International

  • October 15, 2021

    2010 Facebook Buy May Be Important To Transfer Pricing Trial

    Facebook's handling of its 2010 acquisition of a Malaysian firm may become more relevant as the social media giant faces off with the Internal Revenue Service over its transfer pricing practices, a U.S. Tax Court judge said in court.

  • October 15, 2021

    Ireland Shares Favorable Public Views On OECD Tax Overhaul

    Ireland's government shared public comments received as it was negotiating to join the global deal on revamping corporate taxation, showing industry groups, social justice advocates, auditing firms, banks, insurers and even two political parties had backed the push.

  • October 15, 2021

    DC Circ. Urged To Void House Panel's Bid For Trump Docs

    A subpoena from a congressional committee seeking certain financial documents from former President Donald Trump's longtime accounting firm implicates significant separation-of-powers concerns that justify voiding the request, his attorneys told the D.C. Circuit.

  • October 15, 2021

    Global Corporate Tax Deal May Create US Treaty Puzzle

    The recently agreed-upon global corporate tax overhaul requires a multilateral treaty that could face roadblocks in the U.S. if ratification depends on traditional Senate tax treaty procedures, but alternative options for implementing it bring their own uncertainties, including constitutional questions.

  • October 15, 2021

    Aussie Court Allows Proof Of Witness Conviction In Tax Case

    Three companies cannot bar Australia's tax commissioner from introducing evidence that a witness in their tax appeals was convicted of a criminal offense, the Federal Court of Australia said in declining to reconsider its prior ruling.

  • October 15, 2021

    IRS Seeks To Toss Microcaptive Firm's Request For Info

    A Tennessee federal court should toss a microcaptive insurance advisory firm's moves to find out more about how a rule imposing penalties for not following industry-specific reporting requirements was created, the Internal Revenue Service said Friday.

  • October 15, 2021

    EU Says Contract With Moderna Wasn't Aid To Tax Havens

    The European Union's purchase of vaccines from Swiss company Moderna didn't violate the bloc's prohibition on granting coronavirus pandemic aid to companies based in tax havens, according to a letter from the European Commission.

  • October 15, 2021

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service released its weekly bulletin, which included an updated list of countries with which the U.S. has bank deposit interest information exchange agreements.

  • October 15, 2021

    Man Owes $1.2M FBAR Penalty For Not Reporting 2 Accounts

    A man will pay more than $1 million for failing to report two Swiss bank accounts he maintained in the 2000s, a New York federal court has ordered.

  • October 15, 2021

    Estonia Wants To Keep VAT Deduction Limit For Company Cars

    Estonia wants to continue to allow businesses to deduct only half the value-added tax paid on cars that aren't entirely used for commercial reasons, a document submitted to the European Union's council of member states showed.

  • October 15, 2021

    Likely Next German Government Won't Raise Key Taxes

    The three parties likely to form a new government in Germany won't raise key taxes, a document endorsed by the three groups Friday showed, adding that they intend to step up the fight against tax evasion and avoidance.

  • October 14, 2021

    Australian Doc Makes Too Much For Tax Relief, Court Says

    A tax tribunal did not err in ruling a physician earned too much money to qualify for a hardship modification of his AU$1.2 million ($890,000) tax bill, the Federal Court of Australia ruled.

  • October 14, 2021

    Fixing Tax Competition Needs 30% Or Higher Rate, Study Says

    An internationally harmonized minimum corporate tax rate below 30.4% cannot advance governments' objective to reduce tax competition, given last year's mean corporate tax rate and downward pressure by outliers, according to a prominent tax scholar's study.

  • October 14, 2021

    Spain Includes 15% Minimum Tax In Budget Proposal

    Spain's executive branch proposed a 15% minimum corporate tax rate for companies with annual revenues of more than €20 million ($23.2 million), a nod to last week's international agreement on overhauling the global tax system.

  • October 14, 2021

    ECJ Says Missed Declarations Don't Negate VAT Deductions

    European Union governments must allow deductions of input value-added tax even if a filer missed a deadline for declaring whether their purchase was for personal or business use, the EU's top court ruled Thursday in joined cases involving German taxpayers.

  • October 14, 2021

    State Aid Law No Obstacle To Irish Two-Tier Tax

    European Union state aid law is unlikely to get in the way of Ireland's proposed two-tier corporate tax system, which would charge smaller companies a 12.5% rate while making bigger enterprises pay the 15% global minimum rate.

  • October 14, 2021

    ECJ Adviser Backs French Dividend Tax Law

    An adviser to Europe's highest court backed a French dividend tax law on the redistribution of profits Thursday, rejecting arguments by Schneider Electric and other major French companies that it violated a European Union statute.

  • October 14, 2021

    One In Three UK Judges Hit With Penalty Pensions Tax Rate

    A retirement savings threshold that penalizes higher earners hit more than 1,000 U.K. judges in the wallet last year, a 239% jump on the 303 who were affected in the 2016 tax year, according to data published on Thursday.

  • October 13, 2021

    Russian Scientist Tells 4th Circ. He Owes No Tax On Lab Pay

    The U.S. Tax Court was correct in determining that a Russian scientist's pay from working at a Virginia nuclear laboratory wasn't taxable because the fact the money was secured in advance made it an allowance, he told the Fourth Circuit.

  • October 13, 2021

    G-20 Finance Ministers Endorse Global Corporate Tax Pact

    The Group of 20 coalition of the world's top economic powers on Wednesday endorsed a comprehensive international corporate tax overhaul, which is expected to result in the removal of countries' digital services taxes by 2024, Italy's finance minister said.

  • October 13, 2021

    Vineyard Owner's Actions Reckless In FBAR Row, Judge Says

    The California owner of a New Zealand vineyard willfully failed to report her foreign bank accounts for 2012 and 2013, a federal court ruled Wednesday, finding she ignored clear signs that she had to file.

  • October 13, 2021

    Turkey Blocked Cyprus From Global Tax Deal, EU Confirms

    Turkey blocked Cyprus from joining an agreement on overhauling the international tax system, a top European Union official confirmed after the island nation raised sovereignty issues.

  • October 13, 2021

    Belgium Creates Flight Tax, Ends Tax Breaks For Foreigners

    Belgium will roll out a new tax on short-haul flights and close a loophole that taxes some foreign workers at a lower rate than citizens and permanent residents in an effort to balance its budget post-pandemic.

  • October 13, 2021

    UK's Digital Tax Payment Costs Small Biz $34B, Study Says

    HM Revenue & Customs' campaign to digitize its tax administration, known as Making Tax Digital, is costing small businesses £25 billion ($34.1 billion) a year in compliance, according to a business lobby's study published Wednesday.

  • October 13, 2021

    EU Official Expects Unanimous Agreement On Minimum Tax

    A leading European Union tax official said Wednesday that EU countries are likely to consent unanimously to a minimum tax proposal agreed to last week by 136 jurisdictions.

Featured Stories

  • Global Corporate Tax Deal May Create US Treaty Puzzle

    Natalie Olivo

    The recently agreed-upon global corporate tax overhaul requires a multilateral treaty that could face roadblocks in the U.S. if ratification depends on traditional Senate tax treaty procedures, but alternative options for implementing it bring their own uncertainties, including constitutional questions.

  • State Aid Law No Obstacle To Irish Two-Tier Tax

    Todd Buell

    European Union state aid law is unlikely to get in the way of Ireland's proposed two-tier corporate tax system, which would charge smaller companies a 12.5% rate while making bigger enterprises pay the 15% global minimum rate.

  • Reinsurance May Reshuffle If US Passes Int'l Tax Changes

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    International tax changes being considered by congressional Democrats and President Joe Biden's administration would increase taxes for U.S.-based insurance companies and the reinsurers they deal with overseas, forcing the question of whether they should consider restructuring those arrangements.

Expert Analysis

  • Pandora Papers Reveal Need For Greater Tax Enforcement

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    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.

  • Parsing New Int'l Tax Reporting Rules For Pass-Throughs

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    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.

  • A Look At Global Tax Enforcement Developments: Part 2

    Excerpt from Practical Guidance
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    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.

  • A Look At Global Tax Enforcement Developments: Part 1

    Excerpt from Practical Guidance
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    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.

  • EU Climate Plan Should Involve Taxing Pollution, Not Borders

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    In order to crack down on greenhouse gas emissions, the European Union proposes to levy carbon emissions at its borders and to overhaul its long-standing energy tax framework, but the latter would hold polluters directly accountable, giving it the better chance for success, says Rebecca Christie at Bruegel.

  • Prepare For Global Tax Regime's New Biz Dispute Risks

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    Companies should take steps to mitigate the business dispute risks of the new international tax framework, which over a hundred countries agreed to in July, as implementing the new regime will be expensive and require substantial organizational restructuring efforts, says Tim McCarthy at Dykema.

  • Prepare For More Audits Of Tax Info And Withholding Filings

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    Financial institutions and other corporate taxpayers should focus compliance efforts on tax information reporting and withholding, given recent indications from the Biden administration that the IRS will increase enforcement, and the administration's need to fund its infrastructure plan and other costly initiatives, say attorneys at Mayer Brown.

  • Anti-Boycott Compliance Still Key In UAE Business Dealings

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    Notwithstanding recent amendments to U.S. anti-boycott laws that reflect the United Arab Emirates' withdrawal from the Arab boycott of Israel, companies doing business in the UAE and elsewhere still need to maintain effective anti-boycott compliance programs to avoid reporting violations or penalties, says Howard Weissman at Miller Canfield.

  • 9th Circ. Adds Pressure To Reject Substance Over Form

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    The Ninth Circuit’s recent decision rejecting taxes on a family's Roth IRA payments that were made through a foreign sales corporation represents a refreshing trend among federal appeals courts to reject substance-over-form principles and instead look to congressional intent, say Lawrence Hill and Caitlin Tharp at Steptoe & Johnson.

  • 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.