International

  • April 12, 2024

    Taxation With Representation: Freshfields, Kirkland & Ellis

    In this week's Taxation with Representation, eBay acquires Collectors' Goldin auction house, Vertex Pharmaceuticals buys Alpine Immune Sciences, Vista Equity Partners purchases Model N and Tradeweb Markets buys Institutional Cash Distributors.

  • April 12, 2024

    Countries Late On Pillar 2 Need To Catch Up, EU Official Says

    Countries within the European Union that are late implementing the global minimum tax rules need to do so soon, an official with the European Commission said Friday, adding that countries failing to do so could face fines.

  • April 11, 2024

    BlackRock Can't Deduct Interest On $4B, London Court Finds

    Financial services firm BlackRock cannot deduct interest on $4 billion in loans it used for the 2009 purchase of Barclays Global Investors because avoiding taxes was the main reason for the way it structured the transaction, a London appeals court ruled Thursday.

  • April 11, 2024

    France's Anti-Money Laundering Reports Up 15% In 2023

    France's anti-money laundering unit received 15% more reports of suspicious financial transactions in 2023 compared with 2022, continuing a trend that has resulted in a seven-fold increase in such reports over the past decade, the country's finance ministry said Thursday.

  • April 11, 2024

    Int'l Salesman Stuck With FBAR Fines For Swiss Account

    An agricultural salesman earning money in Ukraine willfully hid a Swiss bank account from the IRS that neither his accountant nor his wife knew about, a Nebraska federal judge said Thursday in upholding more than $600,000 in reporting penalties against him.

  • April 11, 2024

    Tax Controversy Quintet Joins Bradley Arant In Atlanta

    Bradley Arant Boult Cummings LLP announced that it hired a five-person tax controversy team from Chamberlain Hrdlicka White Williams & Aughtry highlighted by the addition of three experienced partners, including two former Internal Revenue Service trial attorneys.

  • April 11, 2024

    Proskauer Adds Kirkland Partner For Tax, Estate Issues

    Proskauer Rose LLP has added to its private client services department a partner from Kirkland & Ellis LLP who specializes in developing domestic and international tax and estate plans for clients with very high net worth, the firm announced.

  • April 11, 2024

    Australia Considering Build-To-Rent Tax Break Increases

    Australia is seeking public input on a plan to increase tax breaks for builders constructing rental properties in the country while also introducing conditions to qualify for those breaks.

  • April 11, 2024

    Swiss Bank Probe May Prompt IRS To Revive Disclosure Effort

    Senate Finance Committee Chairman Ron Wyden's latest investigation into the Swiss banking industry may apply further pressure to federal law enforcement officials to revive a program designed to encourage taxpayers' voluntary compliance in disclosing income held overseas to the IRS.

  • April 11, 2024

    EU Parliament Advances Small Biz Single File Tax Plan

    Small businesses in the European Union would be able to file a single tax return with the administration of the business' head office instead of with every member country where the entity operates under a proposal approved by the European Parliament.

  • April 11, 2024

    Adviser Urges ECJ To Annul Nix Of UK's CFC Tax Breaks

    The European Union's General Court erred by relying on controlled foreign company rules in Great Britain when it found that U.K. corporate tax breaks were illegal, an adviser to the bloc's highest court said Thursday in urging the reversal of that ruling.

  • April 11, 2024

    OECD Plans More Guidance On Global Min. Tax, Official Says

    The Organization for Economic Cooperation and Development will issue further guidance on the global minimum corporate tax, a top official from the organization said Thursday, and another official defended a backstop provision of the minimum tax.

  • April 10, 2024

    Plastic Surgeon Owes $7.7M From Offshore Scheme, US Says

    A now-retired plastic surgeon owes the Internal Revenue Service more than $7.7 million after he ran an offshore employee leasing scheme and he and his wife transferred nearly all their assets to their then-11-year-old daughter, who is now a lawyer, the government told an Ohio federal court.

  • April 10, 2024

    Australia's Tax Office Seeks Input On Risk-Weighted Assets

    The Australian Taxation Office is seeking comments on a paper about how it measures the risk-weighted assets of a foreign bank's Australian branch when applying thin capitalization rules, the ATO announced.

  • April 10, 2024

    EU Parliament Wants Transfer Pricing Rules To Apply Sooner

    The European Parliament voted Wednesday to adopt new transfer pricing rules that would take effect one year earlier than previously planned, sending the proposal to the European Union's council of member countries for consideration.

  • April 10, 2024

    IRS' DOJ Referral Rules 'A Disaster,' Sen. Whitehouse Says

    The IRS protocols for referring cases to the U.S. Department of Justice are "a disaster" for enforcing laws against bankers and other actors who help U.S. taxpayers evade taxes, Sen. Sheldon Whitehouse said Wednesday during a hearing on offshore tax evasion before the Senate Budget Committee.

  • April 10, 2024

    Belgium's Anticipated Green Tax Break Carries Some Doubts

    A proposal working its way through the Belgian Parliament would create opportunities for investors in green and sustainable technologies, but questions about the long-term durability of the measure, which would offer an expanded deduction for such investments, could weigh on its popularity and effectiveness.

  • April 10, 2024

    EU Gave €46B In State Aid As Tax Breaks In 2022

    European Union countries gave their companies tax breaks worth about €46 billion ($49.4 billion) in state aid in 2022, some to weather the fallout from the Ukraine war and the COVID-19 pandemic and other aid to promote infrastructure projects or environmental protection, a European Commission report said.

  • April 09, 2024

    Treasury Proposes Long-Awaited Stock Buyback Tax Rules

    The U.S. Treasury Department proposed a pair of long-awaited rules Tuesday that detail the calculation and reporting of a new excise tax assessed to publicly traded corporations that recently bought back their own shares of stock on the open market.

  • April 09, 2024

    Healthcare Co. Can't Sue Ex-Exec For Causing Canada Tax Hit

    A Colorado federal judge shot down a pharmacy automation company's suit alleging its former chief commercial officer cost it nearly CA$1.2 million ($907,000) in Canadian taxes by not telling his employer he had moved out of the country, saying the company hasn't shown it suffered any damage as a result.

  • April 09, 2024

    Poland Adopts Digital Platform Reporting Rules

    Poland's Council of Ministers approved a measure Tuesday implementing the European Union's tax information reporting procedures for digital platform operators, known as DAC7, the country's tax authority said.

  • April 09, 2024

    UK Court Affirms Sweet VAT Ruling For Jumbo Marshmallows

    Jumbo-size marshmallows are not candy like regular marshmallows because they're meant to be roasted, so they qualify for a value-added tax exemption for food, the U.K. Upper Tribunal ruled in upholding a lower court's findings.

  • April 09, 2024

    BCLP Says It Had No Obligation To Man's Family In Tax Fight

    Global law firm Bryan Cave Leighton Paisner was under contract to represent only a family's patriarch and thus shouldn't be liable for taxes resulting from advising him to transfer £242 million ($307 million) in assets to his wife, then to his sons, the firm told a London court.

  • 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.

  • 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.

Expert Analysis

  • How Foreign Info Return Penalty Case May Benefit Taxpayers

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    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.

  • The Nuts And Bolts Of IRS Domestic Content Tax Credit

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    Recent IRS guidance provides specifics on how renewable energy projects can qualify for bonus tax credits by meeting U.S. domestic content rules, but also creates a qualification framework that will be complicated for project developers to navigate, say Scott Cockerham and Wolfram Pohl at Orrick.

  • Taxing The Digital Economy: The Good, The Bad And The Ugly

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    U.S. tech companies should watch for important developments in international taxation, including the resolution of Apple's decade-old state aid case, growing frustration with the Organization for Economic Cooperation and Development's global tax plan and adoption of the digital services tax instead, says Joyce Beebe at Rice University's Baker Institute for Public Policy.

  • Big Tax Changes For Multinational Cos. In Budget Proposal

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    The Biden administration’s fiscal year 2024 budget proposes changes that would materially alter decades-old Internal Revenue Code provisions, requiring a shift in multinational corporations' tax planning strategies comparable to that required after enactment of the Tax Cuts and Jobs Act, say Xenia Garofalo and Kyle Colonna at Eversheds Sutherland.

  • Senate Credit Suisse Report Puts Attention On Banks, Trusts

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    The Senate Finance Committee's recent finding that Credit Suisse violated a plea agreement struck over its role in enabling offshore tax evasion has important ramifications for banks and trusts, including how they onboard, document and report on transactions relevant to U.S. reporting requirements, say Will Barry and Ian Herbert at Miller & Chevalier.

  • Seeking IRS Accountability For Faulty Microcaptive Notice

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    Like the taxpayers in Standard Insurances v. U.S. seeking to expand earlier wins in microcaptive insurance cases that limit IRS use of improperly obtained information, others should consider ways to hold the agency accountable and provide incentive for it to follow the law going forward, says Joshua Smeltzer at Gray Reed.

  • Biden Admin. Proposals Both Encourage And Thwart EV Adoption

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    While the Biden administration has been aggressively focused on promoting electric vehicles from the start, its recently issued guidance on EV tax credits and its restrictive new auto emissions proposal create a sense of implementation whiplash that may frustrate manufacturers and consumers, says Levi McAllister at Morgan Lewis.

  • The Key Issues Keeping Transfer Pricing A Top Tax Concern

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    Several challenges preventing a global economic reemergence from the pandemic era are making practitioners reevaluate commonly used transfer pricing models, and embrace new technologies and ways of doing business, say Farnaz Amini and Sophia Castro Jurado at Marcum.

  • Curtailing Offshore Tax-Advantaged Investment In China

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    The U.S. government's plans to establish a new outbound investment regime hold the potential to arrest Chinese companies' increasing use of offshore, tax-advantaged locations to raise capital, says David Plotinsky at Morgan Lewis.

  • Cos. May Want To Wait Out US-EU Green Incentives Fight

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    As the European Union considers measures to compete with the Inflation Reduction Act's incentives for U.S. production of clean tech, and EU and U.S. officials discuss a possible compromise, companies in the green sector should consider taking a wait-and-see approach to investment decisions, says Todd Thacker at Goldberg Segalla.

  • India's Budget Proposals May Ease Entry For Certain Sectors

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    India’s recently released budget includes proposals to facilitate doing business in Gujarat International Finance Tec-City and moderate thousands of compliance requirements, opening up new opportunities for foreign businesses in the digital infrastructure, manufacturing and renewable energy sectors, say Mukesh Butani and Seema Kejriwal at BMR Legal.

  • High Court Ax Of Atty-Client Privilege Case Deepens Split

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    The U.S. Supreme Court's recent dismissal of In re: Grand Jury as improvidently granted maintains a three-way circuit split on the application of attorney-client privilege to multipurpose communications, although the justices have at least shown a desire to address it, say Trey Bourn and Thomas DiStanislao at Butler Snow.

  • US-India Advance Pricing Resolutions Should Reassure Cos.

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    The United States' and India's tax authorities' recent resolution of a significant number of pending advance pricing agreements should reduce taxpayer uncertainty, reassure companies of the nations' good working relationship and improve India's investment environment, say Miller Williams and Caroline Setliffe at Eversheds Sutherland.

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