International

  • May 14, 2024

    Aussie Budget Proposes Green Credits, Capital Gains Change

    Australia would offer tax credits for hydrogen production and critical mineral mining and update its foreign resident capital gains tax rules as part of a proposed 2024-25 budget released Tuesday.

  • May 14, 2024

    British Industry Group Calls For Green Energy Tax Breaks

    The U.K. needs to "outsmart rather than outspend" other countries to grow in the green energy sector, a British business advocacy group said, calling for the government to create a 40% so-called green innovation tax credit, among other tax breaks.

  • May 14, 2024

    Ex-Whiteford Taylor Business Co-Chair Joins Baker Donelson

    Baker Donelson Bearman Caldwell & Berkowitz PC has welcomed a new shareholder who spent more than a decade with the Internal Revenue Service and previously co-chaired Whiteford Taylor & Preston LLP's business department, the firm announced on Monday.

  • May 14, 2024

    EU Finance Ministers Strike Deal On Withholding Tax Refunds

    European Union finance ministers agreed Tuesday to a withholding tax refund law, as previous holdouts Poland and the Czech Republic withdrew their objections.

  • May 14, 2024

    EU Chair To Fight On For VAT Deal After Estonia's Rejection

    The chair of the European Union's council of finance ministers said he will fight to get unanimous support for a wide-ranging reform of value-added tax rules after Estonia blocked agreement to the law Tuesday.

  • May 14, 2024

    Aussie Senate Faces Separation Of Promoter Penalty, Gas Tax

    The Australian government is poised to double the penalty for corporate promoters of tax avoidance schemes, but it may first have to compromise by separating its bill from another one dealing with a tax on offshore gas exports, according to a legislative report.

  • May 13, 2024

    Corp. Transparency Act An Overbroad Dragnet, 11th Circ. Told

    Congress exceeded its authority in passing the Corporate Transparency Act, which prompted the U.S. Treasury Department to solicit personal information for law enforcement purposes from those that registered and owned state-registered entities, a small-business group told the Eleventh Circuit on Monday.

  • May 13, 2024

    House GOP Bills Target Foreign Funding To Tax-Exempt Orgs

    The House Ways and Means Committee will vote Wednesday on a package of bills that would increase scrutiny of foreign donations to tax-exempt organizations, including legislation that would require those organizations to publicly report the donations, the Joint Committee on Taxation announced Monday.

  • May 13, 2024

    Income Nixes Exxon's 'Final Loss' Deduction, Court Says

    Exxon's Norwegian operation cannot deduct 900 million krone ($83.2 million) from its fiscal year 2012 taxable income that it spent liquidating an Exxon subsidiary in Denmark, a European court ruled Monday.

  • May 13, 2024

    2nd Circ. Won't Revive UBS Suit Over Disclosed Account Info

    The Second Circuit declined Monday to revive a couple's suit accusing UBS of fraudulently flagging an account to the Internal Revenue Service, finding that any alleged harm resulting from an audit would have been caused by the agency itself.

  • May 13, 2024

    Int'l Authorities Want Increased Anti-Money Laundering Efforts

    Countries need to do more to tackle the "huge illicit profits" being generated by international crime organizations and used for harmful practices such as funding terrorism, the heads of the Financial Action Task Force, Interpol and a United Nations group said Monday.

  • May 13, 2024

    Estonia Needs To Improve Property, Health Taxes, OECD Says

    While Estonia has the lowest ratio of government debt to gross domestic product of any OECD country, it has numerous areas where it could improve its tax system, from broadening its tax base to increasing healthcare funding, the OECD said Monday.

  • May 13, 2024

    EU Initiative Pushes Bloc To Strengthen Carbon Taxing

    The European Commission on Monday officially registered a citizen initiative to focus on accelerating the taxing of greenhouse gas emissions as well as making it more equitable, giving the group behind it a year to meet certain criteria that would force the European Union's executive arm to act.

  • May 13, 2024

    Houston Truck Co. Doesn't Owe $2M Excise Tax, 5th Circ. Told

    A Houston truck company that sells tires made by a Chinese manufacturer doesn't owe $2 million in import taxes because it's not legally the tire importer, the company told the Fifth Circuit in asking it to affirm a ruling that could split circuits.

  • May 13, 2024

    Estonia Objecting To VAT Proposal On 'Neutrality' Grounds

    Estonia is objecting to a proposed overhaul of European Union value-added tax rules because the proposal doesn't respect the principle of "neutrality," the country's finance minister said Monday, casting doubt on the fate of the proposal, which needs agreement by all 27 EU countries to pass.

  • May 13, 2024

    EU Chair Offers Compromise To Clinch Withholding Tax Deal

    The chair of European Union finance ministers offered last-minute concessions to try to persuade holdouts the Czech Republic and Poland to agree to a withholding tax refund law, a document published Monday showed.

  • May 11, 2024

    Gov't Urges 8th Circ. To Uphold 3M's $24M Pricing Adjustment

    The U.S. government asked the Eighth Circuit to uphold a U.S. Tax Court decision allowing the IRS to allocate nearly $24 million from 3M's Brazilian affiliate, arguing the company's appeal involves misplaced reliance on a U.S. Supreme Court decision.

  • May 10, 2024

    5 Goals Gov'ts Have For The UN Tax Convention

    Transfer pricing, country-by-country reporting, wealth taxation, the digital economy and the participation of developing countries in negotiations are topics governments at the United Nations said they want to address during the first session on drafting terms of reference for the Framework Convention on International Tax Cooperation.

  • May 10, 2024

    Austria Eyes Fines For Fake Invoices Used In Tax Fraud

    People creating false invoices in Austria could face fines of up to €100,000 ($108,000) as the country looks to crack down on tax fraud involving fictitious businesses, the country's Ministry of Finance said Friday.

  • May 10, 2024

    DC Tax Atty Can't Use Ch. 7 To Ditch Depo In $19M Theft Suit

    A corporate D.C. tax attorney accused of bilking a former client out of $19 million via a captive insurance scam will be deposed, despite a stay in the Maryland federal case against him and his firm after both filed for bankruptcy.

  • May 10, 2024

    Use Of AI For Tax Comment Letters Poses Ethical Quandaries

    While artificial intelligence can streamline the process of conducting a comprehensive review of complex, IRS-proposed federal tax regulations, tax attorneys must be aware of professional and ethical considerations when using it to help draft comment letters to submit to the agency.

  • May 10, 2024

    Australia Looks To Tweak Tax Exemption For US Entertainers

    Australia wants public comments on a proposal that would simplify the elimination of withholding taxes for U.S. entertainers who make $10,000 or less — or the Australian equivalent — in the country in a given year, the Australian Taxation Office said.

  • May 10, 2024

    Calif. OTA In Untested Area On Ruling That Biz Wants Binding

    A decision by California's Office of Tax Appeals that Microsoft can include 100% of the dividends from foreign affiliates in its California sales factor denominator pleased businesses, who now want the OTA to designate the opinion as precedential, thus binding on it and the state Franchise Tax Board.

  • May 10, 2024

    Osborne Clarke Lawyer To Face Tribunal Over Zahawi SLAPP

    An Osborne Clarke LLP partner who represented Nadhim Zahawi could face a disciplinary tribunal over allegations that he used intimidatory warnings in an attempt to silence a critic who was probing the former Conservative chancellor's tax affairs.

  • May 09, 2024

    Mich. Doctor Ordered To Stay In Jail Until Assets Repatriated

    A Michigan doctor fighting accusations that he failed to report his foreign bank accounts will stay in jail, as a federal court declined to release him Thursday when he didn't comply with an order to deposit over $1 million to cover the judgment against him.

Expert Analysis

  • 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.

  • 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.

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