International

  • May 01, 2024

    UN Must Improve Corp. Tax Rules, Platforms, Some Gov'ts Say

    Governments must commit to improving existing corporate tax rules and platforms created at the OECD within the terms of reference for a United Nations framework convention on global tax cooperation, two tax officials who participated in drafting those rules said Wednesday.

  • May 01, 2024

    HMRC Simplifies Late Filing Penalties For Digital Filers

    U.K. taxpayers voluntarily filing their personal income tax returns using a program intended to modernize the country's tax system will receive more leniency and access to a simpler penalty structure in cases of late filing, HM Revenue & Customs said.

  • May 01, 2024

    Hong Kong Proposes Amended Automatic Info Exchange List

    Hong Kong is considering adjusting the list of countries it automatically exchanges financial information with by subtracting nine jurisdictions and adding 11, which the country's tax authority said is in line with recommendations from the Organization for Economic Cooperation and Development.

  • May 01, 2024

    Swiss Sends Amendment To Serbian Tax Treaty To Parliament

    Switzerland's executive body, the Federal Council, sent to the country's parliament Wednesday an amendment for the country's double-taxation treaty with Serbia that would bring it in line with the OECD's base erosion and profit shifting standards, the council said.

  • April 30, 2024

    India, Belgium, Others Support UN Taking On Wealth Taxation

    Governments should make a high-level commitment to reach agreement on the taxation of wealthy individuals within the United Nations framework convention on international tax cooperation, representatives of India, Belgium, Austria, Nigeria and Kenya said Tuesday.

  • April 30, 2024

    Yellen Says US Pushing To Protect R&D Credit Under Pillar 2

    U.S. Treasury Department negotiators are continuing to advocate for more favorable treatment of the country's research and development tax credit under the Pillar Two global minimum tax rules, Treasury Secretary Janet Yellen told the House Ways and Means Committee on Tuesday.

  • April 30, 2024

    German Banker Gets 3 Years For €93M Cum-Ex Tax Evasion

    A German court on Tuesday sentenced a former bank board member to three years and two months in prison for his part in a €93.4 million ($100 million) so-called cum-ex dividend tax fraud.

  • April 30, 2024

    HMRC Proposes Special Economic Zone Tax Relief Extensions

    HM Revenue & Customs proposed Tuesday to extend the time to claim tax relief measures available in special economic zones in the U.K. to 2031 in England and to 2034 in other parts of the country.

  • April 30, 2024

    The Tax Angle: TCJA Teams, Dear Colleague Letters

    From a look at House GOP efforts to prepare for next year's expiration of their 2017 tax overhaul to ongoing attempts by lawmakers to draw attention and support for their own tax legislation, here's a peek into a reporter's notebook on a few of the week's developing tax stories.

  • April 30, 2024

    Global Climate Tax Could Fund Disaster Aid, Report Says

    If OECD countries adopted a tax on the extraction of fossil fuels proposed by over 100 climate organizations, $900 billion could be generated cumulatively by 2030, a majority of which would be earmarked for those hit by climate disasters, some of those groups reported.

  • April 30, 2024

    EU Tax System Needs To Aid Climate Policy, Accountants Say

    European Union lawmakers should design a tax system in their next five-year legislative term that supports the green transition and long-term employment, a European lobby for accountants said in a document posted Tuesday.

  • April 29, 2024

    Court Can Make Widow Pull $2.5M From Swiss Bank, US Says

    A Colorado federal court can force a widow to send $2.5 million from a Swiss bank to the U.S. to repay her late husband's penalties and interest for failing to report his foreign accounts, the U.S. told the court.

  • April 29, 2024

    OECD Nations Steer UN Tax Talks Toward Decision-Making

    The terms of reference for a United Nations global tax convention should guide the decision-making of a committee that will negotiate substantive provisions later even though some governments prefer to defer debate on the decision-making procedures to the General Assembly, several OECD government representatives said Monday.

  • April 29, 2024

    Canada Opens Second R&D Tax Credit Consultation

    With an additional CA$600 million ($439 million) earmarked for its scientific research and experimental development tax incentive program, Canada is looking for more specific feedback on expanding and otherwise adjusting the regime.

  • April 29, 2024

    Poland Pushes Back Mandatory E-Filing After Finding Flaws

    Polish businesses with sales totaling more than 200 million zloty ($50 million) won't have to use the country's electronic invoice system until 2025, with the full rollout delayed until 2026, due to multiple problems uncovered in the system, the country's tax authority said.

  • April 29, 2024

    OECD-UN Initiative Lands Developing Countries $2.3B In Tax

    A joint initiative between the Organization for Economic Cooperation and Development and the United Nations to help developing countries boost tax revenues said Monday that it has generated $2.3 billion in additional revenues and $6.05 billion in additional tax assessments since its 2015 formation.

  • April 29, 2024

    Ex-Man City Player Benjamin Mendy Pays £710K Tax Debt

    Former Manchester City footballer Benjamin Mendy avoided bankruptcy on Monday after paying a £710,000 ($892,000) tax bill minutes before a court hearing to determine whether an order should be made.

  • April 29, 2024

    US Expatriations Plummet In 1st Quarter, IRS Says

    The number of people who expatriated from the U.S. fell nearly 70% during the first quarter of 2024 compared with the previous quarter, the Internal Revenue Service said in a notice published Monday.

  • April 29, 2024

    EU Official Wants Progress On New Revenue Streams

    The budget commissioner of the European Union said Monday that the bloc must make progress toward agreeing on new revenue streams that would give it more diversified sources of income.

  • April 26, 2024

    4 Goals For Gov'ts To Pursue In The UN Tax Convention

    The United Nations' framework convention on international tax cooperation should resolve digital taxation, incorporate tax transparency conventions, seek consensus on tax allocation issues but adopt best practices by simple majority, and help fund development goals, officials and experts told Law360 as governments began negotiations Friday.

  • April 26, 2024

    FedEx Calls Gov't Arguments On Tax Credits Contradictory

    The federal government advanced contradictory arguments in FedEx's $84.6 million foreign tax credits dispute with the Internal Revenue Service, the package delivery giant said in a filing in Tennessee federal court.

  • April 26, 2024

    Ireland Received Nearly €24B In Corp. Taxes In 2023

    Corporations paid Ireland €23.8 billion ($25.5 billion) in taxes in 2023, a 5.3% increase over 2022, making corporate tax receipts the second-largest tax revenue generator in the country, according to the Irish revenue department.

  • April 26, 2024

    PwC Australia Appoints 6 Partners To Guide Scandal Rebound

    PwC Australia announced that it has elected six partners to its governance board as the firm continues to attempt to rebound in the wake of its scandal involving the leak of Australian government documents.

  • April 26, 2024

    HMRC Says Tax Digitalization Plan Will Generate £6.4B

    HM Revenue & Customs said its program to modernize U.K. tax filing is expected to generate £6.38 billion ($7.97 billion) in additional revenue through 2034 after projections last year put it at £3.9 billion.

  • April 26, 2024

    Poland Seeks Input On Bill To Enact Minimum Tax

    Poland, one of a handful of European Union countries that have delayed implementing the Organization for Economic Cooperation and Development's Pillar Two global minimum tax plan, introduced a proposal for public comment that would enact the regime.

Expert Analysis

  • 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.

  • The Reciprocal Tax Bill Is A Warning Shot At Pillar 2

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    A bill recently introduced in the House of Representatives to reciprocally tax countries deemed to have imposed discriminatory taxes on U.S. citizens and businesses takes aim at countries implementing the global minimum tax treaty known as Pillar Two, with which the U.S. has not complied, says Alan Cole at the Tax Foundation.

  • What Tax-Exempt Orgs. Need From Energy Credit Guidance

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    Guidance clarifying the Inflation Reduction Act’s credit regime, expected from the U.S. Department of the Treasury this summer, should help tax-exempt organizations determine the benefits of clean energy projects and integrate alternative energy investments into their activities, say attorneys at Morgan Lewis.

  • 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.

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