International

  • February 08, 2024

    Estonia Moves To Implement Two Late EU Tax Laws

    The Estonian government took a step Thursday to put in place two European Union-wide tax measures that it has been tardy in putting into national law, a news release from the country's Finance Ministry said.

  • February 08, 2024

    Idaho Woman Contests Lien Over Foreign Tax Form

    The Internal Revenue Service cannot unilaterally impose penalties for failing to timely file a tax form for U.S. citizens involved with certain foreign corporations, an Idaho woman told a federal court, asking it to declare invalid a $350,000 lien placed on her family home.

  • February 07, 2024

    IRS Memo Highlights Tensions In Arm's-Length Loan Pricing

    A recent IRS advice memorandum disregards certain details about affiliated companies when treating them as unrelated businesses for the purpose of pricing an intercompany loan, raising questions about how the arm's-length standard should apply to corporate group financing arrangements.

  • February 07, 2024

    US, Telecom Co. Disagree On Taxes Owed In $283M Suit

    The federal government and a telecommunications company remain at odds over how much tax is owed following a ruling in a different case that the company wasn't entitled to a $109 million refund because it exploited a tax loophole, a Colorado federal judge heard Wednesday.

  • February 07, 2024

    US Eyes Requiring Reports On All-Cash Real Estate Transfers

    Professionals involved in real estate transfers in the U.S. would be required to report on the beneficial owners of trusts and other legal entities that receive residential property in any all-cash transactions under draft regulations released Wednesday that aim to tackle tax evasion and corruption.

  • February 07, 2024

    Iceland's Tax Break For Startup Stock Cleared By Trade Body

    An Icelandic measure that will offer a more favorable tax rate for share option profits by employees of research and development startup companies won approval Wednesday from a European trade body.

  • February 07, 2024

    Dutch Gov't Says €11.5B In COVID-Deferred Tax Still Unpaid

    Dutch business owners still owe €11.5 billion ($12.4 billion) in tax out of the €47.7 billion that was allowed to be deferred under a COVID-19 pandemic relief program, the Netherlands' government said Wednesday.

  • February 07, 2024

    Big 4 Support Irish Foreign Income Tax Exemption Plans

    The Big Four accounting firms expressed broad support for Ireland's plans to introduce corporate tax exemptions for foreign-sourced dividends and foreign branch profits, saying the changes are long overdue and would reduce complexities for taxpayers, according to comments published Wednesday.

  • February 07, 2024

    German Cum-Ex Trial Ends After €2.2M Profit Payback

    German prosecutors agreed to provisionally end a trial of an unnamed individual over a fraudulent tax refund scheme after he agreed to pay back €2.2 million ($2.4 million) in illegally gained profits, a court said Wednesday.

  • February 07, 2024

    EU Urges Greece To Scrap Tax-Free Border Shops

    The European Commission called on Greece on Wednesday to remove an exemption from excise duty for shops on borders with non-European Union countries, saying the shops' untaxed status breached EU law.

  • February 07, 2024

    Germany Defying VAT Exemption For Tutoring, EU Says

    Germany isn't correctly implementing the European Union's value-added tax law, which is supposed to exempt private tutoring services from VAT, the European Commission said Wednesday.

  • February 06, 2024

    UK Windfall Tax Hits BP's Bottom Line As Profits Remain High

    London-based BP PLC laid partial blame on the U.K.'s windfall profits tax for hiking its effective tax rate 5 percentage points to 39% last year as annual profits fell 50% to $13.8 billion, according to filings published Tuesday.

  • February 06, 2024

    UK Broker Says Office Raid During Cum-Ex Probe Was Illegal

    Counsel for commodity brokerage MCML Ltd. told the High Court at a hearing Tuesday that a raid on its London offices over allegations it had defrauded the Danish authorities out of 573 million kroner ($54 million) was illegal.

  • February 06, 2024

    Canada's Info Exchange Rules Found To Meet EU Standards

    Canada's standards for automatic exchanges of information are in line with the European Union's tax information reporting procedures for digital platform operators, known as DAC7, the European Commission determined.

  • February 06, 2024

    Chile's Digital VAT Has Brought In $1B Since 2020, Gov't Says

    Chile's value-added tax on digital services from platform providers with no domicile in the country, such as Google and Meta, has generated more than $1 billion since taking effect in 2020, the country's revenue agency said.

  • February 06, 2024

    Man Gets 41 Months, Will Pay $1.3M For Foreign Tax Evasion

    A Texas man who pled guilty in 2023 to evading more than $1 million in taxes on foreign income will serve 41 months in prison and pay fines and restitution of $1.3 million, a Texas federal court ruled.

  • February 06, 2024

    Building Society Expects £9.4M More Tax In Dispute with A&O

    Nationwide Building Society expects to face additional tax liabilities estimated at £9.4 million ($11.8 million) in its dispute with Allen & Overy over that firm's failure to notify the company that certain financial notes were not delisted from the London Stock Exchange, the building society told the High Court. 

  • February 06, 2024

    Thailand Extends Crypto VAT Exemption Indefinitely

    Thailand is extending its value-added tax exemption on the trading of cryptocurrency indefinitely, as well as broadening its scope to include more types of trades, a Finance Ministry official said Tuesday.

  • February 06, 2024

    Tax A Key Tool To Reach Climate Target, EU Commission Says

    Taxing carbon should be a key tool for the European Union to reach its new 2040 targets for cutting greenhouse gas emissions, providing incentives for green investments and generating revenue to combat climate change, the European Commission suggested Tuesday.

  • February 06, 2024

    UAE, Hong Kong Tax Regimes Not Harmful, OECD Says

    Tax regimes in the United Arab Emirates and Hong Kong that were under investigation by an Organization for Economic Cooperation and Development group for being potentially harmful were found to be in compliance with anti-tax base erosion standards, it said Tuesday.

  • February 06, 2024

    Swiss Eye Bill To Stop Lotto Winners Moving To Save On Tax

    Switzerland is considering a bill that would make it harder for high-end lottery winners to change their locations within Switzerland to save money on taxes after a massive payout.

  • February 06, 2024

    EU Lawmaker Wants To Tax Goods From Russia

    A member of the European Parliament called for a tax on trade with Russia, saying money from the tax could help Ukraine rebuild from Russia's invasion, which started nearly two years ago.

  • February 06, 2024

    International Unity Needed To Seize Russian Assets, EU Says

    Europe would have to coordinate closely internationally with the Group of Seven nations to confiscate frozen Russian state assets, the European Commission said Tuesday.

  • February 05, 2024

    Brazil Aiming To Overhaul Income Tax System By Summer

    Brazil is aiming to overhaul its income tax system by summer after lawmakers overhauled consumption taxes late last year, but regulations for consumption taxes may take precedence initially with an income tax bill due in March, officials said Monday during Congress' opening session.

  • February 05, 2024

    Colo. Woman Accused Of Tax Crimes Must Keep GPS Monitor

    A woman indicted on charges of evading $2 million in taxes must continue wearing her ankle monitor as a condition of release, a Colorado federal court ruled, after the U.S. government noted that she has a permit to work in Dubai.

Expert Analysis

  • The Reciprocal Tax Bill Is A Warning Shot At Pillar 2

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    A bill recently introduced in the House of Representatives to reciprocally tax countries deemed to have imposed discriminatory taxes on U.S. citizens and businesses takes aim at countries implementing the global minimum tax treaty known as Pillar Two, with which the U.S. has not complied, says Alan Cole at the Tax Foundation.

  • What Tax-Exempt Orgs. Need From Energy Credit Guidance

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    Guidance clarifying the Inflation Reduction Act’s credit regime, expected from the U.S. Department of the Treasury this summer, should help tax-exempt organizations determine the benefits of clean energy projects and integrate alternative energy investments into their activities, say attorneys at Morgan Lewis.

  • How Foreign Info Return Penalty Case May Benefit Taxpayers

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    The U.S. Tax Court's recent decision that the Internal Revenue Service cannot penalize taxpayers for failing to file foreign corporation information returns may give similarly situated taxpayers an opportunity to also avoid penalties, provided they protect their rights before the decision is overturned or mooted by legislation, say attorneys at Arnold & Porter.

  • The Nuts And Bolts Of IRS Domestic Content Tax Credit

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    Recent IRS guidance provides specifics on how renewable energy projects can qualify for bonus tax credits by meeting U.S. domestic content rules, but also creates a qualification framework that will be complicated for project developers to navigate, say Scott Cockerham and Wolfram Pohl at Orrick.

  • Taxing The Digital Economy: The Good, The Bad And The Ugly

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    U.S. tech companies should watch for important developments in international taxation, including the resolution of Apple's decade-old state aid case, growing frustration with the Organization for Economic Cooperation and Development's global tax plan and adoption of the digital services tax instead, says Joyce Beebe at Rice University's Baker Institute for Public Policy.

  • Big Tax Changes For Multinational Cos. In Budget Proposal

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    The Biden administration’s fiscal year 2024 budget proposes changes that would materially alter decades-old Internal Revenue Code provisions, requiring a shift in multinational corporations' tax planning strategies comparable to that required after enactment of the Tax Cuts and Jobs Act, say Xenia Garofalo and Kyle Colonna at Eversheds Sutherland.

  • Senate Credit Suisse Report Puts Attention On Banks, Trusts

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    The Senate Finance Committee's recent finding that Credit Suisse violated a plea agreement struck over its role in enabling offshore tax evasion has important ramifications for banks and trusts, including how they onboard, document and report on transactions relevant to U.S. reporting requirements, say Will Barry and Ian Herbert at Miller & Chevalier.

  • Seeking IRS Accountability For Faulty Microcaptive Notice

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    Like the taxpayers in Standard Insurances v. U.S. seeking to expand earlier wins in microcaptive insurance cases that limit IRS use of improperly obtained information, others should consider ways to hold the agency accountable and provide incentive for it to follow the law going forward, says Joshua Smeltzer at Gray Reed.

  • 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.

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