International

  • February 13, 2024

    Aussie Tax Staffers Took Part In $1.3B Refund Fraud Scheme

    An Australian Taxation Office investigation into a goods and services tax refund fraud scheme determined that it cost the country AU$2 billion ($1.29 billion) in lost revenue and that 12 ATO employees committed the fraud while working there, Australia's audit office said.

  • February 13, 2024

    Finland Car Tax Revenue Down 24% As EV Buying Jumps

    Finland's revenue from its car tax dropped 24% last year compared with 2022 thanks in part to tax-exempt electric vehicles making up a greater share of new car purchases, the Finnish Tax Administration said Tuesday.

  • February 13, 2024

    Former Italian PM Pushes European Tax Harmonization

    A former prime minister of Italy urged European Union countries to pursue more harmonization in their taxation system, arguing that taking this step would make the bloc more competitive.

  • February 13, 2024

    EU Orders Denmark To Recover Tax Break For Bridge

    The European Commission said Tuesday that special Danish tax treatment for the construction of a bridge between Denmark and Sweden was partly illegal and should be repaid, adding that Denmark would have to determine the exact amount.

  • February 13, 2024

    Andersen Announces Expansion Of Global Valuation Practice

    Professional services firm Andersen has added 14 groups across Europe to its valuation practice in the last 12 months, part of its drive to become a leading valuation provider worldwide, the company announced Tuesday.

  • February 13, 2024

    Belgian Finance Minister Wants Debate On Veto On Tax Files

    The European Union should examine whether to limit the power of individual countries to veto tax legislation, Belgium's finance minister said Tuesday, adding that member states have sometimes used the unanimity rule as a way to hold files hostage. 

  • February 12, 2024

    Aussie Gov't Eyes Limited Public Country-By-Country Reports

    Companies with significant operations in Australia would need to begin publicly reporting tax data on operations in 41 jurisdictions on a country-by-country basis under a revised proposal the government released Monday following backlash to its original proposal's global scope and exceptional requirements.

  • February 12, 2024

    IRS To Float Requirements For Tax-Free Spinoffs, Official Says

    The Internal Revenue Service is planning to propose guidance that would replace regulations floated in 2016 to clarify when corporations can undertake spinoffs and other tax-free distributions without unlawfully distributing earnings and profits, an agency official said Monday.

  • February 12, 2024

    Malta Dividend Tax Refunds Cut Expected Revenue By €1.3B

    While Malta-based companies were expected to generate roughly €1.5 billion ($1.6 billion) in taxes on their foreign-earned income in 2022, they ultimately paid just €216.6 million because of a system that lets much of those taxes be refunded, a local news agency reported Monday.

  • February 12, 2024

    UAE Signs Tax Agreements With Kuwait, Bahrain, Egypt

    The United Arab Emirates signed agreements to prevent double taxation and address other cross-border tax issues with Kuwait, Bahrain and Egypt before a summit held in Dubai, the UAE's official news agency said.

  • February 12, 2024

    EU Countries Agree To Set Aside Russia Revenues

    European Union countries formally decided Monday to identify net income from immobilized Russian state assets and move them to separate accounts to help rebuild Ukraine, though it is unclear when the money will ultimately make it to Ukraine. 

  • February 09, 2024

    Pillar 2 Shouldn't Hit 'Double Dipping' Loss Rules, CPAs Say

    The Pillar Two international minimum tax agreement should not impact U.S. rules that are designed to prevent companies from "double dipping" with a single economic loss, the American Institute of Certified Public Accountants recommended in a letter made public Friday.

  • February 09, 2024

    Colombian Court OKs Lower Thresholds For Tax Sentences

    Colombian legislation that lets the country dole out certain prison sentences based on lower monetary amounts of tax fraud or evasion was approved by the country's highest court, the Colombian tax authority said.

  • February 09, 2024

    6th Circ. Backs Fine Against Doctor For Willful FBAR Violation

    A Michigan doctor clearly met the standard for a willful failure to file reports of foreign bank accounts, the Sixth Circuit said, confirming a lower court decision resulting in a $930,000 penalty against him.

  • February 09, 2024

    PwC Australia Probes Ex-CEO Under Fire In Aussie Senate

    PwC Australia is investigating claims that its former CEO had corrupt dealings with politicians, based on a whistleblower complaint shared with Law360 on Friday, as Australian senators said the firm snubbed Parliament by withholding a review into partners improperly sharing confidential drafts of tax laws.

  • February 09, 2024

    HMRC Seeking Input On New R&D Tax Relief Guidance

    HM Revenue & Customs asked Friday for the public to weigh in on guidance that would accompany changes to the U.K.'s research and development tax relief rules in preparation for the pending passage of the latest finance bill.

  • February 09, 2024

    Polish Co. Found Exploiting Exemption Pays $5M, Gov't Says

    A Polish real estate company paid over 20 million zloty ($5 million) in owed corporate income taxes after an audit revealed it was illegally taking advantage of an exemption from collecting and paying withholding tax, Polish tax authorities said Friday.

  • February 09, 2024

    Import Carbon Fee Having Positive Effect, EU Tax Chief Says

    A European Union program to charge a fee on imported goods entering the bloc from areas with weaker environmental rules is already having a positive impact, EU tax commissioner Paolo Gentiloni said Friday.

  • February 09, 2024

    Taxation With Representation: Sullivan & Cromwell, Kirkland

    In this week's Taxation With Representation, California Resources Corp. acquires Aera Energy, ZeroFox Holdings goes private, and Acerinox purchases Haynes International.

  • February 08, 2024

    3M Tells 8th Circ. IRS Used Invalid Regs To Allocate Income

    Multinational conglomerate 3M urged the Eighth Circuit to reverse a U.S. Tax Court decision upholding regulations that the IRS had used to disregard Brazilian legal restrictions when allocating the company's income, contending that the rules contravene an underlying transfer pricing statute.

  • February 08, 2024

    Neb. Justices To Hear Berkshire Unit's Repatriation Tax Fight

    The Nebraska Supreme Court agreed Thursday to directly review a Berkshire Hathaway entity's appeal of a district court's finding that the state's deduction for certain dividends doesn't apply to income repatriated under the 2017 federal tax overhaul.

  • February 08, 2024

    US Grantor Trusts Need Int'l Reporting Clarity, Treasury Told

    The U.S. Treasury Department should clarify that domestic grantor trusts aren't required to file international information returns, the American Institute of Certified Public Accountants said in a letter made public Thursday, claiming that current uncertainty has led to redundant reporting.

  • February 08, 2024

    German Court Convicts First In €80M Luxury Car VAT Fraud

    A German notary has become the first person convicted by a Berlin court for his role in what the European Public Prosecutor's Office said was an €80 million ($86.2 million) value-added tax fraud scheme involving luxury cars and medical face masks.

  • February 08, 2024

    DC Circ. Skeptical Of 5-Hour Energy Partner's Tax Challenge

    D.C. Circuit judges seemed skeptical of a Canadian citizen's argument that $6.5 million in gains she received from selling a share of a U.S. partnership that sold 5-Hour Energy drinks shouldn't be federally taxed, grappling to understand her reasoning during oral arguments Thursday.

  • February 08, 2024

    Ecuador Considering Smaller VAT Hike To Fund Crime Fight

    Ecuador's president introduced a proposal for a smaller, permanent value-added tax hike after his initial push for a larger but temporary increase, which he said would help fund the country's fight against organized crime, was voted down.

Expert Analysis

  • Participating In Living History Makes Me A Better Lawyer

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    My role as a baron in a living history group, and my work as volunteer corporate counsel for a book series fan association, has provided me several opportunities to practice in unexpected areas of law — opening doors to experiences that have nurtured invaluable personal and professional skills, says Matthew Parker at the Nebraska Department of Health and Human Services.

  • Private Equity Owners Can Remedy Law Firms' Agency Issues

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    Nonlawyer, private-equity ownership of law firms can benefit shareholders and others vulnerable to governance issues such as disparate interests, and can in turn help resolve agency problems, says Michael Di Gennaro at The Law Practice Exchange.

  • How Taxpayers Can Prep As Justices Weigh Repatriation Tax

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    The U.S. Supreme Court might strike down the 2017 federal tax overhaul's corporate repatriation tax in Moore v. U.S., so taxpayers should file protective tax refund claims before the case is decided and repatriate previously taxed earnings that could become entangled in dubious potential Section 965 refunds, say Jenny Austin and Gary Wilcox at Mayer Brown.

  • OFAC Designation Prosecutions Are Constitutionally Suspect

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    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.

  • How The OECD Global Tax Proposal Could Affect M&A

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    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.

  • UK Shares-Tax Proposals Offer Long-Awaited Modernization

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    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.

  • IRS Foreign Tax Credit Pause Is Welcome Course Correction

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    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.

  • IRS Criminal Probe Spells Uncertainty For Malta Pension Plans

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    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.

  • IRS Announcement Will Aid Cos. In Buyback Tax Planning

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    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.

  • Flawed Analysis Supports Common Law Tax Deficiency Ruling

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    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.

  • Review Of Repatriation Tax Sets Justices On Slippery Slope

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    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.

  • What To Make Of IRS' New Advance Pricing Guidance

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    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.

  • Reserved Investor Fund Would Plug Gap In UK Finance Market

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    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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