International

  • July 23, 2021

    Costa Rica Adds Digital Service Cos. To Cross-Border VAT List

    Costa Rica's Ministry of Finance announced the country added 48 entities to its list of digital companies that are subject to its 13% value-added tax on cross-border services beginning Friday.

  • July 23, 2021

    Narrow Path Paved For Tax Rule Challenges After CIC Services

    The U.S. Supreme Court's revival of a company's case disputing an Internal Revenue Service information reporting requirement for microcaptive insurance arrangements likely won't lead to a barrage of pre-enforcement suits challenging complicated international tax rules, tax specialists said.

  • July 23, 2021

    Exam Presence Alters IRS Appeals Process, Retired Atty Says

    The expanded involvement of examiners in cases before the Internal Revenue Service Office of Appeals is changing the nature of the appeals process, and not for the better, according to a recently retired attorney.

  • July 23, 2021

    UK Court Rejects Claims For Trust Deeds In Tax Dodge Case

    A U.K. court on Friday rejected claims by two health care companies and an individual who sought to recover deeds and their contributions to a trust involved in a tax avoidance scheme, according to a judgment that found they lacked evidence to support their claims.

  • July 23, 2021

    IRS Not Obliged To Impose Foreign Co. Penalty Against Spouses

    While penalties can be assessed against the spouses of people with filing requirements related to foreign corporations and partnerships, the IRS is not required to assess those penalties, the agency's Office of Chief Counsel said in an email released Friday.

  • July 23, 2021

    Canada Court Says Sports Charities Entitled To Tax Breaks

    Canada's revenue agency was wrong to deny tax advantages to two charities serving amateur athletes because the foundations' activities were strictly financial and didn't entail provision of training facilities or nationwide promotion of sports, an appeals court ruled.

  • July 23, 2021

    Bahamas High Court Nixes Freeze Of Fraud Convict's Assets

    The Bahamas' Supreme Court overturned its attorney general's freeze on assets held by a man convicted of tax fraud and other crimes in Milan, according to court filings.

  • July 23, 2021

    Singapore's Bank Chief Floats Wealth Tax To Tackle Inequality

    Singapore's central bank chief said a wealth tax on property gains or inheritance might make sense for the country to address inequality.

  • July 23, 2021

    Singapore-Indonesia Double Taxation Treaty Enters Into Force

    A treaty between Singapore and Indonesia meant to eliminate double taxation that also lowers withholding tax rates and exempts some capital gains entered into force Friday, according to government announcements.

  • July 23, 2021

    HMRC Wins Time Cap In Split Ruling In Foreign Unit Tax Fight

    Britain's highest court handed a win on Friday to both sides in long-running litigation over the unlawful tax treatment of dividends, preventing HMRC from lowering its bill by offsetting credits that it has already paid out and imposing a limitation period on the interest claimed by the companies.

  • July 23, 2021

    No Need For UK Law On Risky Tax Strategies, Tax Pros Say

    The goal of new regulations requiring businesses to inform HM Revenue & Customs when they believe their tax strategy may be rejected by courts could have been achieved without creating new legislation, an association of tax professionals said.

  • July 22, 2021

    Repatriation Tax Is Constitutional, US Gov't Tells 9th Circ.

    The U.S. government on Thursday urged the Ninth Circuit to not revive a couple's challenge against the 2017 federal tax overhaul's repatriation provision, arguing the pair has mischaracterized the levy on foreign income as an unconstitutional direct tax on property.

  • July 22, 2021

    McDermott Adds Tax Partners From Baker McKenzie, DLA Piper

    McDermott Will & Emery LLP has added partners from Baker McKenzie and DLA Piper to its Boston and Chicago offices to advise clients on international tax matters, the firm announced Thursday.

  • July 22, 2021

    11th Circ. Won't Revisit Decision On Maximum FBAR Penalty

    The Eleventh Circuit won't reconsider its decision that a naturalized citizen is liable for penalties from failing to report foreign bank accounts to the Internal Revenue Service, according to an order filed Thursday.

  • July 22, 2021

    Gov't Sues To Collect Willful FBAR Penalties From Floridian

    A Florida resident should have known about the requirement to report his offshore bank accounts to the Internal Revenue Service, U.S. government attorneys told a Miami federal court, contending he should hand over unpaid penalties for late filings.

  • July 22, 2021

    EU Appeals Ruling Amazon Didn't Receive Illegal State Aid

    The European Union's executive branch on Thursday asked the European Court of Justice to overturn a ruling by the EU General Court that the £250 million ($294 million) in tax breaks Amazon received from Luxembourg didn't constitute illegal state aid.

  • July 22, 2021

    Exxon Entitled To $1B Refund On Foreign Sales, 5th Circ. Told

    Exxon Mobil Corp. is entitled to a $1.3 billion refund from the Internal Revenue Service because the agency misclassified some of its transactions in Qatar and Malaysia as mineral leases and not sales, the company told the Fifth Circuit.

  • July 22, 2021

    UK Threatens To Withdraw From Northern Ireland Brexit Deal

    British Prime Minister Boris Johnson on Thursday asked the president of the European Commission to look seriously at the U.K.'s proposal to alter the agreement governing trade between the British mainland and its province of Northern Ireland after Brexit.

  • July 22, 2021

    US-Based Multinationals' Dividend Income Fell 31% In 2020

    Multinational corporations based in the U.S. saw a 31% drop in dividend income repatriated to their home country in 2020 from the previous year, reflecting a 13% decline in all profits earned abroad, according to government data released Thursday.

  • July 22, 2021

    UK Urged To Opt For Income Tax Hike To Fund Social Care

    The British government should not raise its social security tax to extend social care for its aging population, but should instead raise income tax, according to a policy note published by a left-leaning think tank.

  • July 21, 2021

    Treasury Official Says OECD Tax Deal Will Help Biz, Public

    U.S.-based multinational corporations and the public stand to benefit from the deal to rewrite global tax rules because it will help stabilize economic globalization after years of protectionist policies, a senior U.S. Treasury Department official said Wednesday.

  • July 21, 2021

    Biden's Tax Plan Hits Cos. Harder Than OECD's, Study Finds

    President Joe Biden's tax proposals would result in U.S. multinationals paying significantly more at home and abroad compared to the Organization for Economic Cooperation and Development's tax plan, according to a study from the Penn Wharton Budget Model published Wednesday.

  • July 21, 2021

    Ireland Seeks Input, Vows Engagement On OECD Tax Revamp

    Ireland is seeking public comments on the recent deal for a 15% global minimum corporate tax rate, with the government promising constructive engagement in ongoing OECD-led talks despite the country's stated objections and outlier status.

  • July 21, 2021

    IRS Won't Be 'Naive' In Virus Pricing Reviews, Official Says

    The Internal Revenue Service will take a pragmatic approach when reviewing whether multinational corporations priced their intercompany transactions at arm's length during the coronavirus pandemic, but the agency won't be "naive" about any opportunism, an IRS official said Wednesday.

  • July 21, 2021

    UK Needs Tax Guidance Before New Reporting Law, Org Says

    HM Revenue & Customs should issue guidance on existing tax laws before it proposes to implement new reporting requirements on large businesses with uncertain tax positions, an executive for a body representing British tax professionals told Law360 on Wednesday.

Featured Stories

  • Narrow Path Paved For Tax Rule Challenges After CIC Services

    No Photo Available

    The U.S. Supreme Court's revival of a company's case disputing an Internal Revenue Service information reporting requirement for microcaptive insurance arrangements likely won't lead to a barrage of pre-enforcement suits challenging complicated international tax rules, tax specialists said.

  • Exam Presence Alters IRS Appeals Process, Retired Atty Says

    Molly Moses

    The expanded involvement of examiners in cases before the Internal Revenue Service Office of Appeals is changing the nature of the appeals process, and not for the better, according to a recently retired attorney.

  • Retired Transfer Pricing Attorney Bemoans Long Delays In Cases

    Molly Moses

    The time needed for audits, trials and settlements in transfer pricing and other large tax cases against the IRS sometimes means companies wait decades for a resolution, according to an attorney who spent much of his career litigating those cases.

Expert Analysis

  • Will The OECD Plan Fix International Taxation?

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    Lilian Faulhaber at Georgetown Law breaks down the Organization for Economic Cooperation and Development’s plan for international tax reform, recently joined by 130 countries, and whether it will solve the problems it was designed to address, including the need for multinational companies to pay their fair share of taxes in the digitized world economy.

  • What Biden's Tax Proposals May Mean For Int'l Private Clients

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    Jennifer Wioncek and Paul D’Alessandro at Bilzin Sumberg discuss the U.S. Department of the Treasury's recently released explanation of the Biden administration's tax proposals and how the changes would affect income and wealth transfer planning for international private clients.

  • What Crypto Holders Can Learn From Early-2000s Tax Scandal

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    The Internal Revenue Service’s recent push to gather information about cryptocurrency accounts is similar to its Swiss bank account investigations of the early 2000s, which should prompt taxpayers to consider voluntarily disclosing transactions before they are individually targeted for enforcement, say Timothy Wagner and Thomas Barnard at Baker Donelson.

  • International Tax Reform's Implications For Transfer Pricing

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    As the Organization for Economic Cooperation and Development overhauls the global tax rules on base erosion and profit shifting, and the Biden administration rolls out new U.S. tax proposals, multinational enterprises need to prepare for the effects of these tax changes on their transfer pricing structures, say Mandy Li and Shuang Feng at MGO.

  • Justices' Preemptive Tax Challenge Ruling Shows Divisions

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    The U.S. Supreme Court's recent decision in CIC Services v. Internal Revenue Service reveals divisions among the justices about when potentially burdensome tax regulations can be challenged, making the holding less clear and less valuable, say George Isaacson and David Swetnam-Burland at Brann & Isaacson.

  • Takeaways From 2 New FBAR Rulings

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    In light of two recent California federal court decisions, capping penalties for nonwillful violations of foreign bank account reporting but broadening the willfulness standard, U.S. taxpayers must be vigilant about understanding their reporting obligations, and prepare for the Internal Revenue Service to target willful conduct, which yields much higher penalties, say Friedemann Thomma and Marianna Felshtiner at Venable.

  • El Salvador's Use Of Bitcoin Complicates US Commercial Law

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    El Salvador recently became the first country to recognize Bitcoin as currency, presenting significant implications for U.S. commercial law as the development will likely trigger the cryptocurrency to now fall within the definition of "money" under the Uniform Commercial Code, say Joe Carlasare and Eric Fogel at SmithAmundsen.

  • Justices' Nod To Preemptive Tax Challenges May Caution IRS

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    The U.S. Supreme Court's recent decision in CIC Services v. Internal Revenue Service, allowing pre-enforcement challenges of tax reporting rules despite the Anti-Injunction Act, is likely to make the U.S. Department of the Treasury more careful about its own compliance obligations under the Administrative Procedure Act, says Robert Carney at Caplin & Drysdale.

  • Let's End The Offshoring Of US Patents

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    Congress should work toward removing the loophole that allows companies to avoid U.S. taxes by moving their patents offshore, and ensure profits are taxed where the sales take place, says Sen. Patrick Leahy, D-Vt.

  • Long Road Ahead For Biden's Individual Tax Hike Proposal

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    Dustin Stamper at Grant Thornton provides insight into President Joe Biden's recently proposed individual tax increases to pay for his American Families Plan, and explains how competing interests among congressional Democrats and Republicans may shape the final provisions and prolong their implementation.

  • What Value-Added Tax Might Look Like In The US

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    Christiaan Van Der Valk and Charles Maniace at Sovos consider the value-added tax, a primary source of revenue for many countries, and what it might mean for the U.S. were it implemented to raise funds for large-scale federal initiatives such as President Joe Biden's infrastructure plan.

  • US Needs Better, Nonpunitive Approach To Greening Trade

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    Instead of imposing tariffs on goods produced where foreign governments have assisted in cleaning up the environment, the U.S. should make trade policy green by helping industries reduce their environmental impact and encouraging every foreign government to do the same, say Elliot Feldman and Michael Snarr at BakerHostetler.

  • What OECD Scrutiny Means For Anti-Corruption In Brazil

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    Attorneys at Paul Hastings examine how an unprecedented standing subgroup recently created by the Organization for Economic Cooperation and Development to monitor Brazil's anti-corruption efforts reflects significant uncertainty regarding the country's commitment to enforcement, and what companies can do to address foreign bribery risk and strengthen compliance programs.