International

  • April 01, 2024

    Liechtenstein Adopts GloBE Rules For Corp. Minimum Tax

    Liechtenstein has supplemented its passage of the Organization for Economic Cooperation and Development's global corporate minimum tax by officially adopting the global anti-base erosion rules, which provide regulations to facilitate the minimum tax.

  • April 01, 2024

    BakerHostetler Adds Partner To Tax Practice Group

    BakerHostetler's Washington office has added a partner from Morris Manning and Martin LLP to join its tax practice group, Baker said in a statement Monday.

  • April 01, 2024

    Baker Donelson Adds EY Tax Pro To Houston Office

    A former EY senior manager has joined Baker Donelson Bearman Caldwell & Berkowitz PC's tax group in Houston as counsel, the firm announced.

  • April 01, 2024

    16 Charged In $12.5M VAT Refund Scheme, Poland Says

    Sixteen people have been charged in a scheme to use forged documents to claim false value-added tax refunds for polymer and steel transactions, causing an estimated 50 million Polish zloty ($12.5 million) in damages, Poland's tax authority said.

  • March 29, 2024

    APA Work Doubled In 2023, IRS Report Says

    The Internal Revenue Service finalized more than twice as many advance pricing agreements for U.S. multinational corporations in 2023 as in the previous year, according to an agency report released Friday.

  • March 29, 2024

    Green Energy Credit Sales Spur Surge In Tax Insurance

    A new way for project owners to monetize clean energy tax credits by selling them for cash has turbocharged demand for insurance policies to cover various risks tied to the transactions, which can often be worth hundreds of millions of dollars.

  • March 29, 2024

    EU OKs Irish Film Tax Credit Cap Increase, Extension

    Ireland is bumping up the cap on its 32% film project tax credit to €125 million ($135 million) and extending the program to the end of 2028 after getting the go-ahead from the European Commission, the country's Department of Finance said Friday.

  • March 29, 2024

    Canada Extends Mineral Exploration Tax Relief To 2025

    A 15% Canadian tax credit for investments in mining activities that was set to expire at the end of the month has been extended to March 2025, the country's Department of Finance said.

  • March 29, 2024

    HMRC Issues Draft R&D Credit Guidance For Overseas Work

    HM Revenue & Customs released draft guidance for complying with new restrictions on tax relief for payments to contractors for research and development, as well as payments for externally provided workers, for R&D activity that takes place abroad.

  • March 28, 2024

    PwC Fined $3M Over Auditor Controls, Australia Probe

    The Public Company Accounting Oversight Board leveled a pair of fines totaling more than $3 million against PwC on Thursday, accusing the Big Four accounting firm of failing to maintain policies to ensure auditor independence and of waiting years to inform the U.S. regulator that it was being investigated in Australia.

  • March 28, 2024

    Corp. Transparency Act Overbroad, Mich. Group Tells Court

    The Corporate Transparency Act is overbroad and violates both the Fourth and Fifth Amendments of the U.S. Constitution, the Small Business Association of Michigan told a federal court in a case similar to one currently in the Eleventh Circuit.

  • March 28, 2024

    Hong Kong Considering Patent Box Tax Regime

    Hong Kong's legislature will soon consider a so-called patent box regime that would establish a 5% tax rate on income derived from intellectual property in the jurisdiction, compared with the normal 16.5% tax rate on nonresident royalty income, the country's Inland Revenue Department said Thursday.

  • March 28, 2024

    Canadian In Wash. Owes Over $1M FBAR Penalty, US Says

    A Canadian man living in Washington state owes more than $1 million in penalties for failing to report bank accounts he held in Montreal, the U.S. Department of Justice said in a complaint filed in an attempt to collect the money.

  • March 28, 2024

    Egypt Tax Info Sharing Only Partially Compliant, OECD Says

    Egypt needs to make "significant improvements" to portions of its exchange of information on request mechanisms to bring it in better compliance with Organization for Economic Cooperation and Development standards, the organization said Thursday.

  • March 28, 2024

    Truck Co. Sues Ex-Boss For £216K Over Tax Dodge Scheme

    A British truck dealership is suing its former managing director for more than £216,000 ($273,000), alleging that he left the company liable for a huge back tax bill by setting up a fraudulent salary sacrifice scheme to rent a house.

  • March 28, 2024

    2nd Circ. Urged To Uphold Dual Citizen's FBAR Penalties

    A New York federal court correctly upheld tax penalties against a dual French citizen for hiding millions of dollars in six foreign accounts, the U.S. government told the Second Circuit, urging it to reject the woman's claims that American authorities violated the Hague Convention in pursuing her.

  • March 28, 2024

    Nev. Estate Owes Over $3.8M In FBAR Penalties, Court Rules

    The estate of a Nevada entrepreneur must pay over $3.8 million in penalties and interest for willfully failing to report his foreign bank accounts in Belize, the Bahamas and Panama, a federal district court ruled.

  • March 28, 2024

    New Zealand Parliament Passes Global Minimum Tax

    The New Zealand Parliament has passed a wide-ranging tax bill that includes establishing the Organization for Economic Cooperation and Development's global corporate minimum tax.

  • March 28, 2024

    EU VAT Draft Draws Flak Over Cost For Online Platforms

    A proposed overhaul of the European Union's value-added tax rules to make them fit for the digital age faces questions about how the draft law treats platform companies in transportation, such as Uber or EU-based Bolt, when it comes to charging VAT.

  • March 28, 2024

    EU Justice Head To Step Aside To Run For Rights Group Post

    The European Union's president granted the bloc's justice commissioner leave to pursue a leadership role with a European human rights organization, the European Commission said.

  • March 28, 2024

    EU States OK Duty-Free Imports From Ukraine To June 2025

    European Union countries have overcome objections and backed the suspension for another year of customs duties and quotas on Ukrainian imports but only after tightening caps on some agricultural products. 

  • March 27, 2024

    Australian Senate OKs Amended Thin Capitalization Rules

    Australia's upper house passed a bill Wednesday amending the country's thin capitalization rules to limit the amount of debt deductions that multinational entities can claim in an income year.

  • March 27, 2024

    PwC Hiding Key Details Of Tax Scandal, Aussie Senate Says

    PwC is hiding key details from investigators about its partners marketing confidential drafts of tax laws to top U.S. firms, waited years to review the matter internally and does not appear capable of making substantive reforms, an Australian Senate committee said Wednesday.

  • March 27, 2024

    Czech Transfer Pricing Audits Boost Tax Base By $248M

    An increased focus by the Czech Republic on transfer pricing audits on arrangements to relicense intangible assets and the reselling of advertising services increased the country's tax base by 5.8 billion Czech koruna ($248 million) in 2023, the country's Financial Administration said Wednesday.

  • March 27, 2024

    Treasury Urged To Adjust Shift To Foreign Currency Rules

    The U.S. Treasury Department should let corporations take an aggregate approach regarding certain affiliates that conduct business in foreign currencies when transitioning to new rules for determining taxable income or loss, the American Bar Association's Tax Section recommended.

Expert Analysis

  • 5th Circ. Ruling Reminds Attys That CBP Can Search Devices

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    The Fifth Circuit’s recent Malik v. Department of Homeland Security decision adds to the chorus of federal courts holding that border agents don’t need a warrant to search travelers’ electronic devices, so attorneys should consider certain special precautions to secure privileged information when reentering the U.S., says Jennifer Freel at Jackson Walker.

  • Enforcement Of International Tax Reporting Is Heating Up

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    Since the U.S. Supreme Court’s February decision in Bittner v. U.S. changed how penalties for failure to report offshore accounts are calculated, recent developments suggest the government is preparing to step up enforcement and vigorously pursue the collection of resulting penalties, say Daniel Silva and Agustin Ceballos at Buchalter.

  • IRS Notice Clarifies R&E Amortization, But Questions Remain

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    The IRS and Treasury Department’s recent notice clarifying the treatment of specified research and experimental expenditures under Section 174 provides taxpayers and practitioners with substantive guidance, but it misses the mark in delineating which expenditures are amortizable, say attorneys at Eversheds Sutherland.

  • Preparing Your Legal Department For Pillar 2 Compliance

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    Multinational entities should familiarize themselves with Pillar Two of the Organization for Economic Cooperation and Development’s BEPs 2.0 project and prepare their internal legal tracking systems for related reporting requirements that may go into effect as early as January, says Daniel Robyn at Ernst & Young.

  • What Large Language Models Mean For Document Review

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    Courts often subject parties using technology assisted review to greater scrutiny than parties conducting linear, manual document review, so parties using large language models for document review should expect even more attention, along with a corresponding need for quality control and validation, say attorneys at Sidley.

  • Participating In Living History Makes Me A Better Lawyer

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    My role as a baron in a living history group, and my work as volunteer corporate counsel for a book series fan association, has provided me several opportunities to practice in unexpected areas of law — opening doors to experiences that have nurtured invaluable personal and professional skills, says Matthew Parker at the Nebraska Department of Health and Human Services.

  • Private Equity Owners Can Remedy Law Firms' Agency Issues

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    Nonlawyer, private-equity ownership of law firms can benefit shareholders and others vulnerable to governance issues such as disparate interests, and can in turn help resolve agency problems, says Michael Di Gennaro at The Law Practice Exchange.

  • How Taxpayers Can Prep As Justices Weigh Repatriation Tax

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    The U.S. Supreme Court might strike down the 2017 federal tax overhaul's corporate repatriation tax in Moore v. U.S., so taxpayers should file protective tax refund claims before the case is decided and repatriate previously taxed earnings that could become entangled in dubious potential Section 965 refunds, say Jenny Austin and Gary Wilcox at Mayer Brown.

  • OFAC Designation Prosecutions Are Constitutionally Suspect

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    Criminal prosecutions based on the Office of Foreign Assets Control’s sanctions-related listing decisions — made with nearly unfettered discretion through an opaque process — present several constitutional issues, so it is imperative that courts recognize additional rights of review, say Solomon Shinerock and Annika Conrad at Lewis Baach.

  • How The OECD Global Tax Proposal Could Affect M&A

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    Following agreement on the Organization for Economic Cooperation and Development’s Pillar Two proposal to introduce a global minimum tax, domestic implementation is expected to have a significant impact on international M&A transactions, with financial modeling, deal structuring, risk allocation and joint venture arrangements likely to be affected, say lawyers at Freshfields.

  • UK Shares-Tax Proposals Offer Long-Awaited Modernization

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    The U.K. government's recent consultation on the introduction of a new tax on transactions in securities raises detailed legal and practical issues, but the prospect of a single digital stamp tax offering both streamlined legislation and administration will be welcomed, say Zoë Arnautov and Mark Sheiham at Simmons & Simmons.

  • IRS Foreign Tax Credit Pause Is Welcome Course Correction

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    A recent IRS notice temporarily suspending application of 2022 foreign tax credit regulations provides wanted relief for the many U.S. multinational companies and other taxpayers that otherwise face the risk of significant double taxation in their international operations, say attorneys at Mayer Brown.

  • IRS Criminal Probe Spells Uncertainty For Malta Pension Plans

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    The IRS’ recent scrutiny of Malta pension plan arrangements — and its unusual issuance of criminal administrative summonses — confirms that it views many of these plans as illegal tax evasion schemes, and the road ahead will not be smooth and steady for anyone involved, say attorneys at Kostelanetz.

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