International

  • 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.

  • March 04, 2024

    TCJA To Reduce Corporate Tax Revenue By 40%, Study Says

    The 2017 Tax Cuts and Jobs Act is expected to reduce corporate tax revenue by about 40% over a decade after increased investment in the U.S. is accounted for, according to a study published Monday by the National Bureau of Economic Research. 

  • March 04, 2024

    Thailand Floats Enactment Of OECD's Global Minimum Tax

    Thailand is looking for public input on its plan to implement the Organization for Economic Cooperation and Development's global corporate minimum tax, its Revenue Department said.

  • March 02, 2024

    Indian Cell Provider Not Responsible For Withholding Taxes

    A cellphone service provider is not responsible for withholding taxes on the income earned by its distributors, the Indian Supreme Court ruled.

  • March 01, 2024

    Aussie Royalty Ruling Counter To Int'l Standards, Groups Say

    An updated version of Australia's draft ruling regarding the taxation of royalty income from certain software and other intellectual property transactions runs afoul of international standards, according to two industry groups.

Expert Analysis

  • 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.

  • Corporate Reporting Considerations As Tax Meets ESG

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    With the U.S. Securities and Exchange Commission filing season upon us amid increasing pressure for greater transparency around effective tax rates and tax strategies, multinational companies must decide how they will approach voluntary tax reporting and prepare their responses if they want to control the narrative, say Michael Lebovitz and Jenny Austin at Mayer Brown.

  • The Highs And Lows Of Tax Controversy In 2021

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    Lawrence Hill at Steptoe & Johnson reviews the ups and downs of tax controversy practice in 2021, including the continued effects of the pandemic, troubling decisions on attorney-client privilege and an IRS comeback on transfer pricing.

  • Lessons From IRS For A New HMRC Whistleblowing Model

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    Andrew Park at Andersen considers whether the public interest would be better served in allowing the U.K.'s tax enforcers, HM Revenue & Customs, to offer larger and more certain cash incentives to people blowing the whistle on tax misdemeanors — similar to the IRS model for whistleblowers.

  • The Benefits Of Competent Authority In Int'l Tax Disputes

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    Multinational enterprises seeking relief from double taxation in a changing international tax landscape should consider utilizing the competent authority process, which provides both taxpayers and domestic tax regulators an efficient and effective means of dispute resolution, say David Farhat and Eman Cuyler at Skadden.

  • How OECD Transfer Tax Initiative Affects Smaller Businesses

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    Small and midsize enterprises with cross-border transactions need to consider redefining tax strategies and operational models in light of the Organization for Economic Cooperation and Development's base erosion and profit shifting initiative, even though the agency's new tax guidelines are aimed at large multinational enterprises, says Ganesh Ramaswamy at Kreston Rangamani.

  • What The New OECD Double-Tax Procedure Statistics Tell Us

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    Monique van Herksen and Clive Jie-A-Joen at Simmons & Simmons consider the Organization for Economic Cooperation and Development’s recent report on double taxation cases resolved in 2020 under the mutual agreement procedure process, and examine whether the process has improved dispute resolution mechanisms since its implementation five years ago.

  • Navigating FCPA Risks Of Minority-Owned Joint Ventures

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    The U.S. Department of Justice and U.S. Securities and Exchange Commission will likely continue to focus on third-party risks under the Foreign Corrupt Practices Act, so companies with minority-owned joint ventures should take several steps to mitigate related compliance challenges, say Ben Kimberley at The Clorox Company and Addison Thompson at Covington.

  • Questions To Ask If Doing Business In A Corruption Hot Spot

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    Businesses facing new scrutiny after the U.S. Department of Justice's recently announced task force for combating human trafficking in Central America, the release of the Pandora Papers and continuing fallout from 2019's Panama Papers, should address compliance risks by having employees ask three questions about every transaction, say attorneys at White & Case.

  • How The Global Tax Agreement Could Backfire For Biden

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    If the $3.5 trillion spending package fails, the federal tax code will not conform to the recent 15% global minimum tax agreement spearheaded by the U.S., which would embarrass the Biden administration and could lead to retaliatory tax measures by other nations, says Alex Parker at Capitol Counsel.

  • Pandora Papers Reveal Need For Greater Tax Enforcement

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    The recent Pandora Papers leak is a reminder of the importance of transparency laws and proper funding for enforcement efforts against tax evasion as bad actors increasingly operate in the shadows, says Daren Firestone and Kevin Crenny at Levy Firestone.

  • Parsing New Int'l Tax Reporting Rules For Pass-Throughs

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    Attorneys at Grant Thornton unpack the Internal Revenue Service’s new pass-through entity reporting requirements for international tax matters and the accompanying guidance for penalty relief, and suggest how companies should prepare for what may be the most significant change to the partnership compliance function in decades.

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