International
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March 26, 2024
Decision Postponed On EU Withholding Tax Proposal
An attempt by European Union finance ministers to agree on a new withholding tax refund law has been postponed from their meeting on April 12, an agenda published Tuesday showed.
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March 25, 2024
Philippines Plastic Bag Tax Would Generate $560M, Gov't Says
A proposed weight-based tax on single-use plastic bags would catch the Philippines up with major economies and generate an estimated 31.52 billion Philippine pesos ($560 million) in its first three years, the country's Department of Finance said Monday.
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March 25, 2024
Nigeria Charges Binance With Tax Evasion, Says Exec Fled
Nigeria's tax authority filed criminal tax evasion charges against Binance, one of the world's largest cryptocurrency exchanges, and two of its executives, one of whom escaped custody Monday, according to state-owned media.
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March 25, 2024
€92M Cross-Border Fuel VAT Fraud Case Under Investigation
Authorities are investigating three Italian citizens based around the world for their roles in a value-added tax fraud scheme involving oil sales that led to an estimated €92 million ($99.7 million) in damages, the European Public Prosecutor's Office said Monday.
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March 25, 2024
Offshore Payments Aren't Taxable Services, UK Court Rules
Two U.K. residents aren't liable for taxes tied to certain payments from an affiliated offshore company to a third-party foreign corporation, a British appeals court ruled Monday, finding the underlying transactions didn't amount to services that would trigger taxation.
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March 25, 2024
EU Court Asked To Rule On VAT On Transfer Pricing Payment
A Romanian appellate court asked the European Union's Court of Justice to rule on whether payments to a Belgian parent company from a Romanian associated company to align profits under OECD transfer pricing guidelines fall within the scope of value-added tax, a document published Monday showed.
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March 25, 2024
PwC Australia Hires New Chief People Officer Amid Scandal
PwC Australia hired a new chief people officer as part of the firm's plan to rebuild trust following its scandal involving the leak of Australian government documents, the firm announced Monday.
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March 25, 2024
EU Report Praises Dutch Efforts To Stop Tax Avoidance
Recent efforts in the Netherlands to tackle corporate tax avoidance are working, according to a report from the European Commission published Monday, which added that a new measure taking effect this year would help make the Netherlands less attractive for tax avoidance practices.
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March 22, 2024
Businessman Indicted Over Hiding Of $20M In Swiss Accounts
A Brazilian-American businessman accused by the government in a criminal complaint of hiding $20 million from the Internal Revenue Service over 35 years by using Swiss bank accounts was indicted by a federal grand jury in Miami and charged with tax evasion, according to a Florida federal court.
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March 22, 2024
UN Needs To Clarify Path For Tax Framework, Dutch Say
The United Nations' ad hoc committee tasked with determining a global tax framework must clarify the goals of its project "as soon as possible," the Netherlands' government said in a letter that included suggestions on how the body could proceed.
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March 22, 2024
Holland & Knight Hires Caplin & Drysdale Member In DC
Holland & Knight LLP has boosted its Washington-based tax team, hiring a Caplin & Drysdale Chtd. member who first joined his former firm 25 years ago from the U.S. Department of the Treasury.
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March 22, 2024
EU Leaders OK Sending Russian Assets' Revenue To Ukraine
European Union leaders expressed support for a proposal to transfer the net income from frozen and immobilized Russian state assets to EU funds for rebuilding Ukraine and buying arms for that country, according to a statement issued Friday.
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March 22, 2024
UK Tax Avoidance Scheme Promoter Fined £900K
A Liverpool-based company that promoted a tax avoidance scheme to medical professionals must pay a £900,000 ($1.1 million) penalty, according to a tribunal ruling published by HM Revenue and Customs on Friday.
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March 22, 2024
US Unlikely To Move On Hungary Tax Treaty, Official Says
Hungary's low corporate tax rate and other policies will likely prevent the U.S. government from resuming negotiations on a stalled 2010 tax treaty after terminating its existing Hungarian treaty in early 2023, an IRS official said Friday.
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March 22, 2024
UK Seeking Feedback On 2027 Carbon Border Tax Plan
HM Revenue & Customs and HM Treasury are seeking feedback on the U.K.'s plan to introduce a carbon border tax on certain carbon-intensive imports by 2027.
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March 22, 2024
EU Leaders Seek Limited Tax Revamp To Boost Capital Market
European Union leaders urged all bloc policymakers Friday to pursue a plan to improve business financing, including a targeted makeover of the tax systems in the member countries regarding corporate taxes, capital gains and tax breaks for interest payments.
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March 21, 2024
Treasury Hoping Pillar 2 Guidance Favors R&D Tax Credits
The U.S. Treasury Department is looking for future administrative guidance on the international minimum tax agreement known as Pillar Two to give favorable treatment to U.S. research and development tax credits, but it will likely come with guardrails, a Treasury official said Thursday.
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March 21, 2024
GoDaddy Can't Block Transfer Of $4 Million Set Aside For VAT
A consortium that sold shares of an internet company to GoDaddy.com can receive a $4 million transfer of escrow funds that GoDaddy claimed were instead needed to pay value-added tax on the share sale, a Dutch court ruled.
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March 21, 2024
UN Could Enhance Global Tax Agenda Setting, Officials Say
The United Nations could play an important role in shaping the agenda for global tax negotiations so it better reflects the priorities and concerns of developing countries, a variety of tax officials said Thursday during a conference.
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March 21, 2024
IRS Proposes Exceptions For 3rd-Party Summons Notices
The IRS proposed rules Thursday that would allow some exceptions to a requirement that the agency notify taxpayers within 45 days before issuing summonses to third parties in tax assessment and collection cases, including for certain time-sensitive examinations.
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March 21, 2024
EU Countries Bash Deal On Duty-Free Imports From Ukraine
Several European Union countries objected to the agreement among EU lawmakers to extend the suspension of the bloc's custom duties and quotas on Ukrainian imports, criticizing a lack of caps on agricultural products.
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March 21, 2024
Australia Seeking Input On Global Minimum Tax Bills
Australia's Treasury is seeking public feedback on three draft bills published Thursday that would implement the Organization for Economic Cooperation and Development's global corporate minimum tax.
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March 21, 2024
Wyden Probes Swiss Bank's Ties To Billionaire Under Scrutiny
The Senate Finance Committee's Democratic majority launched an inquiry into Swiss bank Pictet Group's involvement with a U.S. billionaire under criminal investigation, raising questions about the bank's deferred prosecution agreement and $123 million fine by the U.S. Justice Department, committee Chairman Ron Wyden announced Thursday.
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March 21, 2024
Quintairos Prieto Taps Atlanta Atty To Lead New Tax Group
Quintairos Prieto Wood & Boyer PA said it had created a tax division that will be led by an Atlanta-based partner who has guided clients on civil and criminal tax law, reinforcing its national expertise in litigation, regulatory and corporate law matters.
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March 21, 2024
€58M VAT Toner Fraud Case Lands Four Convictions In Italy
Four people were convicted in Italy for their roles in a value-added tax fraud scheme involving printer toner and other office supplies that resulted in €58 million ($63 million) in illicit profits, the European Public Prosecutor's Office said.
Expert Analysis
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2 Tax Decisions Hold Key Transfer Pricing Takeaways
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.
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Digital Taxation Is Necessary, But Tough To Manage
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.
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Company Considerations For Cash Award Incentives: Part 2
Excerpt from Practical Guidance
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.
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Company Considerations For Cash Award Incentives: Part 1
Excerpt from Practical Guidance
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.
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What AML Bill Could Mean For Firms, Funds And FinCEN
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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Unpacking The New Stock Buyback Tax And Its Exceptions
Xenia Garofalo and Kyle Colonna at Eversheds Sutherland discuss provisions of the recently enacted tax on corporate stock repurchases, how its exceptions may be applied and what companies should consider when evaluating the cost of new or existing programs.
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Inside The OECD Transfer Pricing Documentation Guidance
Excerpt from Practical Guidance
The Organization for Economic Cooperation and Development's recently modified documentation guidelines can assist tax administrations in developing requirements for transfer pricing risk assessments and evaluations, and help multinational entity taxpayers demonstrate satisfaction of the arm's-length principle, says Neil Aragones at Lexis Tax.
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A Close Look At The Decentralized Effort To Tax Digital Assets
Clarity on taxation is one of the biggest hurdles to mass adoption of cryptocurrency, and although digital asset innovation has consistently outpaced worldwide government regulation, recent efforts in the U.S. and elsewhere hint at an emerging standard, says Joshua Smeltzer at Gray Reed.
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Key Takeaways From IRS Reversal On FDII Stance
The Internal Revenue Service's recent memo regarding allocation of deferred compensation expenses for purposes of foreign-derived intangible income is a departure from the agency's previous position and may have implications beyond the context of deferred compensation, say attorneys at Miller & Chevalier.
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New Tax Decree Suggests Expansion In Dutch Transfer Pricing
A July 1 decree from Dutch tax authorities updating transfer pricing guidance heralds a major change in how intercompany financial transactions are considered for transfer pricing purposes and forebodes significant audit activity, say Monique van Herksen and Clive Jie-A-Joen at Simmons and Simmons.
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Is NJ's Voluntary Transfer Pricing Initiative Really Voluntary?
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.
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Global Tax Chiefs Should Look To US Whistleblower Programs
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.
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What Microcaptive Reporting Ruling May Mean For The IRS
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.