International
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May 06, 2024
Austrian Tax Investigations Collected €49M In 2023
Austrian tax investigators carried out 210 investigations in 2023, securing a total of €48.86 million ($52.6 million) in back taxes, with perpetrators possibly owing as much as €100 million in fines, the country's finance ministry said Monday.
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May 06, 2024
EU Court Asked To Rule On Italian Nix Of Biz Tax Deductions
The European Union's highest court was asked to rule on Italy's policy denying Italian parent companies certain tax deductions of corporate taxes paid by their subsidiaries in other EU countries, a question arising from an Italian bank's court challenge, a document published Monday showed.
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May 06, 2024
Macron-Backed Group Backs G20 Wealth Tax In Election Pitch
A group campaigning in the European Parliament elections that is backed by French President Emmanuel Macron supports a wealth tax in the world's largest economies, according to a campaign platform published Monday.
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May 04, 2024
IRS Seeks More Info On Purpose Test In Buyback Tax Regs
The IRS is seeking more information on fine-tuning a test in proposed rules on the stock buyback tax meant to assess whether the principal purpose of a U.S. subsidiary's funding purchase of its foreign parent's stock is to avoid the tax, an agency attorney said Saturday.
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May 03, 2024
US Resisting More Scoping On Amount B, Economist Says
In negotiations over the streamlined transfer pricing approach for baseline marketing and distribution functions known as Amount B, the U.S. has resisted calls for additional scoping criteria that would exclude more companies from the safe harbor, a former U.S. Treasury economist said Friday.
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May 03, 2024
Foreign Trust Reporting Rules Coming Soon, IRS Official Says
The Internal Revenue Service is about to issue proposed regulations that will provide guidance on the reporting obligations for individuals who have transactions with foreign trusts, an agency official said Friday.
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May 03, 2024
HMRC Director Rejoins KPMG To Boost Tax Dispute Offering
A former deputy director at HM Revenue & Customs has returned to KPMG as director of KPMG Law's tax disputes teams, the firm has announced.
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May 03, 2024
Africa Seeks Early UN Reform On Transfer Pricing, Exchanges
Legally binding protocols that reform transfer pricing and exchange of information to the benefit of all countries where multinational corporations operate should be developed simultaneously with the U.N. framework convention on global tax, the U.N.'s African bloc, India and others said Friday.
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May 03, 2024
Estonia Implements 2 EU Tax Laws After Delays
Estonia officially enacted two European Union-wide tax measures that it was late putting into national law, both relating to the OECD's standards for global minimum taxation of large companies.
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May 03, 2024
Aussie Treasury Seeks Input On Powers After PwC Scandal
With investigations into PwC Australia's leak of classified tax plan documents ongoing, the Australian government is asking the public whether it thinks its regulatory powers over tax and accounting firms are sufficient, its Treasury announced Friday.
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May 03, 2024
New Fiscal Rules Force EU Countries To Limit Deficits
New European Union fiscal rules that recently kicked in will force EU countries to restrict public budget deficits by better balancing tax revenues with government spending, the European Commission said Thursday.
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May 03, 2024
US Trade Position Seen Contradicting Stance In Pillar 1 Talks
The U.S. trade representative's withdrawal of support for digital trade proposals has caused tax policy observers to worry that the U.S. position on trade is undermining that of U.S. Treasury Department officials negotiating a taxing rights overhaul at the OECD known as Pillar One.
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May 03, 2024
Finland's Stance On Swiss Treaty Recalls Ended Portugal Deal
Finland's plan to renegotiate its tax treaty with Switzerland in response to concerns about pension tax avoidance has some observers worried that the country will cancel that accord as it did a treaty with Portugal in recent years.
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May 03, 2024
Taxation With Representation: Skadden, Wachtell, Davis Polk
In this week's Taxation With Representation, L'Occitane International said its executive director and chair is leading an offer to buy the company's shares he doesn't already own, UMB Financial agreed to purchase Heartland Financial USA, Medline said it agreed to acquire Ecolab's global surgical solutions business and The Mosaic Co. said it agreed to sell its stake in a phosphate production joint venture.
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May 03, 2024
IRS Can Assess Foreign Info Disclosure Penalty, DC Circ. Says
The D.C. Circuit on Friday overturned a major U.S. Tax Court ruling that had struck down the Internal Revenue Service's authority to assess and administratively collect penalties from taxpayers for failing to file an information return on their interests in a foreign corporation.
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May 03, 2024
Final EV Tax Credit Regs Add New Battery Tracing Test
The U.S. Treasury Department unveiled final regulations Friday for the up to $7,500 electric vehicle tax credit that include a more detailed process for automakers to trace the battery supply chain to qualify for the credit's domestic content requirements.
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May 03, 2024
German's Austrian Ski Holiday Ends With Arrest In VAT Probe
A German citizen on a skiing holiday in Austria was arrested over a large-scale value-added tax fraud scheme, the Finance Ministry in Vienna said in a statement on Friday.
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May 02, 2024
Claimed Panama Papers Leaker Fights To Hide ID In €5M Suit
A person claiming to be the Panama Papers leaker told a federal court they would fear for their life if the court made them disclose their identity in a €5 million ($6.3 million) suit against Germany, protesting a magistrate judge's suggestion that the suit be tossed because the person wouldn't identify themselves.
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May 02, 2024
IRS To Boost Audit Rates By 50% On Wealthy, Werfel Says
The Internal Revenue Service plans to nearly triple audit rates on corporations with assets over $250 million and increase audit rates by more than 50% on wealthy taxpayers with more than $10 million in total positive income by 2026, Commissioner Daniel Werfel said Thursday.
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May 02, 2024
Latest Stock Buyback Tax Rules May Still Have Wide Reach
The U.S. Treasury Department recently floated regulations that narrow an earlier proposal aimed at preventing foreign-parented corporations from circumventing a new excise tax on stock buybacks, but the regulations still characterize avoidance in ways that could include routine intercompany transactions.
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May 02, 2024
HMRC Asked To Investigate Firm On Dodging Sanctions
HM Revenue & Customs should investigate a German-owned garage door manufacturer for violating sanctions by importing products from Belarus into the U.K., but instead authorities brushed off the case and now the company might receive a license, a U.K. lawmaker said.
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May 02, 2024
Canada Budget Seeks To Establish Corp. Min. Tax Standards
Budget proposals submitted to Canada's Parliament by the finance minister would implement the Organization for Economic Cooperation and Development's global corporate minimum tax standards as part of the country's overarching budget plans.
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May 02, 2024
OECD-Asia Group Helping Reform Agenda, OECD Head Says
A group that brings together countries from the mostly Western Organization for Economic Cooperation and Development and Southeast Asia to discuss issues, including tax, is helping countries make changes, the head of the OECD said Thursday.
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May 02, 2024
Airlines Slam Increase In German Air Passenger Tax
The increase in Germany's air passenger tax on May 1 will weaken the country's economy and damage the aviation industry's ability to cut down on its carbon use, an airline group said on Thursday.
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May 01, 2024
No Relief For Fla. Adviser Convicted In $80M Trading Scam
The Eleventh Circuit on Wednesday affirmed the conviction of a Florida investment adviser who bilked more than $80 million from the hundreds of people he persuaded to invest in a fraudulent company, after concluding he was not in custody when he made statements to the police.
Expert Analysis
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Key Considerations For Seeking Relief From Double Taxation
Caroline Setliffe and E. Miller Williams at Eversheds Sutherland lay out the Organization for International Cooperation and Development’s mutual agreement procedure for settling double-taxation disputes, and discuss six factors U.S. taxpayers doing business in multiple countries should consider when determining the most advantageous form of relief.
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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.