International

  • March 19, 2024

    Compliance Costs Call For Border Fee, France's Le Maire Says

    The cost of compliance with European environmental rules justifies the European Union's recently launched carbon border tax, which is designed to raise the price of imports with lower environmental standards, French Finance Minister Bruno Le Maire said Tuesday.

  • March 19, 2024

    UK Energy Co. Fights To Deduct £2.5M Deal Advice Fees

    An investment holding company told the Supreme Court on Tuesday that £2.5 million ($3.2 million) it paid to Deutsche Bank and others for deals advice is tax-deductible because they were the "type of services procured all the time."

  • March 18, 2024

    HMRC Defends Response To Tax Avoidance Ploy

    The U.K. tax authority has rejected claims that it has been "heavy-handed" by applying the loan charge to users of disguised remuneration schemes, according to a letter released on Tuesday by the Treasury Committee.

  • March 18, 2024

    Australia Seeks Input On Revised Energy Tax Regulations

    Australia's Department of the Treasury is seeking responses from the public to a draft of updated regulations for determining petroleum resource rent tax, the department announced Monday.

  • March 18, 2024

    Justices Won't Review Dead Film Exec's IRS Summons

    The U.S. Supreme Court on Monday denied a request from the daughter of a dead film executive to consider invalidating an IRS summons for her father's financial records, letting stand a Ninth Circuit decision that found the agency sought the records in good faith.

  • March 18, 2024

    Treasury Mulling Whether To Keep Foreign Tax Credit Regime

    The U.S. Treasury Department is considering whether the best way to provide administrable foreign tax credit rules and address related policy concerns is to retain the framework from paused final regulations or develop a new one, a Treasury official said Monday.

  • March 18, 2024

    Gov'ts Widely Back Building Capacity Of Tax Authorities

    Building the skills and capacities of tax authorities to implement international tax standards should be a central focus of global tax cooperation at the United Nations for governments to gain revenue, officials from the U.S., the African Group and many others said Monday.

  • March 18, 2024

    Axed HMRC Staffer Wins £16K Disability Discrimination Case

    HM Revenue and Customs must pay a disabled former employee £15,900 ($20,200) after it unfairly sacked him for gross misconduct and wrote off his claim that his sleep apnea was to blame, a Scottish tribunal has ruled.

  • March 18, 2024

    Wyden, Whitehouse Scrutinize DOJ's Caterpillar Investigation

    Two top Democratic senators asked the U.S. Justice Department about its handling of a criminal inquiry into Caterpillar for potential financial crimes and corporate tax fraud after receiving evidence corroborating a report that former DOJ officials may have suppressed the investigation, according to a letter released Monday.

  • March 18, 2024

    FCA Levies £5.95M Fine In Fake Dividend Tax Reclaim Case

    The Financial Conduct Authority said Monday it had decided to fine the former chief executive of Indigo Global Partners Ltd. £5.95 million ($7.57 million) and ban him from the industry for participating in a Danish tax scam that falsely reclaimed dividend taxes on shares.

  • March 18, 2024

    Serving Claims To HMRC By Email Made Permanent

    Claimants pursuing legal action against the U.K. tax authority in England and Wales will continue to be able to serve documents by email, HM Revenue and Customs said Monday, making the process it introduced during the COVID-19 pandemic permanent.

  • March 18, 2024

    Polish Senate Committee Objects To EU BEFIT Proposal

    A Polish Senate committee has objected to a new legislative proposal for corporate taxation in the European Union because it said it may lead to a loss of tax income and weaken the country's investment support programs.

  • March 15, 2024

    UAE Seeks Public Input On Global Minimum Tax

    The United Arab Emirates is seeking public comments on implementing the global minimum tax under the OECD's tax reform plan, along with other tax issues, the country's Ministry of Finance announced Friday.

  • March 15, 2024

    France's Green Energy Investment Tax Credit Now In Effect

    Companies operating in France's wind power sector and other clean energy industries will now be able to use the country's new green investment tax credit, the French finance ministry said Friday.

  • March 15, 2024

    Bechtel's Appeal Tossed In $8.5M Australian Tax Case

    Bechtel Corp. must pay taxes of AU$13 million ($8.5 million) on costs of transporting employees to a worksite because the travel did not occur in the course of producing income, a Federal Court of Australia panel said Friday.

  • March 15, 2024

    The Tax Angle: House GOP Plots TCJA Renewal Strategy

    House Republicans left Washington this week for their annual two-day legislative issues conference, hoping to expand their control of the chamber in the upcoming November elections and planning their strategy for renewal of their historic 2017 tax overhaul law.

  • March 15, 2024

    Tax Foundation Says UN Should Avoid Duplicating Tax Efforts

    The United Nations should only create global tax rules in areas where it can effectively reduce uncertainty and should avoid duplicating negotiations underway elsewhere, the Tax Foundation said Friday in a response to the organization.

  • March 15, 2024

    Netherlands Enters Tax Treaty Talks With 3 More Countries

    The Netherlands government announced plans to negotiate 13 tax treaties this year, including work on agreements with three new countries.

  • March 15, 2024

    Direct Hit On Tax Regs Unlikely If Justices Ditch Chevron

    A decision from the U.S. Supreme Court later this year on two cases challenging the so-called Chevron doctrine, which gives federal agencies wide latitude to interpret ambiguous laws, isn't likely to immediately affect tax regulations.

  • March 15, 2024

    Colombia, Norway Aim To Harmonize UN And OECD Tax Work

    Colombia and Norway are aiming to bring the best aspects of the OECD's tax work into negotiations at the United Nations while drafting a framework convention on global tax cooperation, officials said Friday during a conference in Paris.

  • March 15, 2024

    Taxation With Representation: Freshfields, Kirkland

    In this week's Taxation with Representation, AstraZeneca acquires Amolyt Pharma, XCF Global Capital goes public and EQT Corp. merges with Equitrans Midstream Corp.

  • March 15, 2024

    Swiss Senate Votes Not To Consider Tonnage Tax

    The upper house of the Swiss legislature has decided not to consider a tonnage tax proposal, choosing instead to follow the recommendation of a committee that last month recommended not taking up the measure.

  • March 14, 2024

    Taiwanese Gov't Proposes Filing Of Electronic Invoicing

    The Taiwan government's executive branch approved a draft amendment to the island's Value-added and Non-value-added Business Tax Act that would require businesses to file electronic invoices on an open database, the Ministry of Finance announced Thursday.

  • March 14, 2024

    Economists Suggest UN Tackle CFC Rules, Other Tax Policies

    Governments should look at coordinating globally on controlled foreign corporation rules, economic substance requirements, financial transparency, excess profits taxes, inheritance taxes and wealth taxes in negotiations on the nascent United Nations tax convention, economists said Thursday at a conference in Paris.

  • March 14, 2024

    Wealth Tax, Stiff Biz Tax Could Fund Climate Fight, Study Says

    Governments could generate the $500 billion experts think developing countries would need annually to fund the fight against climate change with a 2% global minimum tax on billionaires and a 20% global minimum tax on corporations with no exclusions, the EU Tax Observatory said Thursday.

Expert Analysis

  • 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.

  • The Key Issues Keeping Transfer Pricing A Top Tax Concern

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    Several challenges preventing a global economic reemergence from the pandemic era are making practitioners reevaluate commonly used transfer pricing models, and embrace new technologies and ways of doing business, say Farnaz Amini and Sophia Castro Jurado at Marcum.

  • Curtailing Offshore Tax-Advantaged Investment In China

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    The U.S. government's plans to establish a new outbound investment regime hold the potential to arrest Chinese companies' increasing use of offshore, tax-advantaged locations to raise capital, says David Plotinsky at Morgan Lewis.

  • Cos. May Want To Wait Out US-EU Green Incentives Fight

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    As the European Union considers measures to compete with the Inflation Reduction Act's incentives for U.S. production of clean tech, and EU and U.S. officials discuss a possible compromise, companies in the green sector should consider taking a wait-and-see approach to investment decisions, says Todd Thacker at Goldberg Segalla.

  • 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.

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