International

  • 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.

  • March 14, 2024

    New Zealand Proposes 12% Tax On Overseas Online Casinos

    The New Zealand tax agency proposed Thursday to target the profits of offshore online gambling companies with a 12% tax that would bring in an expected NZ$35 million ($21.5 million) a year.   

  • March 14, 2024

    Israel Tax Authority Claims Owner Of US Biz Underpaid Tax

    A Jerusalem man is suspected of failing to report 50 million Israeli new shekels ($13.7 million) of his income from companies in Israel and abroad, the Israel Tax Authority said Thursday.

  • March 14, 2024

    Brazil Turns To Central Region In Farm Tax Fraud Probe

    Brazil's tax authority is focusing on the country's central region in the next phase of an investigation into a tax avoidance scheme that led it to more than 550 million real ($110.2 million) in uncollected revenue from rural farmers.

  • March 14, 2024

    Nine In 10 Finnish Cos. Report Positive Attitude To Taxation

    Nine of 10 Finnish companies have a positive attitude toward taxation, according to a survey announced Thursday by Finland's Tax Administration.

  • March 14, 2024

    IRS' Signals On Economic Substance Doctrine Draw Scrutiny

    The Internal Revenue Service's recent legal success asserting a doctrine to invalidate transactions in tax law enforcement matters may embolden the government to broaden that argument's reach, and lawyers are concerned it doesn't properly apply to transfer pricing matters.

Expert Analysis

  • 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.

  • What IRS Funding Increase Means For Taxpayers

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    The Internal Revenue Service will first use the influx of funding from the Inflation Reduction Act to address customer support and personnel issues, but with over half the money allocated to enforcement, corporations and high-net-worth individuals will face increased scrutiny, say Patrick McCann Jr. and Jasen Hanson at Chamberlain Hrdlicka.

  • 6 Tax Considerations For Life Sciences Collaboration Deals

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    Given recent IRS guidance and changes to certain tax rates and deductions, biotech and life sciences companies entering into collaboration agreements should assess several unique taxation issues affecting matters ranging from research and development expenditures to profit-sharing terms, say attorneys at Orrick and Andersen Tax.

  • Rushed Multilateral Negotiations Caused Two-Pillar Tax Mess

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    Cracks appearing in the two pillars of the 2021 global tax plan stem from a multilateral tax policy process that rushed to issue rules without first resolving fundamental differences between countries or ensuring that the U.S., a key player, could implement them, says Jefferson VanderWolk at Squire Patton.

  • Key Considerations For Seeking Relief From Double Taxation

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    Caroline Setliffe and E. Miller Williams at Eversheds Sutherland lay out the Organization for International Cooperation and Development’s mutual agreement procedure for settling double-taxation disputes, and discuss six factors U.S. taxpayers doing business in multiple countries should consider when determining the most advantageous form of relief.

  • 2 Tax Decisions Hold Key Transfer Pricing Takeaways

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    Richard Slowinski and Stefanie Kavanagh at Alston & Bird discuss two recent decisions in cases against the IRS — Eaton Corp. from the Sixth Circuit and Medtronic from the Tax Court — that may help clarify when the agency can cancel an advance pricing agreement, but leave unanswered questions about which pricing method applies to high-value intercompany licensing transactions.

  • Digital Taxation Is Necessary, But Tough To Manage

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    The U.S. government has started to tackle complex new tax laws as the digital economy continues to grow, but this demands guidelines that will facilitate the growth while protecting investors and the government's finances, say attorneys at Cadwalader.

  • Company Considerations For Cash Award Incentives: Part 2

    Excerpt from Practical Guidance
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    Cash awards can help companies address some issues associated with equity awards to compensate employees, but due to potential downsides, they should be treated as a tool in a long-term incentive program rather than a panacea, say Denise Glagau and Kela Shang at Baker McKenzie.

  • Company Considerations For Cash Award Incentives: Part 1

    Excerpt from Practical Guidance
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    Denise Glagau and Kela Shang at Baker McKenzie discuss what companies must consider when offering cash awards outside of U.S. jurisdictions, and explain how some challenges associated with equity awards may be addressed with cash awards.

  • What AML Bill Could Mean For Firms, Funds And FinCEN

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    If passed, an amendment within Congress’ annual defense bill would expand the list of institutions subject to anti-money laundering regulations, from law firms to investment funds, creating potential rulemaking and enforcement challenges for the Financial Crimes Enforcement Network, say attorneys at Arnold & Porter.

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