International

  • 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.

  • March 01, 2024

    IRS Turning To Experts, AI For Complex Returns, Werfel Says

    The Internal Revenue Service is using a blend of newly hired subject-matter experts and artificial intelligence technology to increase scrutiny of complex tax returns filed by wealthy corporations and individuals, agency Commissioner Daniel Werfel said Friday.

  • March 01, 2024

    Major Cos. Paying Well Below 21% TCJA Tax Rate, Study Says

    Major corporations such as Netflix and T-Mobile are on average paying well below the 21% corporate tax rate established by the 2017 Tax Cuts and Jobs Act, a study by the Institute on Taxation and Economic Policy of more than 340 major corporations showed.

  • March 01, 2024

    UN Jabs OECD Over Human Rights Amid Tax Policy Tension

    Inquiries made by United Nations officials to the Organization for Economic Cooperation and Development about how the OECD's international tax plan affects the rights of individuals indicate continuing tension between the two intergovernmental bodies that shows little sign of easing.

  • March 01, 2024

    House Tax Panel To Prep Members On OECD Pillar 1

    Neither Republicans nor Democrats on the House Ways and Means Committee have opined much about the OECD profit reallocation plan known as Pillar One, but they will gain valuable information during an upcoming subcommittee meeting, a tax staffer for the panel said Friday.

  • March 01, 2024

    VAT Fraud Led To €11.5B In Damages To EU Budget

    Despite making up just 18% of all active European Public Prosecutor's Office investigations by the end of 2023, value-added tax fraud cases amounted to more than €11.5 billion ($12.5 billion) in estimated damages to the European Union budget, the EPPO said Friday.

  • March 01, 2024

    Taxation With Representation: Pillsbury, Cleary Gottlieb

    In this week's Taxation with Representation, First Advantage Corp. acquires Sterling Check Corp., International Game Technology spins off two subsidiaries, Disney merges its media operations in India with Reliance Industries, and Atlas Energy Solutions purchases Hi-Crush.

  • February 29, 2024

    Czech Republic May End Windfall Tax Early, Minister Says

    The Czech Republic may end its windfall tax on the profits of banks as well as petrochemical and energy companies a year before its scheduled expiration, its finance minister said Thursday.

  • February 29, 2024

    Global Wealth Tax Plan Could Mirror Pillar 2, G20 Told

    A global minimum wealth tax featuring a top-up tax and enforcement system similar to the global minimum tax on corporations would reduce the ability of very wealthy individuals to avoid the measure by relocating, according to a presentation made to the Group of 20 nations Thursday.

  • February 29, 2024

    Biz Owner's $2.4M FBAR Dispute Paused For Mediation

    The U.S. government and a retired plumbing business owner mutually agreed to a 90-day stay of their $2.4 million tax dispute over foreign bank account reporting while they try to mediate a solution, a Georgia federal judge said Thursday.

  • February 29, 2024

    Spain Updating Control Measures For Foreign Online Sellers

    Spain's government is updating its control measures to better its ability to collect value-added taxes from foreign-based operators selling goods online to customers in the country, its tax agency said Thursday.

  • February 29, 2024

    Senate Confirms First Woman To Top IRS Attorney Post

    The U.S. Senate on Thursday confirmed a former director at EY who previously served as associate chief counsel, international, at the Internal Revenue Service to be the agency's chief counsel, making her the first woman to be confirmed for the role.

  • February 29, 2024

    Medtronic Says 3 Years Of Tax Returns Under IRS Audit

    Three years of medical device company Medtronic's federal income tax returns are being audited by the Internal Revenue Service, the company said in a U.S. Securities and Exchange Commission filing.

  • February 29, 2024

    HMRC Uncovers Complex Offshore Tax Avoidance Scheme

    The U.K. tax authority said Thursday that it had exposed a complex tax avoidance scheme operating through a Singapore-based company.

  • February 29, 2024

    European Authorities Arrest 14 In €195M VAT Fraud Probe

    European law enforcement agencies said Thursday that they had arrested 14 people suspected in a €195 million ($211 million) value-added tax fraud across 17 countries.

  • February 29, 2024

    Disclosure Law Holds Up Under Scrutiny, ECJ Adviser Says

    A European Union law that requires tax advisers to disclose some cross-border arrangements does not violate the principles of EU law, an adviser to Europe's highest court said Thursday.

  • February 28, 2024

    Amgen Seeks Dismissal Of Investor Action Over $11B Tax Bill

    Amgen had no obligation to disclose specific amounts of proposed adjustments to its taxes, the company told a New York federal court as it again demanded dismissal of a proposed class action alleging the company hid a $10.7 billion tax bill from investors.

  • February 28, 2024

    SC Legislature OKs Standards For Transfer Pricing Matters

    South Carolina lawmakers passed a bill Wednesday that would impose additional standards for when the state or a business can assert alternative apportionment when evaluating transfer pricing matters.

  • February 28, 2024

    G20 To Talk Global Minimum Wealth Tax At Brazil's Behest

    The Group of 20 nations' finance ministers and central bank governors will hear proposals for a global minimum tax on wealth Thursday, Brazil's finance minister said Wednesday while expressing support for the policy idea at the opening of meetings in São Paulo.

  • February 28, 2024

    EU Authorities Bust €30M Italian VAT Fraud Ring

    Nine suspects were arrested as part of an investigation into an Italian fraud ring involving beverage sales that resulted in them dodging €30 million ($32.5 million) in value-added taxes, the European Public Prosecutor's Office said.

  • February 28, 2024

    Bank Disputes South Africa's $254M Claim Over Client Taxes

    A South African bank said it should not be held liable for 4.9 billion rand ($254.2 million) plus interest and costs for taxes that the country's revenue service could not collect from the bank's former foreign exchange clients due to illegal actions.

  • February 28, 2024

    Hong Kong To Propose Increased Tax On High Earners

    Hong Kong's government plans to propose a two-tiered income tax rate system that would impact those making over HK$5 million ($639,000) per year, its financial secretary said Wednesday.

  • February 28, 2024

    Stalled Pillar 1 Raises Specter Of EU Digital Tax

    The stalling at the international level of a redistribution of taxing rights known as Pillar One is raising questions about whether the European Union would revive a digital tax, which it had put aside hoping Pillar One would succeed.

  • February 28, 2024

    Draft EU Withholding Law Breezes Through EU Parliament

    The European Parliament gave a clear green light on Wednesday to a draft law intended to streamline refunds for withholding tax and prevent fraud in the European Union, completing a necessary procedural step in the legislative process.

  • February 27, 2024

    US Biz Group Urges Treasury Against Basis Denial Rule

    The U.S. Treasury Department should rethink its proposed upcoming rule that would deny the basis that U.S. companies have in particular foreign affiliates involved in certain inbound transactions, the National Foreign Trade Council said in a letter made public Tuesday.

Expert Analysis

  • A Look At Global Tax Enforcement Developments: Part 2

    Excerpt from Practical Guidance
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    Sean Craig at LexisNexis examines recent investigations by the Joint Chiefs of Global Tax Enforcement and their impact on U.S. taxpayers, as well as the growing significance of transfer pricing disputes and policies for future enforcement.

  • A Look At Global Tax Enforcement Developments: Part 1

    Excerpt from Practical Guidance
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    Sean Craig at LexisNexis looks at how international initiatives, such as the Joint Chiefs of Global Tax Enforcement, are addressing cryptocurrency-related tax evasion, and how the COVID-19 pandemic and increasing demands for governmental welfare programs are driving global tax policy.

  • EU Climate Plan Should Involve Taxing Pollution, Not Borders

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    In order to crack down on greenhouse gas emissions, the European Union proposes to levy carbon emissions at its borders and to overhaul its long-standing energy tax framework, but the latter would hold polluters directly accountable, giving it the better chance for success, says Rebecca Christie at Bruegel.

  • Prepare For Global Tax Regime's New Biz Dispute Risks

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    Companies should take steps to mitigate the business dispute risks of the new international tax framework, which over a hundred countries agreed to in July, as implementing the new regime will be expensive and require substantial organizational restructuring efforts, says Tim McCarthy at Dykema.

  • Prepare For More Audits Of Tax Info And Withholding Filings

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    Financial institutions and other corporate taxpayers should focus compliance efforts on tax information reporting and withholding, given recent indications from the Biden administration that the IRS will increase enforcement, and the administration's need to fund its infrastructure plan and other costly initiatives, say attorneys at Mayer Brown.

  • Anti-Boycott Compliance Still Key In UAE Business Dealings

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    Notwithstanding recent amendments to U.S. anti-boycott laws that reflect the United Arab Emirates' withdrawal from the Arab boycott of Israel, companies doing business in the UAE and elsewhere still need to maintain effective anti-boycott compliance programs to avoid reporting violations or penalties, says Howard Weissman at Miller Canfield.

  • 9th Circ. Adds Pressure To Reject Substance Over Form

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    The Ninth Circuit’s recent decision rejecting taxes on a family's Roth IRA payments that were made through a foreign sales corporation represents a refreshing trend among federal appeals courts to reject substance-over-form principles and instead look to congressional intent, say Lawrence Hill and Caitlin Tharp at Steptoe & Johnson.

  • Will The OECD Plan Fix International Taxation?

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    Lilian Faulhaber at Georgetown Law breaks down the Organization for Economic Cooperation and Development’s plan for international tax reform, recently joined by 130 countries, and whether it will solve the problems it was designed to address, including the need for multinational companies to pay their fair share of taxes in the digitized world economy.

  • What Biden's Tax Proposals May Mean For Int'l Private Clients

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    Jennifer Wioncek and Paul D’Alessandro at Bilzin Sumberg discuss the U.S. Department of the Treasury's recently released explanation of the Biden administration's tax proposals and how the changes would affect income and wealth transfer planning for international private clients.

  • What Crypto Holders Can Learn From Early-2000s Tax Scandal

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    The Internal Revenue Service’s recent push to gather information about cryptocurrency accounts is similar to its Swiss bank account investigations of the early 2000s, which should prompt taxpayers to consider voluntarily disclosing transactions before they are individually targeted for enforcement, say Timothy Wagner and Thomas Barnard at Baker Donelson.

  • International Tax Reform's Implications For Transfer Pricing

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    As the Organization for Economic Cooperation and Development overhauls the global tax rules on base erosion and profit shifting, and the Biden administration rolls out new U.S. tax proposals, multinational enterprises need to prepare for the effects of these tax changes on their transfer pricing structures, say Mandy Li and Shuang Feng at MGO.

  • Justices' Preemptive Tax Challenge Ruling Shows Divisions

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    The U.S. Supreme Court's recent decision in CIC Services v. Internal Revenue Service reveals divisions among the justices about when potentially burdensome tax regulations can be challenged, making the holding less clear and less valuable, say George Isaacson and David Swetnam-Burland at Brann & Isaacson.

  • Takeaways From 2 New FBAR Rulings

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    In light of two recent California federal court decisions, capping penalties for nonwillful violations of foreign bank account reporting but broadening the willfulness standard, U.S. taxpayers must be vigilant about understanding their reporting obligations, and prepare for the Internal Revenue Service to target willful conduct, which yields much higher penalties, say Friedemann Thomma and Marianna Felshtiner at Venable.

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