International
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April 24, 2024
EU Court Won't Disturb Spanish Tax Break Rulings
A Spanish company on Wednesday lost its attempt to legitimize a tax scheme declared illegal by the European Commission when the European Union's General Court rejected its appeal, refusing to disturb prior decisions in the long-running dispute.
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April 24, 2024
GOP Reps Seek IRS Nonprofit Info After China Reports
House Ways and Means Republicans asked the Internal Revenue Service to provide information about how it monitors tax-exempt organizations for possible violations of their status after reports China may be funding and improperly influencing nonprofits, according to a letter sent Wednesday.
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April 24, 2024
Treasury Limits Reach Of Look-Through Rule In Final Regs
The U.S. Treasury Department finalized regulations Wednesday that retain but narrow the scope of a proposal to, in a manner of speaking, look through the corporate owners of real estate investment entities to determine whether they are domestically controlled.
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April 24, 2024
Tax Pros Suggest How HMRC Can Assess Digitalization Effort
HM Revenue & Customs should abide by a set of benchmarks when evaluating tests of its digitalization program for income tax self-assessment forms, two groups representing U.K. tax professionals said.
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April 24, 2024
Ex-England Footballer Banned As Director For Unpaid Tax
Former England football international John Barnes has been banned from being a company director after his business failed to pay more than £190,000 ($236,000) in tax, a U.K. government agency announced on Wednesday.
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April 24, 2024
Papua New Guinea Commits To Automatic Tax Info Exchange
Papua New Guinea has committed to enacting the Organization for Economic Cooperation and Development's standard for automatic exchange of financial account information in tax matters by September 2027, the OECD said Wednesday.
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April 24, 2024
EU Keeps Gibraltar, Panama, UAE On AML Blacklist
Gibraltar, Panama and the United Arab Emirates should remain on the European Union's blacklist of high-risk countries for money laundering, the European Parliament said, stopping the EU from following the lead of a global organization promoting standards for countries to fight those crimes.
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April 24, 2024
EU Expected To OK Withholding Tax, Digital VAT Laws In May
European Union finance ministers are expected to agree on a new withholding tax refund law and a package to modernize value-added tax reporting at their May 14 meeting, an EU official said Wednesday, speaking on the condition of anonymity.
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April 24, 2024
EU Says 3 States Aren't Correctly Following AML Law
The European Commission said Wednesday that three European Union countries — Ireland, France and Latvia — aren't correctly implementing the bloc's laws against money laundering, meaning that the countries now have two months to correct the shortcomings.
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April 23, 2024
Treasury Says Aussie Royalty Ruling Contradicts US, OECD
Australia's updated draft ruling regarding when payments for the rights to distribute software would be considered royalties conflicts with OECD and U.S. standards on the treatment of such deals, a U.S. Department of the Treasury official said in a letter made public Tuesday.
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April 23, 2024
Biz Ownership Law Constitutional, Lawmakers Tell 11th Circ.
The Corporate Transparency Act is a garden-variety exercise of Congress' powers to address threats to national security, foreign affairs, commerce and tax collection, five Democratic lawmakers told the Eleventh Circuit, disputing a ruling that the law is unconstitutional.
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April 23, 2024
DC Circ. Backs Tax Penalties Against Swiss Couple
A Swiss couple who incurred $500,000 in penalties for failing to report millions of dollars they held in Swiss bank accounts can't get out of paying, the D.C. Circuit ruled Tuesday, rejecting their argument that the IRS didn't properly approve the fines.
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April 23, 2024
Int'l Pricing Pact Guidance Is Coming Soon, IRS Official Says
Updated Internal Revenue Service guidance that would help multinational corporations pursue advance pricing agreements will likely be released in a few months, an agency official said Tuesday.
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April 23, 2024
Disney, IBM Stuck With Tax On Royalties, NY Top Court Holds
New York's highest court rejected Disney and IBM's arguments that the state unconstitutionally denied their attempts to take tax deductions on royalties received from foreign affiliates, holding Tuesday that the law at issue didn't discriminate against interstate commerce.
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April 23, 2024
EV Levy Could Blunt Swiss Climate Plan Pains, Report Says
The first report on the long-term fiscal impact of climate change mitigation measures in Switzerland, released Tuesday, projects a major negative impact on public funds as certain tax sources dry up, but a planned replacement levy on electric vehicles could lessen that effect.
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April 23, 2024
Irish Minister Warns Corp. Tax Windfall Still Shrouds Deficit
Ireland's budget is projected to have an €8.6 billion ($9.2 billion) surplus this year, but the country's finance minister again cautioned Tuesday that without the slowly decreasing windfall corporate tax receipts there would actually be a deficit.
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April 23, 2024
Tax Experts Want Cut To Healthcare Insurance Levy
Tax experts on Tuesday urged the U.K. government to partially suspend a levy on healthcare insurance products, after it revealed record premium tax revenue of £8.1 billion ($10.1 billion) last year.
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April 23, 2024
Talk Of Int'l Wealth Tax Fuels Debate On UN Vs. OECD
Discussion of an international tax on the world's wealthiest individuals has intensified a debate about whether international tax policy would be better steered by the Organization for Economic Cooperation and Development or the United Nations.
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April 23, 2024
EU Parliament OKs Extending Duty-Free Imports From Ukraine
The European Parliament approved the suspension of the European Union's customs duties and quotas on Ukrainian imports into the EU for one year until June 2025 on Tuesday, overcoming discord in March over farm imports that threatened the deal.
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April 22, 2024
Scotiabank Fights To Keep Peru VAT Claim Alive
The Bank of Nova Scotia urged the World Bank's international arbitration institution in recently released documents not to dismiss the arbitration of its value-added tax dispute against Peru, saying the case raises issues of fact.
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April 22, 2024
Congress Can Enact Corp. Transparency, Orgs Tell 11th Circ.
Congress is empowered to require American companies to report their beneficial owners to the federal government because there is ample evidence they've previously been used to fund hostile foreign actors, evade sanctions and traffic drugs, two think tanks told the Eleventh Circuit in an amici brief.
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April 22, 2024
Partnership Can't Claim $22.7M Loss, Tax Court Says
The U.S. Tax Court on Monday upheld the IRS' decision to deny a $22.7 million loss deduction claimed by a Connecticut partnership, finding that underlying transactions involving a bankrupt Brazilian company's debt obligations amounted to a disguised property sale.
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April 22, 2024
Sweden Proposes Tax Breaks Ahead Of Budget Negotiations
The Swedish Finance Ministry proposed adjusting its so-called expert tax incentive, which businesses use to attract external workers, among a series of tax changes offered up Monday.
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April 22, 2024
Trader Behind £1.4B Tax Fraud Thought Trades Were Valid
A British trader accused of being the mastermind of a fraudulent trading scheme that cost Denmark's tax authority £1.4 billion ($1.7 billion) genuinely believed that the trades worked, his lawyer told a London court on Monday.
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April 22, 2024
Finland Discovers €30M In Undeclared Crypto Profits
Finnish taxpayers made at least €30 million ($32 million) in undeclared cryptocurrency trade profits in 2022, Finland's tax authority said Monday, reminding taxpayers to include such profits in their filings this year.
Expert Analysis
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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.
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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.