International

  • November 29, 2021

    HMRC Can Take Team Owner's £2.5M Tax Relief, Tribunal Says

    A U.K. tribunal affirmed a lower tribunal's ruling that allowed HM Revenue & Customs to withdraw £2.5 million ($3.33 million) in tax relief on a soccer club owner's purchase but tossed a £1.3 million bill on transactions it preapproved.

  • November 25, 2021

    Estonia Willing To Veto EU OECD Tax Deal Law If Dissatisfied

    Estonia is willing to veto European Union laws formalizing the global agreement to fundamentally reform the international tax system if it threatens the country's current business-friendly regime, the state's finance minister said on Thursday.

  • November 24, 2021

    UK Biz For Chinese Students Owes $1.9M VAT, Tax Court Says

    A career coaching company for Chinese students in the U.K. owes £1.42 million ($1.9 million) in value-added taxes for failing to properly vet clients' residency as required by a 2011 European Council directive, Britain's Upper Tribunal said.

  • November 24, 2021

    7 Things Tax Pros Are Grateful For This Thanksgiving Season

    From the continued extension of federal and state tax deadlines because of the pandemic to clarification on forgiven Paycheck Protection Program loans and the agreement on a global corporate tax overhaul, tax attorneys are grateful for many things this Thanksgiving. Here, Law360 reviews seven developments tax professionals are thankful for this year.

  • November 24, 2021

    Denmark Urges Compelled Disclosure In $2.1B Tax Case

    A federal court must compel two defendants in a $2.1 billion tax refund dispute with Denmark's tax authority to surrender documents on refund requests made to other tax authorities because they're relevant in the Danish case, the tax agency said.  

  • November 24, 2021

    Pro-Business Party To Get German Finance Ministry

    The pro-business Free Democratic Party is due to take over the Finance Ministry in the next German government, the coalition agreement for the three parties expected to be in the next government showed Wednesday. 

  • November 24, 2021

    Corp. AMT Plan May Blur Line Between Tax, Financial Data

    A proposed alternative minimum tax based on financial statements has sparked concerns among accounting experts, who worry that blending two separate systems for measuring corporate income could undermine the underlying — and intentionally different — purposes of each one.

  • November 24, 2021

    Sweden's Risk Tax Isn't State Aid, EU Commission Says

    A Swedish proposal to institute a risk tax on large credit institutions does not amount to an illegal state aid measure despite the claims of the country's banking lobby, the European Commission said Wednesday.

  • November 24, 2021

    EU Won't Drop VAT For Turnover Tax, Commissioner Says

    The European Union has no plans to drop value-added tax and replace it with a turnover tax, the bloc's tax commissioner said in a letter to a member of the European Parliament published Wednesday.

  • November 23, 2021

    Russian Scientist's Income Is Taxable, IRS Tells 4th Circ.

    The IRS urged the Fourth Circuit on Tuesday to reverse a U.S. Tax Court decision finding payments to a Russian scientist at a Virginia facility aren't taxable, arguing his income isn't exempt under the U.S.-Russia tax treaty.

  • November 23, 2021

    Calif. Man Owes $2M In FBAR Penalties, Interest, Court Says

    A Californian was ordered Tuesday to pay more than $2 million in penalties and interest to the U.S. government in a case in which he admitted that he had failed to file reports of foreign bank accounts.

  • November 23, 2021

    Shell Companies Detrimental To Netherlands, Gov't Reports

    Shell companies are detrimental to the Netherlands because they contribute little to the economy, rob developing countries of tax revenue and damage the country's reputation, according to a Dutch government commission's final report.

  • November 23, 2021

    US Settles $477K FBAR Case With Floridian Estate

    The estate of a Florida securities broker resolved almost half a million dollars in penalties by settling allegations by the U.S. government that the broker failed to report her foreign bank accounts.

  • November 23, 2021

    UK Taxpayers Warned Against Sharing HMRC Login Info

    Taxpayers shouldn't provide their HM Revenue & Customs login credentials to anyone, including advisers they have nominated to act on their behalf, according to an advocacy group for low-income taxpayers that warned against unscrupulous tax refund companies.

  • November 23, 2021

    French Minister Suggests Expanding Carbon Deal Beyond EU

    The European Union should be open to agreement on its so-called carbon border adjustment mechanism with non-EU countries, a French minister said, adding that internal agreement on the tax would give the EU more leverage in negotiating outside the bloc.

  • November 23, 2021

    Turkey Joins US-Led Pact To Scrap Digital Taxes

    Turkey joined a pledge among countries to drop their digital services taxes in a deal with the United States following the conclusion of talks by the Organization for Economic Cooperation and Development to overhaul the international tax system.

  • November 22, 2021

    Clifford Chance Builds Int'l Practice By Adding Osler Partner

    Clifford Chance announced Monday that it is bolstering its U.S and international tax, pensions and employment practice, bringing to its New York office a former managing partner from Osler Hoskin & Harcourt with extensive experience in cross-border corporate transactions.

  • November 22, 2021

    Court Lifts Fla. Accountant's Curfew, Keeps $80M Bond

    A Florida accountant accused of hiding $93 million earned through a Russian company is free from an 8 p.m. curfew after having persuaded a federal court to modify his terms of release, but he still faces an $80 million bond.

  • November 22, 2021

    Transfer Pricing Disputes Rising While Others Fall, OECD Says

    The number of transfer pricing disputes that were either opened or closed between jurisdictions grew in 2020 compared with the previous year, while the number of other cases shrank, the Organization for Economic Cooperation and Development said Monday.

  • November 22, 2021

    US Accepts Settlement In $49K FBAR Case

    The United States government told a California federal court Monday it had accepted a settlement from a woman accused of failing to report interest in 14 United Kingdom bank accounts, which led to $49,000 in fines being assessed.

  • November 22, 2021

    EU Urged To Let Tax Body Critique Personal Income Rules

    The European Union should expand the scope of its Code of Conduct Group for business taxation, which highlights objectionable tax practices within the bloc, to include personal income tax matters, an EU-funded think tank said Monday.

  • November 22, 2021

    2 Chinese Livestreamers Fined $14.6M For Tax Evasion

    Two Chinese livestreamers have been fined nearly $14.6 million in total for evading taxes, according to an announcement Monday from the city-level tax authority in Hangzhou, Zhejiang province.

  • November 19, 2021

    Tax Havens Told US To Look Inward, Ex-IRS Official Says

    When Don Fort visited tax havens during his three-decade career at the Internal Revenue Service, officials often challenged him by saying the U.S. needed to police its own states' tax schemes before lecturing others, he said Friday during a panel.

  • November 19, 2021

    Woman Says Ex-Atty Flubbed Response To $4M FBAR Suit

    A New York federal court should let a woman amend her answer to accusations that she owes $4.1 million for failing to report Swiss bank accounts on the grounds that her former counsel mistakenly said she controlled them, her attorneys said. 

  • November 19, 2021

    NY Electronics Exporter Owes $625K In FBAR Fines, US Says

    A New York electronics exporter owes more than $625,000 in FBAR penalties plus interest for failing to disclose a Swiss bank account held by a British Virgin Islands corporation that he solely owned, the U.S. said Friday.

Featured Stories

  • 7 Things Tax Pros Are Grateful For This Thanksgiving Season

    Amy Lee Rosen

    From the continued extension of federal and state tax deadlines because of the pandemic to clarification on forgiven Paycheck Protection Program loans and the agreement on a global corporate tax overhaul, tax attorneys are grateful for many things this Thanksgiving. Here, Law360 reviews seven developments tax professionals are thankful for this year.

  • Corp. AMT Plan May Blur Line Between Tax, Financial Data

    Natalie Olivo

    A proposed alternative minimum tax based on financial statements has sparked concerns among accounting experts, who worry that blending two separate systems for measuring corporate income could undermine the underlying — and intentionally different — purposes of each one.

  • FATCA Data Transfers Likely Safe From Court Challenges

    Natalie Olivo

    A European Union court ruling that invalidated mechanisms used to transfer personal data across the Atlantic is unlikely to bolster privacy-related challenges against the U.S. Foreign Account Tax Compliance Act's information exchange agreements, which have so far survived litigation overseas.

Expert Analysis

  • Navigating FCPA Risks Of Minority-Owned Joint Ventures

    Author Photo

    The U.S. Department of Justice and U.S. Securities and Exchange Commission will likely continue to focus on third-party risks under the Foreign Corrupt Practices Act, so companies with minority-owned joint ventures should take several steps to mitigate related compliance challenges, say Ben Kimberley at The Clorox Company and Addison Thompson at Covington.

  • Questions To Ask If Doing Business In A Corruption Hot Spot

    Author Photo

    Businesses facing new scrutiny after the U.S. Department of Justice's recently announced task force for combating human trafficking in Central America, the release of the Pandora Papers and continuing fallout from 2019's Panama Papers, should address compliance risks by having employees ask three questions about every transaction, say attorneys at White & Case.

  • How The Global Tax Agreement Could Backfire For Biden

    Author Photo

    If the $3.5 trillion spending package fails, the federal tax code will not conform to the recent 15% global minimum tax agreement spearheaded by the U.S., which would embarrass the Biden administration and could lead to retaliatory tax measures by other nations, says Alex Parker at Capitol Counsel.

  • Pandora Papers Reveal Need For Greater Tax Enforcement

    Author Photo

    The recent Pandora Papers leak is a reminder of the importance of transparency laws and proper funding for enforcement efforts against tax evasion as bad actors increasingly operate in the shadows, says Daren Firestone and Kevin Crenny at Levy Firestone.

  • Parsing New Int'l Tax Reporting Rules For Pass-Throughs

    Author Photo

    Attorneys at Grant Thornton unpack the Internal Revenue Service’s new pass-through entity reporting requirements for international tax matters and the accompanying guidance for penalty relief, and suggest how companies should prepare for what may be the most significant change to the partnership compliance function in decades.

  • A Look At Global Tax Enforcement Developments: Part 2

    Excerpt from Practical Guidance
    Author Photo

    Sean Craig at LexisNexis examines recent investigations by the Joint Chiefs of Global Tax Enforcement and their impact on U.S. taxpayers, as well as the growing significance of transfer pricing disputes and policies for future enforcement.

  • A Look At Global Tax Enforcement Developments: Part 1

    Excerpt from Practical Guidance
    Author Photo

    Sean Craig at LexisNexis looks at how international initiatives, such as the Joint Chiefs of Global Tax Enforcement, are addressing cryptocurrency-related tax evasion, and how the COVID-19 pandemic and increasing demands for governmental welfare programs are driving global tax policy.

  • EU Climate Plan Should Involve Taxing Pollution, Not Borders

    Author Photo

    In order to crack down on greenhouse gas emissions, the European Union proposes to levy carbon emissions at its borders and to overhaul its long-standing energy tax framework, but the latter would hold polluters directly accountable, giving it the better chance for success, says Rebecca Christie at Bruegel.

  • Prepare For Global Tax Regime's New Biz Dispute Risks

    Author Photo

    Companies should take steps to mitigate the business dispute risks of the new international tax framework, which over a hundred countries agreed to in July, as implementing the new regime will be expensive and require substantial organizational restructuring efforts, says Tim McCarthy at Dykema.

  • Prepare For More Audits Of Tax Info And Withholding Filings

    Author Photo

    Financial institutions and other corporate taxpayers should focus compliance efforts on tax information reporting and withholding, given recent indications from the Biden administration that the IRS will increase enforcement, and the administration's need to fund its infrastructure plan and other costly initiatives, say attorneys at Mayer Brown.

  • Anti-Boycott Compliance Still Key In UAE Business Dealings

    Author Photo

    Notwithstanding recent amendments to U.S. anti-boycott laws that reflect the United Arab Emirates' withdrawal from the Arab boycott of Israel, companies doing business in the UAE and elsewhere still need to maintain effective anti-boycott compliance programs to avoid reporting violations or penalties, says Howard Weissman at Miller Canfield.

  • 9th Circ. Adds Pressure To Reject Substance Over Form

    Author Photo

    The Ninth Circuit’s recent decision rejecting taxes on a family's Roth IRA payments that were made through a foreign sales corporation represents a refreshing trend among federal appeals courts to reject substance-over-form principles and instead look to congressional intent, say Lawrence Hill and Caitlin Tharp at Steptoe & Johnson.

  • Will The OECD Plan Fix International Taxation?

    Author Photo

    Lilian Faulhaber at Georgetown Law breaks down the Organization for Economic Cooperation and Development’s plan for international tax reform, recently joined by 130 countries, and whether it will solve the problems it was designed to address, including the need for multinational companies to pay their fair share of taxes in the digitized world economy.