International

  • March 21, 2024

    Australia Seeking Input On Global Minimum Tax Bills

    Australia's Treasury is seeking public feedback on three draft bills published Thursday that would implement the Organization for Economic Cooperation and Development's global corporate minimum tax.

  • March 21, 2024

    Wyden Probes Swiss Bank's Ties To Billionaire Under Scrutiny

    The Senate Finance Committee's Democratic majority launched an inquiry into Swiss bank Pictet Group's involvement with a U.S. billionaire under criminal investigation, raising questions about the bank's deferred prosecution agreement and $123 million fine by the U.S. Justice Department, committee Chairman Ron Wyden announced Thursday.

  • March 21, 2024

    Quintairos Prieto Taps Atlanta Atty To Lead New Tax Group

    Quintairos Prieto Wood & Boyer PA said it had created a tax division that will be led by an Atlanta-based partner who has guided clients on civil and criminal tax law, reinforcing its national expertise in litigation, regulatory and corporate law matters.

  • March 21, 2024

    €58M VAT Toner Fraud Case Lands Four Convictions In Italy

    Four people were convicted in Italy for their roles in a value-added tax fraud scheme involving printer toner and other office supplies that resulted in €58 million ($63 million) in illicit profits, the European Public Prosecutor's Office said.

  • March 21, 2024

    PwC Still Withholding Names Of Aussie Leak Recipients

    PwC is continuing to refuse to name the six recipients of confidential drafts of Australian tax laws despite repeated requests from the country's government, the firm said in documents published Thursday.

  • March 21, 2024

    HSBC Settles Investors' £240M Claim Over Disney Tax Scheme

    HSBC has settled a £240 million ($304 million) claim brought by more than 100 investors alleging that the bank misled them to finance a Disney film tax relief scheme it developed which turned out to be worthless.

  • March 21, 2024

    UK Insurance Tax Bill Rises To £8.1B Amid Soaring Premiums

    The Insurance Premium Tax raised more than £8.1 billion ($10.3 billion) so far this financial year, according to official figures Thursday, while premiums continue to rise.

  • March 21, 2024

    ECJ Adviser Rejects Taxing Foreign Pension Funds Differently

    Taxing dividends paid to foreign public pension funds while exempting dividends paid to the source country's general retirement savings funds contravenes European Union law, an adviser to the bloc's highest court said Thursday, backing Finnish pension funds' challenge of a Swedish law.

  • March 20, 2024

    IRS Releases Foreign Housing Expense Limits For 2024

    The Internal Revenue Service released adjustments to the limitation on foreign housing expense deductions and exclusions for 2024 on Wednesday.

  • March 20, 2024

    EU Proposes Sending Russian Assets' Revenue To Ukraine

    The European Commission proposed on Wednesday transferring the net income from frozen and immobilized Russian state assets to European Union funds for rebuilding Ukraine and buying arms for that country.

  • March 20, 2024

    How The Supreme Court Could Narrow Chevron

    After hours of oral argument in a closely watched administrative law case, it appeared that some U.S. Supreme Court justices could be open to limiting the opportunities for lower courts to defer to federal agencies' legal interpretations in disputes over rulemaking — and legal experts said there are a number of ways they could do it.

  • March 20, 2024

    OECD Reports More Compliance With Tax Treaty Standards

    The Organization for Economic Cooperation and Development reported Wednesday that members of the group's inclusive framework — countries that have agreed to adopt minimum standards of an international anti-base erosion plan — have increased their compliance with the standard intended to prevent treaty shopping.

  • March 20, 2024

    IRS Withholding Docs On Partnership Audits, Baker Atty Says

    The Internal Revenue Service has not responded to a request for documents pertaining to the agency's scrutiny of large partnerships and should be forced to disclose them, an attorney with Baker McKenzie told a D.C. federal court.

  • March 20, 2024

    EU Floats Alternative To Unanimity As Bloc Eyes Growth

    The European Commission floated an alternative Wednesday to unanimity voting on matters such as tax as it seeks to streamline the way the bloc reaches decisions amid talk of expanding the number of EU countries.

  • March 20, 2024

    IRS Grants Income Exclusion To Those Fleeing 6 Countries

    Individuals who fled conditions in Ukraine, Belarus, Sudan, Haiti, Niger and Iraq after specific dates in 2023 can exclude foreign earned income, and can exclude or deduct housing costs, from gross income that year because of adverse conditions in the countries, the IRS said.

  • March 20, 2024

    Law360 Announces The Members Of Its 2024 Editorial Boards

    Law360 is pleased to announce the formation of its 2024 Editorial Advisory Boards.

  • March 20, 2024

    King & Spalding Adds Ex-PwC Tax Pro As Partner In NY

    An experienced tax attorney has joined King & Spalding LLP in New York after working at PricewaterhouseCoopers LLP for six years.

  • March 20, 2024

    HMRC Makes U-Turn On Helpline Cuts After Backlash

    The U.K. tax authority backtracked Wednesday on plans to close down several helplines for taxpayers from April through September after facing criticism from politicians and industry groups.

  • March 19, 2024

    UN Experts Aim To Finalize Tool For Model Treaty Updates

    The United Nations' tax committee is aiming this week to finalize a tool to facilitate faster adoption of updates to its model tax treaty within bilateral negotiations, although some members remain skeptical about its usefulness, according to discussions Tuesday.

  • March 19, 2024

    GILTI Figures Into CFC Applicability Project, Official Says

    The U.S. global intangible low-taxed income system is factoring into continuing Internal Revenue Service work on whether a tax code provision limiting corporations from offsetting income with net operating or other tax losses after ownership changes applies to controlled foreign corporations, an agency official said Tuesday.

  • March 19, 2024

    Pakistan Enlists Nonprofit To Boost Digital Tax Administration

    Pakistan's tax authority said it is partnering with a nonprofit focused on business financing to help the government better understand businesses' needs as it works to improve online tax administration tools.

  • March 19, 2024

    OECD Deputy Tax Director To Leave Post In June

    A deputy tax director for the Organization for Economic Cooperation and Development announced he is stepping down from his position at the end of June after nearly a decade there working on international tax policy.

  • March 19, 2024

    Exxon Wants Closed Court In $1.8B Tax Trial

    Exxon Mobil plans to seek courtroom closures for parts of an upcoming trial in its $1.8 billion suit challenging denied tax deductions for payments it made to Qatar, telling a Texas federal court that certain testimony, if made public, would damage its relationship with the foreign partner.

  • March 19, 2024

    HMRC Under Fire For Sharply Cutting Back Helpline Service

    The U.K. tax authority has moved too quickly to phase out helpline services for taxpayers filing self-assessment returns this year, members of Parliament said Tuesday.

  • March 19, 2024

    EU Parliament Committees Approve AML Laws

    Two European Parliament committees approved new anti-money laundering legislation Tuesday for the European Union to create a single rule book for all 27 EU countries and to establish a common enforcement authority.

Expert Analysis

  • IRS Announcement Will Aid Cos. In Buyback Tax Planning

    Author Photo

    Recent IRS transitional guidance regarding current requirements for reporting and payment of the stock repurchase excise tax will help corporate taxpayers make decisions about records retention and establishing reserves for future tax payments, say Xenia Garofalo and Kyle Colonna at Eversheds Sutherland.

  • Flawed Analysis Supports Common Law Tax Deficiency Ruling

    Author Photo

    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

    Author Photo

    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

    Author Photo

    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

    Author Photo

    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

    Author Photo

    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

    Author Photo

    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

    Author Photo

    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

    Author Photo

    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

    Author Photo

    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

    Author Photo

    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

    Author Photo

    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

    Author Photo

    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.

Can't find the article you're looking for? Click here to search the Tax Authority International archive.