International

  • February 02, 2024

    Taxation With Representation: Simpson, Wachtell Lipton

    In this week's Taxation With Representation, Rise Growth Partners receives a $250 million investment, a group of investors led by Carlyle Group co-founder David Rubenstein acquires a controlling stake in MLB's Baltimore Orioles, The Cigna Group sells multiple Medicare businesses to Health Care Service Corp., and WillScot Mobile buys McGrath RentCorp.

  • February 02, 2024

    CPS Denies Liability in Ex-Sidley Lawyer Failed Prosecution

    The Crown Prosecution Service has denied being liable for its botched tax fraud prosecution of a former Sidley Austin LLP lawyer, a former senior KPMG official and a banking adviser, who are collectively seeking more than £66 million ($84 million) from the U.K.'s main prosecutor.

  • February 01, 2024

    Kemp Klein Brings On Tax Attorney From Foster Swift

    Kemp Klein Law Firm said Thursday that it added a shareholder to its team who was formerly with Foster Swift Collins & Smith PC and counsels clients in tax planning.

  • February 01, 2024

    India Budget Includes Abrupt End Of Manufacturing Tax Break

    India plans to allow its reduced corporate income tax rate for manufacturing facilities to sunset in April in an unexpected move, while seeking extensions to tax holidays for startups and sovereign wealth funds, attorneys told Law360 on Thursday about the government's interim budget.

  • February 01, 2024

    Lawyer Convicted Of Tax Fraud Can't Halt Disciplinary Case

    An English tribunal refused Thursday to throw out a disciplinary case against a lawyer over his conviction for tax fraud in the U.S., rejecting his argument that it couldn't hear his case because he wasn't a registered solicitor at the time.

  • February 01, 2024

    Canada Seeks Input On Patent Box Regime, R&D Credit

    Canada is asking the public for input on whether a patent box tax regime would be suitable for the country and whether the government can improve the structure of its research and development tax credit.

  • February 01, 2024

    EU Leaders Slow Plan To Use Frozen Russian Assets

    European Union leaders reined in the bloc's rush to use frozen and immobilized Russian state assets for the reconstruction of Ukraine, as leaders from Germany, France and Italy called for caution Thursday.

  • February 01, 2024

    Italy Working On Social Media Tool To Detect Tax Evasion

    Italian authorities are developing a tool to compare social media users' posts against their tax returns to flag potential tax evasion, an official with the country's Finance Ministry said.

  • February 01, 2024

    Duet Group Co-Founder Gets Nearly 5-Year Cum-Ex Sentence

    The co-founder of the London-based Duet Group investment firm received a nearly five-year jail sentence for crimes related to so-called cum-ex activities following a trial in Germany, a person familiar with the verdict confirmed to Law360 on Thursday.

  • February 01, 2024

    Payroll Biz Director Can't Challenge £21M VAT Fraud Decision

    A London judge has refused a bid by a director of a defunct payroll services company to overturn a finding that he defrauded the taxpayer of £21 million ($26 million) by under-declaring value-added tax.

  • January 31, 2024

    House Sends Bipartisan Tax Break Package To Senate

    The House of Representatives passed a bipartisan bill Wednesday night that would extend the full tax break for research and development costs and expand the child tax credit for multiple years, sending the deal to the Senate for consideration.

  • January 31, 2024

    Serbian Dual Citizen Must Pay $5.3M FBAR Penalty

    A man with dual citizenship in the U.S. and Serbia will have to pay $5.3 million in penalties and interest for willful failure to report a Swiss bank account, according to a judgment a New York federal judge issued Wednesday.

  • January 31, 2024

    Feds Urged To Adopt EV Battery Tracing For Tax Credit Rules

    A mechanism to trace the source of battery materials in electric vehicles would help enforce manufacturers' compliance with the domestic content requirements that are now linked to the EV consumer tax credit, stakeholders told U.S. Treasury Department and IRS officials Wednesday.

  • January 31, 2024

    Ex-Ga. Tech Prof Gets Home Confinement For Tax Fraud

    A former Georgia Institute of Technology professor was sentenced to a year of home confinement and three years' probation on Wednesday for shirking hundreds of thousands of dollars in federal taxes by inflating his charitable deductions through a scheme involving Chinese nationals' donations to the university.

  • January 31, 2024

    GILTI Succeeds While FDII, BEAT Struggle, Think Tank Says

    The three main international tax provisions of 2017's Tax Cuts and Jobs Act — GILTI, FDII and the BEAT — have had mixed success, but lawmakers should be careful to retain the beneficial parts while considering any changes to better fit into the global tax structure, the Tax Foundation said Wednesday.

  • January 31, 2024

    EU Seeks To Extend Import Duty Freeze For Ukrainian Goods

    The European Commission proposed Wednesday that the European Union extend its suspension of customs duties and quotas on Ukrainian imports for one more year while introducing exemptions for certain food products. 

  • January 31, 2024

    German Tax Revenue Rose Below Inflation Rate, Report Says

    German tax revenue increased by 1.8% last year, a report from the country's Finance Ministry said, though it added that weak economic growth and tax reduction measures depressed government intake to growth that was below the rate of inflation. 

  • January 30, 2024

    Ashurst Brings On Specialist Funds Tax Partner

    Ashurst added a tax specialist from Arendt & Medernach to its Luxembourg office to strengthen the firm's presence in the country, Ashurst announced.

  • January 30, 2024

    Cities Compete To Host EU's New AML Center

    Representatives from Paris, Rome, Vienna and other European cities touted living conditions, generous financial offers and track records of fighting dirty money at a hearing Tuesday where they presented bids to host the European Union's new authority to fight money laundering and terrorist financing.

  • January 30, 2024

    Latvia Delaying Global Minimum Tax Until 2029

    Latvia's executive body voted Tuesday to delay carrying out the European Union's directive on the global corporate minimum tax until 2029 under an exception afforded to member countries with little to no in-scope companies doing business there.

  • January 30, 2024

    India's APA Network Rivals Germany And China, Report Says

    India's tax authority has accrued roughly the same number of bilateral advance pricing agreements as Germany and China despite beginning its program later, but scaling to meet demand will present challenges, two officers at the Indian Revenue Service said in a brief.

  • January 30, 2024

    French Court Won't Revive Case Against FATCA Transfers

    France's highest administrative court on Tuesday upheld a decision from the country's data protection agency, which had tossed a challenge against the transfer of financial information about certain individuals to U.S. tax authorities under the Foreign Account Tax Compliance Act.

  • January 30, 2024

    Spain Implementing Digital Platform Reporting Rules

    Spain's government approved a measure Tuesday adopting the European Union's tax information reporting procedures for digital platform operators, known as DAC7, as well as standards in line with the OECD's automatic exchanges of information.

  • January 30, 2024

    Spencer Fane Adds Tampa Tax Partner From Gunster

    Spencer Fane LLP has added a partner focused on corporate and tax matters from Florida firm Gunster to its Tampa office.

  • January 30, 2024

    EU Gives More Time For Carbon Import Reporting After Glitch

    Companies that a system glitch prevented from filing required information related to the European Union's new fee on carbon-intensive imports will have extra time to submit the information, the European Commission said.

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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