International

  • February 05, 2024

    Ireland Aims To Drop Warehoused Debt Interest, Pay Refunds

    Irish companies that still owe taxes that they deferred as part of a so-called debt warehousing scheme rolled out during the COVID-19 pandemic would no longer have to pay interest under proposed legislation announced Monday by the country's Department of Finance.

  • February 05, 2024

    German Economy Minister Calls For Corporate Tax Relief

    Germany needs to strengthen its economic competitiveness by changing its corporate tax code to benefit businesses, the country's economy minister told a local news agency Monday.

  • February 05, 2024

    GOP Lawmakers' Concerns Spur Talks On German Royalty Tax

    House Ways and Means Committee Republicans have been in touch with U.S. Treasury Department officials to address the lawmakers' concerns about a German withholding tax imposed on intellectual property registered in the country, a GOP lawmaker told Law360.

  • February 05, 2024

    Australia Seeking Input On Film Production Tax Offset Change

    Australia is looking for the public to weigh in on a proposal to nearly double the tax offset available to production companies filming movies there in hopes of attracting more productions, the country's Treasury announced Monday.

  • February 02, 2024

    Japan Considering Patent Box Regime, Taxing Digital Services

    Japan's Ministry of Finance sent a bill to the country's legislature Friday that would introduce a tax obligation for some digital platform operators and implement a patent box regime, among other proposed changes.

  • February 02, 2024

    Couple Owe Reduced FBAR Penalty Of $400K, Court Says

    An Oregon couple must pay almost $400,000 in fines, interest and penalties for failing to report their foreign bank accounts to the Internal Revenue Service, a federal court said.

  • February 02, 2024

    Lawyer Struck Off Roll Over $14M US Tax Fraud Conviction

    A British lawyer who was convicted in the U.S. over a multimillion-dollar tax fraud was barred from practicing in England on Friday after a tribunal concluded that he was shown to have been dishonest.

  • February 02, 2024

    ED&F To Face £56M Trial Over Role In Danish Cum-Ex Fraud

    Denmark's £56 million ($70.7 million) claim against ED&F over its alleged role in a fraudulent tax refund scheme can head to trial, a London judge ruled Friday despite finding that the Danish tax authority could have raised its new case against the broker earlier.

  • February 02, 2024

    UK Labour Party Vows To Keep Corp. Tax Rate, Full Expensing

    The U.K.'s Labour Party is committed to keeping the government's corporate income tax rate at 25% and to keeping full capital expensing for businesses, party leaders told business executives at a conference in London.

  • February 02, 2024

    Eaton Asks Court To Agree To Block IRS Summons

    Multinational power management company Eaton Corp. urged an Ohio federal court to adopt a magistrate judge's recommendation to allow the company to buck an IRS summons for confidential performance evaluations of its foreign employees, saying the government's objection underplays the documents' sensitivity.

  • February 02, 2024

    Denmark Sentences Brit Trader To 6 Years For Cum-Ex Fraud

    A British trader who defrauded the Danish treasury out of 320 million Danish kroner ($46.7 million) in a sham tax reclaim scheme was sentenced to six years in prison Friday, Danish prosecutors said.

  • February 02, 2024

    Tax Adviser Group Criticizes EU Transfer Pricing Proposal

    A European association of tax advisers warned that the European Commission's proposal for new transfer pricing legislation in the European Union is costly and complicated and exceeds the EU's legal boundaries.

  • February 02, 2024

    Swedish Parliamentary Panel Objects To EU's BEFIT Proposal

    The tax committee of Sweden's Parliament objected to a draft framework for corporate taxation in the European Union, saying it breached the boundaries of EU legislation.

  • February 02, 2024

    Taxation With Representation: Simpson, Wachtell Lipton

    In this week's Taxation With Representation, Rise Growth Partners receives a $250 million investment, a group of investors led by Carlyle Group co-founder David Rubenstein acquires a controlling stake in MLB's Baltimore Orioles, The Cigna Group sells multiple Medicare businesses to Health Care Service Corp., and WillScot Mobile buys McGrath RentCorp.

  • February 02, 2024

    CPS Denies Liability in Ex-Sidley Lawyer Failed Prosecution

    The Crown Prosecution Service has denied being liable for its botched tax fraud prosecution of a former Sidley Austin LLP lawyer, a former senior KPMG official and a banking adviser, who are collectively seeking more than £66 million ($84 million) from the U.K.'s main prosecutor.

  • February 01, 2024

    Kemp Klein Brings On Tax Attorney From Foster Swift

    Kemp Klein Law Firm said Thursday that it added a shareholder to its team who was formerly with Foster Swift Collins & Smith PC and counsels clients in tax planning.

  • February 01, 2024

    India Budget Includes Abrupt End Of Manufacturing Tax Break

    India plans to allow its reduced corporate income tax rate for manufacturing facilities to sunset in April in an unexpected move, while seeking extensions to tax holidays for startups and sovereign wealth funds, attorneys told Law360 on Thursday about the government's interim budget.

  • February 01, 2024

    Lawyer Convicted Of Tax Fraud Can't Halt Disciplinary Case

    An English tribunal refused Thursday to throw out a disciplinary case against a lawyer over his conviction for tax fraud in the U.S., rejecting his argument that it couldn't hear his case because he wasn't a registered solicitor at the time.

  • February 01, 2024

    Canada Seeks Input On Patent Box Regime, R&D Credit

    Canada is asking the public for input on whether a patent box tax regime would be suitable for the country and whether the government can improve the structure of its research and development tax credit.

  • February 01, 2024

    EU Leaders Slow Plan To Use Frozen Russian Assets

    European Union leaders reined in the bloc's rush to use frozen and immobilized Russian state assets for the reconstruction of Ukraine, as leaders from Germany, France and Italy called for caution Thursday.

  • February 01, 2024

    Italy Working On Social Media Tool To Detect Tax Evasion

    Italian authorities are developing a tool to compare social media users' posts against their tax returns to flag potential tax evasion, an official with the country's Finance Ministry said.

  • February 01, 2024

    Duet Group Co-Founder Gets Nearly 5-Year Cum-Ex Sentence

    The co-founder of the London-based Duet Group investment firm received a nearly five-year jail sentence for crimes related to so-called cum-ex activities following a trial in Germany, a person familiar with the verdict confirmed to Law360 on Thursday.

  • February 01, 2024

    Payroll Biz Director Can't Challenge £21M VAT Fraud Decision

    A London judge has refused a bid by a director of a defunct payroll services company to overturn a finding that he defrauded the taxpayer of £21 million ($26 million) by under-declaring value-added tax.

  • January 31, 2024

    House Sends Bipartisan Tax Break Package To Senate

    The House of Representatives passed a bipartisan bill Wednesday night that would extend the full tax break for research and development costs and expand the child tax credit for multiple years, sending the deal to the Senate for consideration.

  • January 31, 2024

    Serbian Dual Citizen Must Pay $5.3M FBAR Penalty

    A man with dual citizenship in the U.S. and Serbia will have to pay $5.3 million in penalties and interest for willful failure to report a Swiss bank account, according to a judgment a New York federal judge issued Wednesday.

Expert Analysis

  • High Court Ax Of Atty-Client Privilege Case Deepens Split

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    The U.S. Supreme Court's recent dismissal of In re: Grand Jury as improvidently granted maintains a three-way circuit split on the application of attorney-client privilege to multipurpose communications, although the justices have at least shown a desire to address it, say Trey Bourn and Thomas DiStanislao at Butler Snow.

  • US-India Advance Pricing Resolutions Should Reassure Cos.

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    The United States' and India's tax authorities' recent resolution of a significant number of pending advance pricing agreements should reduce taxpayer uncertainty, reassure companies of the nations' good working relationship and improve India's investment environment, say Miller Williams and Caroline Setliffe at Eversheds Sutherland.

  • Stock Buyback Excise Tax Guidance A Mixed Bag For SPACs

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    Recent IRS guidance on the new stock repurchase excise tax includes a welcome exception for publicly traded special-purpose acquisition companies but does not exclude redemptions in connection with a de-SPAC transaction, and further guidance is needed to clarify ambiguities around the exception's application, say Olga Bogush and Evgeny Magidenko at ArentFox Schiff.

  • The IRS' APA Rulemaking Journey: There And Back Again

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    Attorneys at Dentons examine recent challenges in which taxpayers successfully argued Internal Revenue Service rulemaking was invalid under the Administrative Procedure Act, how tax exceptionalism and U.S. Supreme Court regulatory deference prompted such challenges, and similar challenges the agency will likely face following this line of cases.

  • ECJ Fiat Ruling Sets Clear Boundaries For EU State Aid Law

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    The European Court of Justice's recent landmark decision in Fiat v. Commission limiting the commission’s attempts to circumvent the lack of EU powers in the area of tax law has important implications in EU state aid law and beyond, say Andreas Reindl and Pietro Stella at Van Bael.

  • Unpacking The Interim Guidance On New Stock Buyback Tax

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    The U.S. Department of the Treasury and Internal Revenue Service's recent notice on applying the newly effective excise tax on stock repurchases provides much-needed clarity on the tax's scope, which is much broader than anticipated given its underlying policy rationale, say attorneys at Eversheds Sutherland.

  • IRS Will Use New Resources To Increase Scrutiny In 2023

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    The new year promises to be a busy one for the Internal Revenue Service, which is poised to apply the boost in funding provided by the Inflation Reduction Act to bolster and expand its enforcement capability, and there are four areas to watch, say attorneys at Skadden.

  • How Japan's Implementation May Change The Pillar 2 Debate

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    Japan’s outline of proposed legislation adopting a primary component of the Organization for Economic Cooperation and Development's 15% global minimum tax will increase pressure on countries — including the U.S. — that have not committed to adopting Pillar Two, says Takato Masuda of Nishimura & Asahi.

  • 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.

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