International

  • January 30, 2024

    Ex-Freshfields Lawyer Gets 3½ Years In €389M Cum-Ex Case

    A former top tax lawyer for Freshfields Bruckhaus Deringer LLP was sentenced Tuesday to three-and-a-half years in prison by a regional German court for his role in a cum-ex scheme that cost tax authorities €389 million ($421.5 million), according to a local news agency.

  • January 30, 2024

    IMF Warns UK Against Tax Cuts Amid Financial Strains

    The International Monetary Fund said Tuesday that it is advising the U.K. government to not make tax cuts in the upcoming spring budget because it needs to maintain public spending.

  • January 30, 2024

    Employee Faking Invoices Can Be Liable For VAT, ECJ Says

    A Polish fuel seller's employee using her company's details without its consent to issue fraudulent value-added tax receipts can be held liable for paying the VAT, provided that the company took appropriate anti-fraud measures, the European Court of Justice ruled Tuesday.

  • January 30, 2024

    EU Opens Probe Into Swedish Tax Breaks For Biogas

    The European Commission has opened a probe to determine if two Swedish tax exemption schemes for nonfood-based biogas and biopropane used for heating are in line with the European Union's state aid rules, the commission said Tuesday.

  • January 29, 2024

    Int'l Pricing Method Much Faster Than Others, Report Says

    Tax authorities under a multilateral program assessed risks associated with a company's transfer pricing positions in less than half the time of other methods, according to a report published Monday.

  • January 29, 2024

    R&D Credit Amendments Proposed For UK Finance Bill

    A pair of amendments that would further adjust the treatment of research and development tax credits in the latest U.K. finance bill to avoid double-counting were published by HM Revenue & Customs on Monday.

  • January 29, 2024

    Norway Agencies Want More Transparent Ownership Info

    It is too difficult for relevant agencies to determine the true owners of real estate and stocks in Norway, especially when they are foreign owners, three Norwegian agencies said in a survey released Monday.

  • January 29, 2024

    Tax Group Of The Year: Sullivan & Cromwell

    Sullivan & Cromwell LLP's tax practice advised Abiomed on the tax aspects of its acquisition by Johnson & Johnson in the largest medtech deal in history last year, earning the firm a spot among Law360's 2023 Tax Groups of the Year.

  • January 29, 2024

    HMRC Started Over 1,000 Serious Tax Probes In 2022-23

    The U.K. tax authority launched more than 1,000 serious tax investigations in the fiscal year ended March 31, 2023, following a yearly increase in tax evasion and avoidance, Pinsent Masons LLP said on Monday.

  • January 29, 2024

    EU Member States Extend Sanctions Against Russia

    The European Union decided to roll over existing economic sanctions against Russia because of its war against Ukraine for another six months until July 31, the council of member countries said Monday. 

  • January 26, 2024

    US Proved Daughters Fraudulently Moved $1.4M, Court Says

    The U.S. government proved that two daughters fraudulently transferred $1.4 million to their U.S. bank accounts from their mother's Israeli bank, but it failed to name and support the amount of damages it seeks, a Florida federal court said.

  • February 08, 2024

    Law360 Seeks Members For Its 2024 Editorial Boards

    Law360 is looking for avid readers of its publications to serve as members of its 2024 editorial advisory boards.

  • January 26, 2024

    Hungary Adjusts Pharmaceutical Tax To Conform To Pillar 2

    Hungary amended a special tax rate for pharmaceutical manufacturers to conform to the Organization for Economic Cooperation and Development's global corporate minimum tax, the country's Ministry of Finance said Friday.

  • January 26, 2024

    HMRC Transfer Pricing Inquiries Took 5 Months Longer

    HM Revenue & Customs fielded fewer transfer pricing inquiries in 2022-23 compared with the prior tax year, but the time it took to close them went up by almost five months, according to statistics released by the British tax authority.

  • January 26, 2024

    Bipartisan Tax Break Bill Faces Rocky Road To Passage

    A bipartisan tax bill that quickly cleared the House's tax panel faces a tumultuous path forward in the full chamber, where Speaker Mike Johnson, R-La., needs to either have robust bipartisan support to pass the bill or risk opening it up to changes.

  • January 26, 2024

    Tax Group Of The Year: Mayer Brown

    Mayer Brown LLP secured local and global victories in 2023, from a Washington state appellate court's decision in a novel sales tax case to an energy company's $307 million merger resulting in a business with an Africa exploration and production focus, earning the firm a spot among Law360's Tax Groups of the Year.

  • January 26, 2024

    EU Defends Latest Economic Sanctions Against Russia

    The European Union on Friday defended its new round of economic sanctions to be imposed on Russia against claims from the Kremlin that all EU sanctions are illegal and harm Europe and the world.

  • January 26, 2024

    Biz Lobby Urges That BEFIT Wait On Stable Global Tax Rules

    A European business lobby criticized a new draft framework for corporate taxation in the European Union, saying it does not achieve its goals of reducing compliance costs and simplifying the tax landscape and should be delayed until global tax rules stabilize.

  • January 26, 2024

    US Expatriations Rise In 4th Quarter, IRS Says

    The number of people who expatriated from the U.S. jumped nearly 45% during the fourth quarter of 2023 compared with the previous quarter, the Internal Revenue Service said in a notice published Friday.

  • January 25, 2024

    UK Tribunal Rejects Ruling On Foreign Dividend Tax Relief

    Investment funds and an insurance company challenging whether their double tax relief claims for taxes paid on foreign dividend payments were proper could face stricter rules on those provisions after a U.K. Upper Tribunal on Thursday rejected a more flexible interpretation of those laws.

  • January 25, 2024

    ECJ Adviser Rejects Spanish Excise Taxes On Mineral Oils

    A European Union state cannot impose varying levels of excise taxes on mineral oils for autonomous regions, an adviser to the European Court of Justice said Thursday in a preliminary ruling sought by Spanish courts.

  • January 25, 2024

    John Hancock Clients Owed Tax Credit Perk, 11th Circ. Told

    John Hancock Life Insurance Co. clients urged an Eleventh Circuit panel on Thursday to reverse a lower court's ruling that the company didn't breach a fiduciary duty when $100 million worth of foreign tax credits wasn't passed through to them, saying the transaction diminished the value of their retirement accounts.

  • January 25, 2024

    EU Says 9 Members Late To Enact Global Minimum Tax Rules

    Nine countries that delayed adoption of the 15% global minimum tax haven't complied with rules saying they must order their multinational companies to require a subsidiary in a country with the tax to file a return for the group, the European Commission said Thursday.

  • January 25, 2024

    Aussie Mining Cos. Call For Tax Break To Counter US Credit

    Mining companies in Australia asked the country's government Thursday to establish a tax credit to make up for business lost to the U.S. as a consequence of the Inflation Reduction Act.

  • January 25, 2024

    Loeb & Loeb Hires 20-Year McDermott Tax Partner In Chicago

    Loeb & Loeb LLP has hired a McDermott Will & Emery LLP partner who spent the past 20 years at the platform working on tax and estate planning matters, according to a Thursday announcement.

Expert Analysis

  • Stock Buyback Excise Tax Guidance A Mixed Bag For SPACs

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    Recent IRS guidance on the new stock repurchase excise tax includes a welcome exception for publicly traded special-purpose acquisition companies but does not exclude redemptions in connection with a de-SPAC transaction, and further guidance is needed to clarify ambiguities around the exception's application, say Olga Bogush and Evgeny Magidenko at ArentFox Schiff.

  • The IRS' APA Rulemaking Journey: There And Back Again

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    Attorneys at Dentons examine recent challenges in which taxpayers successfully argued Internal Revenue Service rulemaking was invalid under the Administrative Procedure Act, how tax exceptionalism and U.S. Supreme Court regulatory deference prompted such challenges, and similar challenges the agency will likely face following this line of cases.

  • ECJ Fiat Ruling Sets Clear Boundaries For EU State Aid Law

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    The European Court of Justice's recent landmark decision in Fiat v. Commission limiting the commission’s attempts to circumvent the lack of EU powers in the area of tax law has important implications in EU state aid law and beyond, say Andreas Reindl and Pietro Stella at Van Bael.

  • Unpacking The Interim Guidance On New Stock Buyback Tax

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    The U.S. Department of the Treasury and Internal Revenue Service's recent notice on applying the newly effective excise tax on stock repurchases provides much-needed clarity on the tax's scope, which is much broader than anticipated given its underlying policy rationale, say attorneys at Eversheds Sutherland.

  • IRS Will Use New Resources To Increase Scrutiny In 2023

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    The new year promises to be a busy one for the Internal Revenue Service, which is poised to apply the boost in funding provided by the Inflation Reduction Act to bolster and expand its enforcement capability, and there are four areas to watch, say attorneys at Skadden.

  • How Japan's Implementation May Change The Pillar 2 Debate

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    Japan’s outline of proposed legislation adopting a primary component of the Organization for Economic Cooperation and Development's 15% global minimum tax will increase pressure on countries — including the U.S. — that have not committed to adopting Pillar Two, says Takato Masuda of Nishimura & Asahi.

  • Foreign Tax Credit Proposal Is Some Help, But More Is Needed

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    New foreign tax credit regulations proposed by the U.S. Treasury Department provided some measure of relief on cost recovery and royalty withholding, two of the most troublesome aspects of the 2021 final foreign tax credit regulations, but the final regulations are still harmful to many taxpayers, making litigation inevitable, say attorneys at Fenwick.

  • IRS' Tax Gap Statistics Don't Paint A Full Compliance Picture

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    The Internal Revenue Service's recent report indicating a widening tax gap sheds important light on tax compliance, underlines key pressure points and provides insights into how tax administration could be improved; but tax gap estimates also have their limits, says Joyce Beebe at Rice University.

  • How High Court Could Change FBAR Penalty Landscape

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    On Wednesday, the U.S. Supreme Court will hear Bittner v. U.S., a case that will affect many people penalized for failing to file a Report of Foreign Bank and Financial Accounts, and there are important procedural implications should the government's position be reversed, say Reuben Muller and Andreas Apostolides at Cole Schotz.

  • IRS Memo May Change IP Royalty Tax Prepayment Planning

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    A recent Internal Revenue Service advice memorandum finding a taxpayer was not permitted to prepay tax on contingent royalties after contributing intellectual property offshore is a noteworthy departure from earlier guidance that highlights potential differences between actual and deemed licenses, says William Skinner at Fenwick.

  • What IRS Funding Increase Means For Taxpayers

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    The Internal Revenue Service will first use the influx of funding from the Inflation Reduction Act to address customer support and personnel issues, but with over half the money allocated to enforcement, corporations and high-net-worth individuals will face increased scrutiny, say Patrick McCann Jr. and Jasen Hanson at Chamberlain Hrdlicka.

  • 6 Tax Considerations For Life Sciences Collaboration Deals

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    Given recent IRS guidance and changes to certain tax rates and deductions, biotech and life sciences companies entering into collaboration agreements should assess several unique taxation issues affecting matters ranging from research and development expenditures to profit-sharing terms, say attorneys at Orrick and Andersen Tax.

  • Rushed Multilateral Negotiations Caused Two-Pillar Tax Mess

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    Cracks appearing in the two pillars of the 2021 global tax plan stem from a multilateral tax policy process that rushed to issue rules without first resolving fundamental differences between countries or ensuring that the U.S., a key player, could implement them, says Jefferson VanderWolk at Squire Patton.

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