International

  • January 26, 2024

    Hungary Adjusts Pharmaceutical Tax To Conform To Pillar 2

    Hungary amended a special tax rate for pharmaceutical manufacturers to conform to the Organization for Economic Cooperation and Development's global corporate minimum tax, the country's Ministry of Finance said Friday.

  • January 26, 2024

    HMRC Transfer Pricing Inquiries Took 5 Months Longer

    HM Revenue & Customs fielded fewer transfer pricing inquiries in 2022-23 compared with the prior tax year, but the time it took to close them went up by almost five months, according to statistics released by the British tax authority.

  • January 26, 2024

    Bipartisan Tax Break Bill Faces Rocky Road To Passage

    A bipartisan tax bill that quickly cleared the House's tax panel faces a tumultuous path forward in the full chamber, where Speaker Mike Johnson, R-La., needs to either have robust bipartisan support to pass the bill or risk opening it up to changes.

  • January 26, 2024

    Tax Group Of The Year: Mayer Brown

    Mayer Brown LLP secured local and global victories in 2023, from a Washington state appellate court's decision in a novel sales tax case to an energy company's $307 million merger resulting in a business with an Africa exploration and production focus, earning the firm a spot among Law360's Tax Groups of the Year.

  • January 26, 2024

    EU Defends Latest Economic Sanctions Against Russia

    The European Union on Friday defended its new round of economic sanctions to be imposed on Russia against claims from the Kremlin that all EU sanctions are illegal and harm Europe and the world.

  • January 26, 2024

    Biz Lobby Urges That BEFIT Wait On Stable Global Tax Rules

    A European business lobby criticized a new draft framework for corporate taxation in the European Union, saying it does not achieve its goals of reducing compliance costs and simplifying the tax landscape and should be delayed until global tax rules stabilize.

  • January 26, 2024

    US Expatriations Rise In 4th Quarter, IRS Says

    The number of people who expatriated from the U.S. jumped nearly 45% during the fourth quarter of 2023 compared with the previous quarter, the Internal Revenue Service said in a notice published Friday.

  • January 25, 2024

    UK Tribunal Rejects Ruling On Foreign Dividend Tax Relief

    Investment funds and an insurance company challenging whether their double tax relief claims for taxes paid on foreign dividend payments were proper could face stricter rules on those provisions after a U.K. Upper Tribunal on Thursday rejected a more flexible interpretation of those laws.

  • January 25, 2024

    ECJ Adviser Rejects Spanish Excise Taxes On Mineral Oils

    A European Union state cannot impose varying levels of excise taxes on mineral oils for autonomous regions, an adviser to the European Court of Justice said Thursday in a preliminary ruling sought by Spanish courts.

  • January 25, 2024

    John Hancock Clients Owed Tax Credit Perk, 11th Circ. Told

    John Hancock Life Insurance Co. clients urged an Eleventh Circuit panel on Thursday to reverse a lower court's ruling that the company didn't breach a fiduciary duty when $100 million worth of foreign tax credits wasn't passed through to them, saying the transaction diminished the value of their retirement accounts.

  • January 25, 2024

    EU Says 9 Members Late To Enact Global Minimum Tax Rules

    Nine countries that delayed adoption of the 15% global minimum tax haven't complied with rules saying they must order their multinational companies to require a subsidiary in a country with the tax to file a return for the group, the European Commission said Thursday.

  • January 25, 2024

    Aussie Mining Cos. Call For Tax Break To Counter US Credit

    Mining companies in Australia asked the country's government Thursday to establish a tax credit to make up for business lost to the U.S. as a consequence of the Inflation Reduction Act.

  • January 25, 2024

    Loeb & Loeb Hires 20-Year McDermott Tax Partner In Chicago

    Loeb & Loeb LLP has hired a McDermott Will & Emery LLP partner who spent the past 20 years at the platform working on tax and estate planning matters, according to a Thursday announcement.

  • January 25, 2024

    Tax Group Of The Year: Eversheds Sutherland

    Eversheds Sutherland's tax practice earned key victories in 2023, including one for Fitzgerald Truck Parts and Sales LLC in a $400 million tax refund battle with the IRS and another for Verizon Communications in a fight with New York state over gross receipts taxes, landing it among Law360's 2023 Tax Groups of the Year.

  • January 25, 2024

    EU Prosecutors Investigating €40M VAT Fraud From Tire Sales

    Italian authorities carried out searches Thursday in an investigation into what the European Public Prosecutor's Office said is an almost €40 million ($43.4 million) value-added tax fraud scheme involving the sale of tires.

  • January 25, 2024

    UK Tax Cuts Fiscally Risky, Think Tank Argues

    The U.K. government will have to reverse any tax cuts it takes now or make drastic public spending cuts in the near future, the Institute for Fiscal Studies, an influential think tank, said Thursday.

  • January 25, 2024

    EU Official Defends Country Adjustments In BEFIT

    A European Commission official on Thursday defended a provision in the commission's new draft framework for corporate tax law that allows individual European Union member countries to adjust the allotment of the tax base.

  • January 25, 2024

    Russia Hits Out At EU Over Latest Sanctions Move

    Russia has hit out against the European Union for preparing a 13th economic sanctions package against the Kremlin regime, claiming that the sanctions are illegal and harmful to Europe and the world.

  • January 24, 2024

    Bid To Swap Chevron For An Old Standby Raises Doubts

    Last week, the U.S. Supreme Court debated whether a World War II-era doctrine encouraging courts to strongly consider agency statutory interpretations could replace the court's controversial so-called Chevron doctrine that requires judges to defer to those interpretations if a statute is ambiguous.

  • January 24, 2024

    Justices' Repatriation Tax Review May Disrupt Investor Levies

    The U.S. Supreme Court has signaled the possibility of a narrow ruling that upholds the one-time mandatory repatriation provision, but justices could still undermine certain capital markets measures if they question the constitutionality of taxes on unrealized income.

  • January 24, 2024

    Dead Film Exec's IRS Summons Invalid, High Court Told

    The daughter of a dead film executive asked the U.S. Supreme Court to review a Ninth Circuit decision approving an IRS summons for her father's financial records, saying the documents stemmed from an illegal search of his home in Los Angeles triggered by Italian authorities.      

  • January 24, 2024

    Hong Kong, Croatia Reach Deal On Double-Tax Treaty

    Hong Kong signed an agreement with Croatia on a treaty to prevent double taxation Wednesday as part of a larger goal to establish such treaties with countries participating in China's Belt and Road global infrastructure project.

  • January 24, 2024

    Sweden Proposes Acquisition Deduction Allowance Increase

    An entity acquiring a loss maker would be able to deduct a previous year's deficit for up to 300% of the acquisition price under a proposal from Sweden's Finance Ministry as part of a package of tax proposals ahead of the upcoming budget.

  • January 24, 2024

    Tax Group Of The Year: Cravath

    Cravath Swaine & Moore LLP attorneys provided tax advice to Johnson & Johnson on a landmark $41 billion spinoff of its consumer health business to Kenvue Inc. that led to a $4.37 billion initial public offering, earning the firm a spot among Law360's 2023 Tax Groups of the Year.

  • January 24, 2024

    EU States Back Start Of Russia Freeze Plan, Official Says

    European Union countries gave their support Wednesday for the first part of a three-step plan to use frozen and immobilized Russian state assets for the reconstruction of Ukraine, with "a few technicalities" left to be resolved, an EU official said.

Expert Analysis

  • 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.

  • 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.

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