International

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • April 04, 2024

    Parliament Committee Delaying Vote On EU Energy Tax Law

    A European Parliament committee will delay a vote on a landmark energy taxation law, as it is unclear if a majority will back the measure, a European Union source familiar with the matter told Law360 on Thursday.

  • April 04, 2024

    Next EU Parliament Must Eye Tax Fairness, Lawmaker Says

    The new European Parliament that is elected in June must continue to work on fairness in taxation, removing tax barriers to economic growth and scrutiny of international tax policies, the outgoing chair of the parliamentary tax subcommittee said Thursday.

  • April 03, 2024

    IRS Says $28M In Fines Against Microsemi Adhered To Rules

    The Internal Revenue Service is again pressing the U.S. Tax Court to rule that it followed supervisory approval requirements when it imposed nearly $28 million in penalties against semiconductor manufacturer Microsemi in a transfer pricing dispute.

  • April 03, 2024

    McDermott Adds Ex-Baker McKenzie Tax Pro In Chicago

    The former chair of Baker McKenzie's Chicago tax practice group has joined McDermott Will & Emery LLP and will work as a partner in the firm's Chicago office, McDermott said Wednesday.

  • April 03, 2024

    Dutch Seek Input On Narrowing Plot Transfer Tax Exemption

    The Netherlands is seeking input on plans to amend a rule that exempts buildings on transferred plots of land from the country's transfer tax, saying that it needs to be narrowed to just agricultural buildings in line with the exemption's intention to benefit rural areas.

  • April 03, 2024

    UK Seeks To Share Country-Level Tax Reports, Official Says

    The U.K. government wants to allow low-income countries greater access to country-by-country reports of multinational corporations' tax data as a way to help them recover revenue that they're owed, a Cabinet official said Wednesday.

  • April 03, 2024

    Grading State Tax Policy And Judging The 'Dirty 30'

    For the first time in a quarter-century, the Council on State Taxation, which represents the state tax interests of more than 500 multinational corporations, is led by someone who is not named Douglas L. Lindholm. Here, Law360 speaks with the organization's new president emeritus.

  • April 03, 2024

    Taiwan Issues Tax Relief Guidance In Wake Of Earthquake

    Individuals and businesses impacted by the 7.4-magnitude earthquake that hit Taiwan on Wednesday morning are eligible for tax reductions or exemptions if their property was damaged, the country's National Taxation Bureau said.

  • April 03, 2024

    Greece Can Have Tax Regime On Self-Employed, EU Says

    Greece has the right to introduce a standardized minimum taxable income for the self-employed, according to European Union tax commissioner Paolo Gentiloni, who said rebalancing the tax burden between big and small businesses could help reduce income inequalities.

  • April 02, 2024

    Swiss Banker Avoids Prison For $60M Tax Evasion Conspiracy

    A Manhattan federal judge allowed a Swiss finance pro to avoid prison Tuesday for facilitating a tax evasion scheme that helped wealthy Americans hide $60 million from the IRS, saying the defendant is less culpable than alleged co-conspirators.

  • April 02, 2024

    South Africa Relying Less On Biz Tax As Revenues Top $115B

    South Africa's total tax revenue rose to 2.155 trillion rand ($115 billion) last year, buoyed by collections of personal income tax increasing more than 8% and despite corporate income tax collections sinking nearly 9%, the South African Revenue Service said Tuesday.

  • April 02, 2024

    Norway Floats Tax Framework For Activities On Sea Shelf

    With an increase in economic activity expected on Norway's continental sea shelf in the future, the country's Ministry of Finance said Tuesday that it wants to introduce tax liabilities on foreign companies generating income from certain activities there and is looking for public comment.

  • April 02, 2024

    Luxembourg's Deduction Rules Flout EU Law, Bloc Tells Court

    The European Commission asked the European Union's Court of Justice to rule that Luxembourg is breaking EU law by including securitized entities among financial undertakings that are allowed deductibility of interest payments, the EU's Official Journal said Tuesday.

  • April 02, 2024

    Small UK Cos. 'Freed' From VAT Payments By Threshold Rise

    Some 28,000 businesses have been "freed" from paying value-added tax as the registration threshold rose from £85,000 ($106,000) to £90,000 in revenue, HM Treasury has said.

  • April 02, 2024

    Watchdog Probes Norway's Carbon Tax Exemption Measures

    A Norwegian plan to exempt from excise duty waste incineration that is subject to the European Union's emissions trading system and to exempt natural gas, which is also subject to the ETS, from carbon tax is the focus of an investigation into state aid, a watchdog said Tuesday.

Expert Analysis

  • Consider Mutual Agreement Procedures For Double Tax Relief

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    Taxpayers wary of using mutual agreement procedures for double taxation relief should revisit the process, which is more straightforward than many believe, lest they miss out on tax savings, says Monique van Herksen of Simmons & Simmons.

  • A Road Map For US Involvement In Europe's Cum-Ex Probe

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    The dividend arbitrage trading strategy known as cum-ex continues to face regulatory scrutiny in Europe, and stateside regulators may soon follow suit with the U.S. Securities and Exchange Commission’s recent American depositary receipt probe as a guide for enforcement, says Joshua Ray at Rahman Ravelli.

  • Congress Should Make TCJA Income Definition Permanent

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    Congress should not allow the Tax Cuts and Jobs Act's definition of adjusted taxable income, which includes depreciation and amortization, to expire in 2022 because it would discourage debt-free investment, running counter to the law's intent, says George Callas at Steptoe & Johnson.

  • OECD Delays Are Imperiling Digital Tax Deal

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    As the Organization for Economic Cooperation and Development continues to push back its deadline for a digital tax overhaul, countries are beginning to pursue unilateral solutions and the negotiations are turning political, decreasing the likelihood of an agreement, says Joyce Beebe at Rice University.

  • Mitigating IRS Cryptocurrency Enforcement Risk In 2021

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    The IRS seems poised to shift focus in 2021 from education to enforcement of virtual currency tax laws, and noncompliant taxpayers should consider whether they are eligible to file amended returns or voluntary disclosures to mitigate the risk of civil penalties, criminal investigation or prosecution, say Don Fort and Lawrence Sannicandro at Kostelanetz & Fink.

  • 2020's Key Tax Controversy Developments

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    Andrew Roberson and Kevin Spencer at McDermott highlight 2020's key tax controversy developments, offering their perspective on important tax decisions, the Internal Revenue Service’s cooperative audit program, informal tax return amendment procedures, Large Business & International Division campaigns, and handling virtual appeals conferences during the pandemic.

  • Justices Likely To Shield Treasury From Preemptive Action

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    Recent U.S. Supreme Court oral arguments in CIC Services v. Internal Revenue Service suggest the court will resolve a circuit split by ruling the Anti-Injunction Act shields the U.S. Department of the Treasury from preemptive challenges — bad news for those hoping to challenge unfavorable regulations, says Monte Silver at Silver & Co.

  • Response Options For Danish Cum-Ex Interview Targets

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    As the Danish tax authority prepares for the first of a three-part U.K. trial involving cum-ex fraud, U.K. recipients of interview requests from the Danish prosecutorial agency should neither automatically accept, nor ignore the invitations, despite that agency's seeming lack of power to compel their attendance, says David Corker at Corker Binning.

  • Advancing The Democratic Tax Agenda In 2021

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    Even with a divided government starting next year, Democrats will have a major effect on tax policy, pursuing legislative compromises and regulatory changes in service of President-elect Joe Biden's tax plan, and potentially reversing many Trump administration initiatives, say Russell Sullivan and Radha Mohan at Brownstein Hyatt.

  • M&A Poised For Growth In The Biden Era

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    The M&A market is well positioned for recovery and growth under a Biden administration and divided Congress, which will likely gain control over the coronavirus pandemic, pass a stimulus package, and provide greater transparency in antitrust enforcement, say attorneys at Debevoise.

  • Final BEAT Regs Still Contain Pitfalls For Taxpayers

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    Recently finalized U.S. Department of the Treasury regulations retain a taxpayer-friendly election allowing corporations to waive deductions to avoid the base erosion and anti-abuse tax, but neglect to include recourse for companies that waive more deductions than necessary, say attorneys at Ropes & Gray.

  • Post-Election Tax Policy Scenario 3: A Divided Government

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    Attorneys at Brownstein Hyatt consider whether Democrats and Republicans will find common ground on tax policies and legislation regarding COVID-19 relief, domestic research and manufacturing, pension and retirement savings, foreign taxation of U.S. companies, and infrastructure development if the upcoming election results in a divided government.

  • Post-Election Tax Policy Scenario 2: A Democratic Sweep

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    Russell Sullivan and Radha Mohan at Brownstein Hyatt consider former Vice President Joe Biden’s perspective that a better economy addresses income inequality, and the likelihood of passing specific tax measures in the event of a Democratic sweep, despite varying party perspectives.

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