International
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March 21, 2024
PwC Still Withholding Names Of Aussie Leak Recipients
PwC is continuing to refuse to name the six recipients of confidential drafts of Australian tax laws despite repeated requests from the country's government, the firm said in documents published Thursday.
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March 21, 2024
HSBC Settles Investors' £240M Claim Over Disney Tax Scheme
HSBC has settled a £240 million ($304 million) claim brought by more than 100 investors alleging that the bank misled them to finance a Disney film tax relief scheme it developed which turned out to be worthless.
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March 21, 2024
UK Insurance Tax Bill Rises To £8.1B Amid Soaring Premiums
The Insurance Premium Tax raised more than £8.1 billion ($10.3 billion) so far this financial year, according to official figures Thursday, while premiums continue to rise.
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March 21, 2024
ECJ Adviser Rejects Taxing Foreign Pension Funds Differently
Taxing dividends paid to foreign public pension funds while exempting dividends paid to the source country's general retirement savings funds contravenes European Union law, an adviser to the bloc's highest court said Thursday, backing Finnish pension funds' challenge of a Swedish law.
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March 20, 2024
IRS Releases Foreign Housing Expense Limits For 2024
The Internal Revenue Service released adjustments to the limitation on foreign housing expense deductions and exclusions for 2024 on Wednesday.
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March 20, 2024
EU Proposes Sending Russian Assets' Revenue To Ukraine
The European Commission proposed on Wednesday transferring the net income from frozen and immobilized Russian state assets to European Union funds for rebuilding Ukraine and buying arms for that country.
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March 20, 2024
How The Supreme Court Could Narrow Chevron
After hours of oral argument in a closely watched administrative law case, it appeared that some U.S. Supreme Court justices could be open to limiting the opportunities for lower courts to defer to federal agencies' legal interpretations in disputes over rulemaking — and legal experts said there are a number of ways they could do it.
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March 20, 2024
OECD Reports More Compliance With Tax Treaty Standards
The Organization for Economic Cooperation and Development reported Wednesday that members of the group's inclusive framework — countries that have agreed to adopt minimum standards of an international anti-base erosion plan — have increased their compliance with the standard intended to prevent treaty shopping.
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March 20, 2024
IRS Withholding Docs On Partnership Audits, Baker Atty Says
The Internal Revenue Service has not responded to a request for documents pertaining to the agency's scrutiny of large partnerships and should be forced to disclose them, an attorney with Baker McKenzie told a D.C. federal court.
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March 20, 2024
EU Floats Alternative To Unanimity As Bloc Eyes Growth
The European Commission floated an alternative Wednesday to unanimity voting on matters such as tax as it seeks to streamline the way the bloc reaches decisions amid talk of expanding the number of EU countries.
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March 20, 2024
IRS Grants Income Exclusion To Those Fleeing 6 Countries
Individuals who fled conditions in Ukraine, Belarus, Sudan, Haiti, Niger and Iraq after specific dates in 2023 can exclude foreign earned income, and can exclude or deduct housing costs, from gross income that year because of adverse conditions in the countries, the IRS said.
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March 20, 2024
Law360 Announces The Members Of Its 2024 Editorial Boards
Law360 is pleased to announce the formation of its 2024 Editorial Advisory Boards.
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March 20, 2024
King & Spalding Adds Ex-PwC Tax Pro As Partner In NY
An experienced tax attorney has joined King & Spalding LLP in New York after working at PricewaterhouseCoopers LLP for six years.
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March 20, 2024
HMRC Makes U-Turn On Helpline Cuts After Backlash
The U.K. tax authority backtracked Wednesday on plans to close down several helplines for taxpayers from April through September after facing criticism from politicians and industry groups.
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March 19, 2024
UN Experts Aim To Finalize Tool For Model Treaty Updates
The United Nations' tax committee is aiming this week to finalize a tool to facilitate faster adoption of updates to its model tax treaty within bilateral negotiations, although some members remain skeptical about its usefulness, according to discussions Tuesday.
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March 19, 2024
GILTI Figures Into CFC Applicability Project, Official Says
The U.S. global intangible low-taxed income system is factoring into continuing Internal Revenue Service work on whether a tax code provision limiting corporations from offsetting income with net operating or other tax losses after ownership changes applies to controlled foreign corporations, an agency official said Tuesday.
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March 19, 2024
Pakistan Enlists Nonprofit To Boost Digital Tax Administration
Pakistan's tax authority said it is partnering with a nonprofit focused on business financing to help the government better understand businesses' needs as it works to improve online tax administration tools.
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March 19, 2024
OECD Deputy Tax Director To Leave Post In June
A deputy tax director for the Organization for Economic Cooperation and Development announced he is stepping down from his position at the end of June after nearly a decade there working on international tax policy.
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March 19, 2024
Exxon Wants Closed Court In $1.8B Tax Trial
Exxon Mobil plans to seek courtroom closures for parts of an upcoming trial in its $1.8 billion suit challenging denied tax deductions for payments it made to Qatar, telling a Texas federal court that certain testimony, if made public, would damage its relationship with the foreign partner.
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March 19, 2024
HMRC Under Fire For Sharply Cutting Back Helpline Service
The U.K. tax authority has moved too quickly to phase out helpline services for taxpayers filing self-assessment returns this year, members of Parliament said Tuesday.
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March 19, 2024
EU Parliament Committees Approve AML Laws
Two European Parliament committees approved new anti-money laundering legislation Tuesday for the European Union to create a single rule book for all 27 EU countries and to establish a common enforcement authority.
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March 19, 2024
Compliance Costs Call For Border Fee, France's Le Maire Says
The cost of compliance with European environmental rules justifies the European Union's recently launched carbon border tax, which is designed to raise the price of imports with lower environmental standards, French Finance Minister Bruno Le Maire said Tuesday.
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March 19, 2024
UK Energy Co. Fights To Deduct £2.5M Deal Advice Fees
An investment holding company told the Supreme Court on Tuesday that £2.5 million ($3.2 million) it paid to Deutsche Bank and others for deals advice is tax-deductible because they were the "type of services procured all the time."
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March 18, 2024
HMRC Defends Response To Tax Avoidance Ploy
The U.K. tax authority has rejected claims that it has been "heavy-handed" by applying the loan charge to users of disguised remuneration schemes, according to a letter released on Tuesday by the Treasury Committee.
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March 18, 2024
Australia Seeks Input On Revised Energy Tax Regulations
Australia's Department of the Treasury is seeking responses from the public to a draft of updated regulations for determining petroleum resource rent tax, the department announced Monday.
Expert Analysis
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US Should Leverage Tax Rules To Deter Business With Russia
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.
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Justices Must Apply Law Evenly In Shadow Docket Rulings
In recent shadow docket decisions, the U.S. Supreme Court has inconsistently applied the requirement that parties demonstrate irreparable harm to obtain injunctive relief, which is problematic for two separate but related reasons, says David Hopkins at Benesch.
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US Investors Stand To Benefit From Brazil's New Forex Law
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.
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A Landmark UK Enforcement Case For Crypto-Assets
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.
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Simplifying Tax Issues For Nonresident Athletes In Canada
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.
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Steps For Universities As DOJ Shifts Foreign Influence Policy
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.
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Why I'll Miss Arguing Before Justice Breyer
Carter Phillips at Sidley shares some of his fondest memories of retiring Justice Stephen Breyer both inside and out of the courtroom, and explains why he thinks the justice’s multipronged questions during U.S. Supreme Court oral arguments were everything an advocate could ask for.
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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.