfalls to avoid, say Neil Getnick and Nico Gurian at Getnick & Getnick.

  • What Microcaptive Reporting Ruling May Mean For The IRS

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    In CIC v. Internal Revenue Service, a Tennessee federal court’s decision to set aside an IRS requirement to disclose microcaptive insurance arrangements may be a step toward evidentiary standards to show that the potential for abuse in a lawful transaction is sufficient to support heightened disclosure requirements, says Samuel Lauricia at Weston Hurd.

  • US Should Leverage Tax Rules To Deter Business With Russia

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    The U.S. should further restrict the flow of resources available for the Putin regime's war in Ukraine by denying U.S. businesses that operate in Russia or Belarus foreign tax credits and global intangible low-taxed income preferences, and by terminating its tax treaty with Russia, says Reuven Avi-Yonah at University of Michigan Law School.

  • US Investors Stand To Benefit From Brazil's New Forex Law

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    Brazil's New Foreign Exchange Law facilitates negotiations and reduces bureaucracy for foreign investments, making it a good time for U.S. investors looking for projects with a positive environmental, social and governance impact to allocate funds to Brazilian energy and infrastructure, say Jorge Kamine and Juliana Pimentel at Willkie.

  • A Landmark UK Enforcement Case For Crypto-Assets

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    HM Revenue and Customs' recent seizure of nonfungible tokens from three people under investigation for value-added tax fraud promises to be the first of many such actions against crypto-assets, so investors should preemptively resolve potential tax matters with U.K. law enforcement agencies to avoid a rude awakening, says Andrew Park at Andersen.

  • Simplifying Tax Issues For Nonresident Athletes In Canada

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    Tax compliance can be particularly challenging for nonresident professional athletes playing in Canada, but as NHL contract negotiations approach a close, it's worth looking at some ways the tax burden can be mitigated, say Marie-France Dompierre and Marc Pietro Allard at Davies Ward.

  • Steps For Universities As DOJ Shifts Foreign Influence Policy

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    Notwithstanding Wednesday's U.S. Department of Justice announcement terminating the initiative targeting Chinese influence and raising the bar for criminal prosecutions, universities should ensure their compliance controls meet new disclosure standards and that they can efficiently respond to inquiries about employees' foreign connections, say attorneys at Covington.

  • Corporate Reporting Considerations As Tax Meets ESG

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    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.

  • The Highs And Lows Of Tax Controversy In 2021

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    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.

  • Lessons From IRS For A New HMRC Whistleblowing Model

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    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.

  • The Benefits Of Competent Authority In Int'l Tax Disputes

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    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.

  • How OECD Transfer Tax Initiative Affects Smaller Businesses

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    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.