International

  • March 07, 2024

    EU Pressure May Push Germany To Align VAT Law For Tutors

    Pressure from the European Commission may force Germany to align its law on value-added tax with the European Union's VAT law and thus make it easier for private tutors to receive a VAT exemption they're entitled to under EU law.

  • March 07, 2024

    EU Parliament Panel Backs Duty-Free Imports From Ukraine

    The European Parliament's international trade committee voted on Thursday to extend the suspension of EU customs duties and quotas on Ukrainian imports for one more year.

  • March 07, 2024

    Biden Urges Higher Taxes On Wealthy Companies, Individuals

    President Joe Biden, in his Thursday night State of the Union address, urged Congress to make the U.S. tax code fairer by enacting higher rates on wealthy corporations and individuals and extending tax relief to working families.

  • March 06, 2024

    Impending Corp. Spinoff Guidance Could Refine Tax-Free Test

    Tax attorneys are watching to see if eagerly awaited corporate spinoff guidance will help determine whether transactions qualify for tax-free status with more clarity than current regulations, and without controversial bright-line rules that were floated several years ago.

  • March 06, 2024

    Startup Investors' Attys Want $1.5M In Fees On Disclosure Suit

    Lawyers for a class of investors have asked a New York federal court to approve their attorney fees of $1.5 million for a $4.5 million settlement with a Chinese analytics startup over claims the company misrepresented its tax liability before its initial public offering. 

  • March 06, 2024

    Suspect Charged In €42M Italian VAT Fraud Scheme

    A suspect was placed under house arrest by Italian authorities and charged with €41.8 million ($45.6 million) in value-added tax fraud involving the wholesale trade of computer equipment, as well as the misappropriation of €6.7 million in public funds, the European Public Prosecutor's Office said Wednesday.

  • March 06, 2024

    HMRC Estimates UK's 2022-23 VAT Gap At £8.6B

    An updated estimate by HM Revenue & Customs released Wednesday put the gap between the amount of value-added tax the U.K. expected to collect in the 2022-23 tax year and the amount actually collected at £8.6 billion ($10.96 billion).

  • March 06, 2024

    UK Cuts Tax, Reforms Non-Dom Rules In Pre-Election Budget

    The U.K. government unveiled another cut in payroll taxes and changes to rules on non-domicile status on Wednesday as it presented its election-year spring Budget.

  • March 06, 2024

    EU Proposes VAT Exemption For Joint Arms Purchases

    The European Commission proposed an exemption from value-added tax for arms procurement when European Union countries band together in joint purchase programs, part of a broad strategy to boost the bloc's defense capabilities.

  • March 05, 2024

    Calif. OTA Ruling May Limit Foreign Income State Can Reach

    With its newly revealed opinion allowing Microsoft to include all of its foreign dividends in the denominator of its California sales factor, the state's Office of Tax Appeals has made plain that multinational corporations in similar circumstances can ultimately reduce the amount of foreign income the state may tax.

  • March 05, 2024

    Goal Is Still For A Mandatory Amount B, Treasury Official Says

    Negotiators at the OECD made it optional for countries to adopt new simplified and streamlined transfer pricing rules, known as Amount B, but the goal is still for the framework to be mandatory, a U.S. Treasury Department official said Tuesday.

  • March 05, 2024

    DLA Piper Brings On HMRC Vet For Corp. Crime Team

    DLA Piper added a member to its corporate crime and investigations team in London, an HM Revenue & Customs veteran most recently at Pinsent Masons, the firm announced.

  • March 05, 2024

    Pillar 1 Would Have Cost US Gov't $1.4B In 2021, Study Says

    U.S. tax revenue would have been reduced by $1.4 billion in 2021 under a proposed system to reallocate a share of tax payments to where large multinational corporations have customers but lack a physical presence, the Joint Committee on Taxation said Tuesday.

  • March 05, 2024

    Biz Owner Gets 10 Months For Evading Tax On Foreign Income

    The owner of a manufacturing company was sentenced in California federal court to 10 months in prison for avoiding taxes on almost $4.5 million in income by failing to report his foreign sales to the Internal Revenue Service, the U.S. Department of Justice said.

  • March 05, 2024

    Retiree's Bid For $284K FBAR Refund Thrown Out

    Federal district courts lack jurisdiction to refund penalties for failing to report foreign accounts, which means a Georgia man must refile in the U.S. Court of Federal Claims to try to recover $284,000 that he was penalized, a Georgia federal court said in dismissing his case.

  • March 05, 2024

    UK Budget Should Include Tax Cuts, Biz Group Says

    The U.K. budget should include tax cuts and other credits to support growth industries such as green technology, life sciences and advanced manufacturing, a British business advocacy group said Tuesday.

  • March 05, 2024

    EU Advisory Body Backs Draft Bill On Withholding Tax

    A European Union advisory body gave the go-ahead to a draft bill that would streamline refunds for withholding tax while helping to prevent fraud, according to an opinion published Tuesday.

  • March 05, 2024

    Aussie Reporting Plan Changes Not Enough, Biz Group Says

    The Australian government's attempt to narrow its plan to require companies to publicly report tax data on operations in 41 jurisdictions on a country-by-country basis still goes beyond international norms, the National Foreign Trade Council said Tuesday.

  • March 05, 2024

    Dutch Co. Appeals Dismissal Of Challenge To Minimum Tax

    The European Union's lower court was wrong to rule that a Dutch company lacked standing to challenge the EU law implementing the global minimum corporate tax, the company said Tuesday in an appeal to the bloc's highest court.

  • March 04, 2024

    Former DOJ Assistant Chief Joins Bird Marella

    The assistant chief in the fraud section of the Department of Justice's Criminal Division joined Bird Marella Rhow Lincenberg Drooks & Nessim LLP, the firm announced Tuesday.

  • March 05, 2024

    Natural Gas Levy Hurts Neighbors, EU Warns Germany

    The European Commission warned Germany that its export tax on sales of natural gas to neighboring EU countries harms the bloc's energy cooperation efforts and damages moves to cut dependence on Russian natural gas.

  • March 04, 2024

    Corporate Transparency Act Unconstitutional, Ala. Judge Says

    An Alabama federal judge has found that the Corporate Transparency Act is unconstitutional, dealing a blow to proponents of the anti-money laundering law, who anticipate the ruling will be appealed to the Eleventh Circuit.

  • March 04, 2024

    UK Trusts Can't Avoid Capital Gains Tax With Treaty

    A lower tribunal correctly held that a capital gains tax exemption in a U.K.-Mauritius treaty did not apply to a share sale made by a group of U.K. trusts because the sale decisions were made in the U.K., not Mauritius, the Upper Tribunal held Monday.

  • March 04, 2024

    Calif. Owes Microsoft $94M After Foreign Dividend Ruling

    Microsoft Corp. can include 100% of dividends received from foreign affiliates in the denominator of its California sales factor and is due a $94 million refund, the state Office of Tax Appeals ruled in opinions obtained Monday by Law360.

  • March 04, 2024

    Hong Kong, Bahrain Agree To Double-Taxation Treaty

    Hong Kong signed an agreement with Bahrain on a treaty to prevent double taxation as part of a larger goal to establish such treaties with countries participating in China's Belt and Road global infrastructure project, Hong Kong's Inland Revenue Department said Monday.

Expert Analysis

  • A Close Look At The Decentralized Effort To Tax Digital Assets

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    Clarity on taxation is one of the biggest hurdles to mass adoption of cryptocurrency, and although digital asset innovation has consistently outpaced worldwide government regulation, recent efforts in the U.S. and elsewhere hint at an emerging standard, says Joshua Smeltzer at Gray Reed.

  • Key Takeaways From IRS Reversal On FDII Stance

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    The Internal Revenue Service's recent memo regarding allocation of deferred compensation expenses for purposes of foreign-derived intangible income is a departure from the agency's previous position and may have implications beyond the context of deferred compensation, say attorneys at Miller & Chevalier.

  • New Tax Decree Suggests Expansion In Dutch Transfer Pricing

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    A July 1 decree from Dutch tax authorities updating transfer pricing guidance heralds a major change in how intercompany financial transactions are considered for transfer pricing purposes and forebodes significant audit activity, say Monique van Herksen and Clive Jie-A-Joen at Simmons and Simmons.

  • Is NJ's Voluntary Transfer Pricing Initiative Really Voluntary?

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    The New Jersey Division of Taxation's voluntary transfer pricing audit initiative promises penalty abatement to taxpayers that elect to participate and agree to the division's proposed adjustments, but the effective penalties associated with nonparticipation raise questions about the program's voluntary nature, say attorneys at McDermott.

  • Global Tax Chiefs Should Look To US Whistleblower Programs

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    As the Joint Chiefs of Global Tax Enforcement develops its international whistleblower program to address tax evasion and money laundering schemes in new areas like cryptocurrency, it should take lessons from highly successful U.S. programs on which features to include and pitfalls to avoid, say Neil Getnick and Nico Gurian at Getnick & Getnick.

  • What Microcaptive Reporting Ruling May Mean For The IRS

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    In CIC v. Internal Revenue Service, a Tennessee federal court’s decision to set aside an IRS requirement to disclose microcaptive insurance arrangements may be a step toward evidentiary standards to show that the potential for abuse in a lawful transaction is sufficient to support heightened disclosure requirements, says Samuel Lauricia at Weston Hurd.

  • US Should Leverage Tax Rules To Deter Business With Russia

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    The U.S. should further restrict the flow of resources available for the Putin regime's war in Ukraine by denying U.S. businesses that operate in Russia or Belarus foreign tax credits and global intangible low-taxed income preferences, and by terminating its tax treaty with Russia, says Reuven Avi-Yonah at University of Michigan Law School.

  • Justices Must Apply Law Evenly In Shadow Docket Rulings

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    In recent shadow docket decisions, the U.S. Supreme Court has inconsistently applied the requirement that parties demonstrate irreparable harm to obtain injunctive relief, which is problematic for two separate but related reasons, says David Hopkins at Benesch.

  • US Investors Stand To Benefit From Brazil's New Forex Law

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    Brazil's New Foreign Exchange Law facilitates negotiations and reduces bureaucracy for foreign investments, making it a good time for U.S. investors looking for projects with a positive environmental, social and governance impact to allocate funds to Brazilian energy and infrastructure, say Jorge Kamine and Juliana Pimentel at Willkie.

  • A Landmark UK Enforcement Case For Crypto-Assets

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    HM Revenue and Customs' recent seizure of nonfungible tokens from three people under investigation for value-added tax fraud promises to be the first of many such actions against crypto-assets, so investors should preemptively resolve potential tax matters with U.K. law enforcement agencies to avoid a rude awakening, says Andrew Park at Andersen.

  • Simplifying Tax Issues For Nonresident Athletes In Canada

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    Tax compliance can be particularly challenging for nonresident professional athletes playing in Canada, but as NHL contract negotiations approach a close, it's worth looking at some ways the tax burden can be mitigated, say Marie-France Dompierre and Marc Pietro Allard at Davies Ward.

  • Steps For Universities As DOJ Shifts Foreign Influence Policy

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    Notwithstanding Wednesday's U.S. Department of Justice announcement terminating the initiative targeting Chinese influence and raising the bar for criminal prosecutions, universities should ensure their compliance controls meet new disclosure standards and that they can efficiently respond to inquiries about employees' foreign connections, say attorneys at Covington.

  • Why I'll Miss Arguing Before Justice Breyer

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    Carter Phillips at Sidley shares some of his fondest memories of retiring Justice Stephen Breyer both inside and out of the courtroom, and explains why he thinks the justice’s multipronged questions during U.S. Supreme Court oral arguments were everything an advocate could ask for.

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