International

  • June 11, 2024

    Compliance Costs Outweigh Min. Tax Gains, Biz Reps Say

    Multinational businesses are concerned that the burden of complying with the 15% global minimum tax outweighs any potential revenue gains associated with the burgeoning system, tax attorneys and a trade association representative said during a panel Tuesday.

  • June 11, 2024

    House Panel Chair Seeks To End Media Org's Tax Exemption

    The House's top tax writer wants the Internal Revenue Service to revoke the tax-exempt status of a nonprofit Mideast-focused news outlet, telling Commissioner Daniel Werfel that the organization is aiding Hamas.

  • June 11, 2024

    Lawmakers Urge Biden To Back Brazil's Int'l Wealth Tax Plan

    Sen. Bernie Sanders and Democratic lawmakers asked the Biden administration Tuesday to support the global minimum tax on billionaires being proposed by Brazil, which is encouraging the Group of 20 nations to endorse the initiative at its meetings next month.

  • June 11, 2024

    Kostelanetz Partners Talk Benefits Of Atlanta Tax Firm Tie-Up

    Kostelanetz LLP partners Bryan Skarlatos and Todd Welty discuss the firm’s recent combination with Atlanta boutique Welty PC.

  • June 11, 2024

    Democratic Republic Of Congo Joins African Tax Coalition

    The Democratic Republic of the Congo has officially joined the African Tax Administration Forum as its 44th member, the group announced.

  • June 11, 2024

    Tory Tax Cut Plans Raise Questions On Funding Gaps

    The prime minister unveiled plans for £17.2 billion ($21.8 billion) in tax cuts at the launch of the Conservative Party's election manifesto on Tuesday, but a headline cut of two percentage points in the payroll tax was put off for three years — and funding plans left some experts unconvinced.

  • June 11, 2024

    French Tax Law Challenged On Free Movement Grounds

    The European Court of Justice is examining a French law regarding undeclared assets held outside the country to determine whether it is in line with the European Union's law respecting free movement of capital, the EU's official journal said.

  • June 11, 2024

    Sunak Pledges Further Tax Cuts In Election Manifesto

    Rishi Sunak said on Tuesday that his Conservative Party would establish a tax system that "rewards work" by slashing a range of levies if it wins the general election, including another cut in the national payroll tax by 2027.

  • June 10, 2024

    Canadian Gov't Proposes Capital Gains Tax Hike

    A new tax rate on capital gains realized annually above CA$250,000 ($181,700) by individuals and on all capital gains realized by Canadian corporations would go into effect this month under a proposal introduced by Canada's finance minister Monday.

  • June 10, 2024

    Big Tech Urges US Reprisal Over Canada's Impending DST

    The Office of the U.S. Trade Representative should open formal dispute proceedings with the Canadian government in response to a 3% digital services tax that is expected to soon pass in the Canadian Senate, business groups with members in the U.S. tech industry said Monday.

  • June 10, 2024

    UN Aims To Finish Drafting Tax Convention By Fall 2026

    The United Nations should aim to finish a framework convention on international tax cooperation and early protocols that address taxation of the digital economy, cross-border services and high-net-worth individuals by September 2026, according to draft terms of reference open for comment through June 21.

  • June 10, 2024

    3rd Prime Suspect Arrested In €50M Italian VAT Fraud Ring

    The Italian Financial Police arrested a third person suspected of leading a value-added tax fraud scheme involving sales of over 3 million Apple AirPods that caused an estimated €50 million ($54 million) in losses, the European Public Prosecutor's Office said Monday.

  • June 10, 2024

    Authorities Arrest Danish Suspect In €85M VAT Fraud In Kenya

    A Dane suspected of leading an €85 million ($91 million) value-added tax fraud ring was apprehended in Kenya after having fled Denmark late last year, the European Public Prosecutor's Office said Monday.

  • June 10, 2024

    Latvia Parliament Passes Parts Of Minimum Tax Directive

    Under pressure from the European Union, Latvia's Parliament approved a bill transposing portions of the bloc's directive to implement the Organization for Economic Cooperation and Development's Pillar Two standards to prevent tax base erosion and profit shifting.

  • June 10, 2024

    Singapore Seeks Opinions On OECD's Minimum Tax Plan

    Singapore is seeking public feedback on a proposal that would introduce the Organization for Economic Cooperation and Development's corporate global minimum tax, the country's Ministry of Finance said Monday.

  • June 10, 2024

    EU Commission Invites Experts To Anti-Tax-Evasion Forum

    The European Union's executive arm issued a call Monday for nongovernmental organizations to apply to join a platform that discusses measures against tax evasion and avoidance outside the bloc.

  • June 10, 2024

    EU Countries To Aim Again For VAT Deal, Agenda Says

    European Union countries will again discuss proposed changes to the bloc's value-added tax laws at a meeting next week, aiming to find a deal after one country blocked agreement, according to a meeting agenda.

  • June 10, 2024

    Lib Dems Vow To Raise Capital Gains Tax For UK's Wealthiest

    The U.K.'s third-largest political party vowed on Monday to raise taxes on the country's wealthiest individuals if it wins the next election, in a bid to raise £5 billion ($6.4 billion) for the National Health Service.

  • June 10, 2024

    What Tax Experts Hope To See In Labour's Manifesto

    Labour's policy manifesto, expected to be unveiled on Thursday, will be studied by tax lawyers for more detail on the fiscal planning being carried out by the clear favorite to win the general election, including a final word on lifetime pension savings.

  • June 07, 2024

    IRS Updates EV Battery Reporting Guide For Tax Credits

    The Internal Revenue Service provided updated guidance Friday for automakers planning to provide a report on meeting the battery sourcing requirements that can qualify their new electric vehicle models for the consumer tax credit of up to $7,500.

  • June 07, 2024

    NZ Sets Foreign Investment Interest Deemed Rate Of Return

    New Zealand has set the deemed rate of return for attributing interest on foreign investment funds — one of the ways to calculate income from such sources for tax purposes — at 8.63% for the 2023-24 income year, the country's revenue agency said.

  • June 07, 2024

    Dentons Adds Pair Of Husch Blackwell Tax Attys

    Two South Carolina tax attorneys have joined Dentons' corporate, tax and private client practice as partners after moving from Husch Blackwell LLP, the firm announced on Thursday.

  • June 07, 2024

    Halliburton Wrongly Denied $11.3M Deduction, Court Told

    The Internal Revenue Service is arbitrarily and wrongfully refusing to refund Halliburton over $11.3 million in tax deductions taken for a payment to a foreign government to secure the safety of the company's employees, Halliburton told a federal court.

  • June 07, 2024

    Chile Says Filing Restriction Program Stopped $203M In Fraud

    Chile's tax agency said Friday that its strategy for blocking value-added tax fraud via fraudulent invoices prevented the disbursement of 186 billion Chilean pesos ($203 million) of incorrect value-added tax credits since the start of 2023 through April 2024.

  • June 07, 2024

    Taxation With Representation: Vinson, Latham, Ropes & Gray

    In this Week's Taxation with Representation, Waste Management buys Stericycle, Becton Dickinson pays $4.2 billion for Edwards Lifesciences' critical care products unit, Aquiline Capital Partners raises over $3.4 billion in fund capital, and Bain Capital buys PowerSchool Holdings.

Expert Analysis

  • 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.

  • 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.

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