International
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April 09, 2024
France, Luxembourg Extend Old Tax System To 2023 Income
French residents working in Luxembourg don't yet have to account for a new system for avoiding double taxation included in an updated treaty between the two countries, but there will a final extension for the previous system, the French finance ministry said Tuesday.
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April 09, 2024
Greece Adopts Global Minimum Tax Directive After Pressure
Greece has officially implemented the global corporate minimum tax spearheaded by the Organization for Economic Cooperation and Development, after being reprimanded this year by the European Commission.
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April 09, 2024
EU Lawmakers OK Revised Deal On Imports From Ukraine
European Union lawmakers agreed on a revised deal to extend the suspension of the bloc's customs duties and quotas on Ukrainian imports until June 2025 after some EU countries had rejected a previous deal.
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April 09, 2024
Adviser Group Wants Limitations Added To EU Disclosure Law
A group that represents tax advisers in Europe said Tuesday that it wants the European Union's executive branch to add limitations to a major disclosure law designed to combat cross-border tax evasion, saying the law puts too high a burden on them.
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April 09, 2024
Labour Party Pledges £5.1B Tax Crackdown If Elected
Britain's opposition Labour Party pledged Tuesday to raise £5.1 billion ($6.5 billion) by closing tax loopholes and cracking down on tax avoidance schemes if it wins the next election, expected later this year.
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April 08, 2024
Tax Court Upholds $11M In Foreign Reporting Penalties
The U.S. Tax Court on Monday mostly upheld $11 million in foreign reporting penalties against a man who admitted he hid money overseas, but the court declined to overturn its ruling that the IRS lacks authority to assess certain foreign reporting penalties.
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April 08, 2024
CPAs Want Treasury To Delay Beneficial Ownership Registry
The U.S. Department of the Treasury should delay enforcement of beneficial ownership information reporting requirements while courts hear cases challenging the Corporate Transparency Act, the American Institute of Certified Public Accountants and 54 state CPA societies said.
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April 08, 2024
Siblings Sentenced Over £1M UK Film Tax Fraud
Two brothers who fraudulently filed for more than £1 million ($1.3 million) in U.K. film and value-added tax refunds for movies actually made in the U.S. — and in one case, never existed — were each sentenced Monday to seven years in prison, HM Revenue & Customs said.
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April 08, 2024
EU Tax Single Filing Would Aid Small-Biz Trade, Official Says
A proposal allowing small businesses in the European Union to file a single tax return with the administration of the business' head office as opposed to with every member country where the entity does business would cut compliance costs and encourage trade, an EU official said.
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April 08, 2024
EU Expansion Question Shines Light On Tax Voting Procedure
The question of whether the European Union should expand beyond its current 27 member countries is putting the spotlight on the bloc's voting practices, raising concerns that the current unanimity requirement for tax policy changes would become unmanageable with a larger group.
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April 05, 2024
Monopolies Will Raise Prices Under Minimum Tax, Expert Says
The 15% global minimum tax will worsen the problems that monopolistic companies impose on economies because raising taxes on a company that lacks competition will lead it to raise prices, an academic expert on tax havens said Friday during a conference.
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April 05, 2024
Ireland Issues Example Of Dividend Exemption Proposal
The Ireland Department of Finance released a hypothetical example Friday to help guide further discussions on the country's planned implementation of a participation exemption from Irish corporation tax for foreign dividends.
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April 05, 2024
Irish Finance Dept. Seeks 2 Sovereign Funds For Tax Surplus
The Irish Department of Finance introduced a bill that would establish two sovereign wealth funds in Ireland as a way to take advantage of the country's surplus generated in part by corporate windfall taxes.
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April 05, 2024
Contrasts Emerge Between Taiwan Tax Bill, Regular Treaties
A bill pending in the Senate would lay the groundwork for double-tax relief and other treaty-like arrangements with Taiwan, but the unique legislative process and relatively reduced content could cast uncertainty over the unofficial accord's ultimate fate.
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April 05, 2024
UK Urges Delay In Claiming Pensions Until Rules Change
The U.K. tax authority has warned people to delay claiming their pensions until after Saturday, when the lifetime allowance is abolished, while the government clarifies technical changes to the legislation.
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April 05, 2024
EU Executive To Probe Complaint About Hungarian Retail Tax
The European Commission will look into a complaint it received about a Hungarian tax on the retail sector, the European Union's executive branch confirmed Friday.
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April 05, 2024
18 Crime Gangs Specialize In VAT Fraud, Europol Says
Eighteen major criminal gangs in the European Union specialize in value-added tax fraud, having end-to-end control over the entire criminal process, the EU's law enforcement agency said Friday.
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April 05, 2024
Taxation With Representation: Latham, Simpson Thacher
In this week's Taxation with Representation, Endeavor and Nuvei each go private, SLB purchases ChampionX and Liberty Media Corp. buys Dorna Sports SL.
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April 04, 2024
Snell & Wilmer Adds Former McDermott Partner In Dallas
A former McDermott Will & Emery partner and tax specialist has joined Snell & Wilmer's Dallas office to advise clients on cross-border transactions, particularly in Latin America and Mexico.
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April 04, 2024
Companies In Limbo As IRS Mulls Waiver For 15% Book Tax
Corporations preparing for their quarterly estimated taxes are uncertain about paying a 15% alternative minimum tax due on April 15, since the Internal Revenue Service granted waivers last year and has yet to release proposed regulations that officials have promised since October.
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April 04, 2024
IRS Penalties Proper In $11B Amgen Dispute, Tax Court Says
The Internal Revenue Service properly authorized penalties included in a tax bill of nearly $11 billion that drugmaker Amgen is challenging, the U.S. Tax Court said Thursday.
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April 04, 2024
Ireland Would Need Big Tax Hike For Unification, Study Says
The costs of a theoretical reunification of Northern Ireland with the rest of Ireland would be between 5% and 10% of the country's gross national income, which would likely need to be made up with a "dramatic" increase in taxes, a study released Thursday said.
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April 04, 2024
Attys Awarded $1.5M In Fees On Tax Disclosure Suit
Attorneys who won a $4.5 million settlement for a class of investors claiming a Chinese startup misrepresented its tax liability will receive their requested $1.5 million in attorney fees, a New York federal judge ruled.
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April 04, 2024
Mayer Brown Adds Former KPMG Tax Specialist In London
Mayer Brown has added a former KPMG tax professional to its London office to advise clients on asset management and fund matters in the U.S., Europe and the Middle East, the firm announced.
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April 04, 2024
Singapore Co.'s Properties Transfer Ruled Capital Transaction
The transfer of properties between a Singapore company and a related company as part of a corporate restructuring would constitute a capital transaction, the country's Inland Revenue Authority said, making the swap tax-exempt.
Expert Analysis
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OFAC Designation Prosecutions Are Constitutionally Suspect
Criminal prosecutions based on the Office of Foreign Assets Control’s sanctions-related listing decisions — made with nearly unfettered discretion through an opaque process — present several constitutional issues, so it is imperative that courts recognize additional rights of review, say Solomon Shinerock and Annika Conrad at Lewis Baach.
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How The OECD Global Tax Proposal Could Affect M&A
Following agreement on the Organization for Economic Cooperation and Development’s Pillar Two proposal to introduce a global minimum tax, domestic implementation is expected to have a significant impact on international M&A transactions, with financial modeling, deal structuring, risk allocation and joint venture arrangements likely to be affected, say lawyers at Freshfields.
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UK Shares-Tax Proposals Offer Long-Awaited Modernization
The U.K. government's recent consultation on the introduction of a new tax on transactions in securities raises detailed legal and practical issues, but the prospect of a single digital stamp tax offering both streamlined legislation and administration will be welcomed, say Zoë Arnautov and Mark Sheiham at Simmons & Simmons.
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IRS Foreign Tax Credit Pause Is Welcome Course Correction
A recent IRS notice temporarily suspending application of 2022 foreign tax credit regulations provides wanted relief for the many U.S. multinational companies and other taxpayers that otherwise face the risk of significant double taxation in their international operations, say attorneys at Mayer Brown.
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IRS Criminal Probe Spells Uncertainty For Malta Pension Plans
The IRS’ recent scrutiny of Malta pension plan arrangements — and its unusual issuance of criminal administrative summonses — confirms that it views many of these plans as illegal tax evasion schemes, and the road ahead will not be smooth and steady for anyone involved, say attorneys at Kostelanetz.
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IRS Announcement Will Aid Cos. In Buyback Tax Planning
Recent IRS transitional guidance regarding current requirements for reporting and payment of the stock repurchase excise tax will help corporate taxpayers make decisions about records retention and establishing reserves for future tax payments, say Xenia Garofalo and Kyle Colonna at Eversheds Sutherland.
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Flawed Analysis Supports Common Law Tax Deficiency Ruling
The Colorado federal district court’s recent decision in Liberty Global, holding that the U.S. Department of Justice may assert a common law tax claim without the notice of tax deficiency required by the Internal Revenue Code, relies on a contorted reading of the statute and irrelevant case law, say Loren Opper and Christie Galinski at Miller Canfield.
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Review Of Repatriation Tax Sets Justices On Slippery Slope
The U.S. Supreme Court’s recent decision to review the constitutionality of the repatriation tax in Moore v. U.S. has implications for many tax rules involving unrealized amounts and could leave the court on the brink of invalidating large swaths of the Internal Revenue Code, say attorneys at Eversheds Sutherland.
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What To Make Of IRS' New Advance Pricing Guidance
Recent guidance on the IRS' goals for its advance pricing agreement system provides helpful insight into review and decision-making procedures for advance pricing agreement requests, but it also raises questions about the IRS' objectives, say Richard Slowinski and Stefanie Kavanagh at Alston & Bird.
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Reserved Investor Fund Would Plug Gap In UK Finance Market
The reserved investor fund recently proposed by HM Treasury has the potential to be a welcome tax-efficient addition to the U.K.’s canon of products for real estate investments, with attractive features for companies and, in particular, large asset managers, say lawyers at Herbert Smith.
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The Reciprocal Tax Bill Is A Warning Shot At Pillar 2
A bill recently introduced in the House of Representatives to reciprocally tax countries deemed to have imposed discriminatory taxes on U.S. citizens and businesses takes aim at countries implementing the global minimum tax treaty known as Pillar Two, with which the U.S. has not complied, says Alan Cole at the Tax Foundation.
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What Tax-Exempt Orgs. Need From Energy Credit Guidance
Guidance clarifying the Inflation Reduction Act’s credit regime, expected from the U.S. Department of the Treasury this summer, should help tax-exempt organizations determine the benefits of clean energy projects and integrate alternative energy investments into their activities, say attorneys at Morgan Lewis.
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How Foreign Info Return Penalty Case May Benefit Taxpayers
The U.S. Tax Court's recent decision that the Internal Revenue Service cannot penalize taxpayers for failing to file foreign corporation information returns may give similarly situated taxpayers an opportunity to also avoid penalties, provided they protect their rights before the decision is overturned or mooted by legislation, say attorneys at Arnold & Porter.