International

  • June 17, 2024

    OECD Clarifies Rules For Global Minimum Tax

    The OECD-led international negotiating body working on fundamental changes to corporate tax law clarified rules under the global minimum tax on deferred tax and securitization, the organization said Monday.

  • June 17, 2024

    EU Approves Italian Fee Cut For Boats Using Cleaner Energy

    The European Commission approved an Italian plan Monday which, by waiving a fee, incentivizes boats to use a cleaner way of obtaining electricity.

  • June 14, 2024

    US Urges 5th Circ. To Back $2M Tax Bill For Tire Imports

    The Fifth Circuit should overturn a lower court's ruling that a Houston truck company was not an importer responsible for nearly $2 million in excise taxes on tires it bought from a Chinese manufacturer, the U.S. told the Fifth Circuit on Friday.

  • June 14, 2024

    Eaton Says Court Improperly Required Int'l Employee Evals

    An Ohio federal court should reconsider its decision that multinational power management company Eaton must disclose the personnel records of its foreign employees that were requested by the Internal Revenue Service in a transfer pricing investigation, the company told the court.

  • June 14, 2024

    Mining Co. Entity Can't Deduct Loan Interest, UK Court Says

    A U.S. mining company's entity in the U.K. that was created to save taxes through the acquisition of a Texas-based firm cannot overturn the Upper Tribunal's decision that its U.K tax deductions weren't deserved, according to a Court of Appeal judgment.

  • June 14, 2024

    G7 Chiefs Agree On Using Frozen Russian Profits For Ukraine

    Leaders from the Group of Seven countries reached a provisional agreement to use windfall profits from frozen and immobilized Russian state assets to back a $50 billion loan to Ukraine, they announced Friday, although details have to be ironed out before the end ot the year, said Italy's prime minister, Giorgia Meloni.

  • June 14, 2024

    Swiss Council OKs Tax Agreements With Angola, Germany

    Switzerland's executive body, the Federal Council, approved a double taxation agreement with Angola and an amendment to an existing agreement with Germany, it announced Friday.

  • June 14, 2024

    Taxation With Representation: Kirkland, Arnold & Porter

    In this week's Taxation with Representation, Noble Corp. PLC buys Diamond Offshore Drilling Inc., Cognizant buys Belcan, AlphaSense raises funding to buy Tegus, and Matador Resources Co. acquires a subsidiary of the EnCap Investments portfolio company Ameredev II Parent.

  • June 14, 2024

    ABA Tax Section Calls For Revision To Stock Buyback Regs

    The U.S. Department of the Treasury and the IRS should narrow a rule in proposed regulations on the stock buyback tax regarding U.S. subsidiaries funding repurchases of their foreign parents' stock, the American Bar Association's Tax Section said in a letter released Friday.

  • June 14, 2024

    Full DC Circ. Won't Hear Foreign Disclosure Penalty Dispute

    The D.C. Circuit declined to reconsider its ruling overturning a major U.S. Tax Court decision that had crimped the administrative collection arm of the Internal Revenue Service, letting stand a panel's restoration of the agency's power to more freely penalize undisclosed foreign corporations.

  • June 14, 2024

    UK Broker Denied Supreme Court Hearing Over Cum Ex Raids

    Judges at a London court refused on Friday to allow a brokerage to challenge at the U.K. Supreme Court findings that a raid on its London office during an investigation into tax fraud in 2022 was legal, finding that the "outcome of any appeal would be no different."

  • June 14, 2024

    EU Transfer Pricing Law To Involve Basic Rights, Prof Says

    A proposed European Union law on transfer pricing would, if adopted, mean the EU's charter of fundamental rights became relevant to transfer pricing disputes, a tax professor said Friday.

  • June 13, 2024

    Canada Should Look Beyond Capital Gains Tax Hike, IMF Says

    Though Canada's proposed capital gains tax increase would be another positive development for a country that has largely fared well in its pandemic rebound, the country should consider more avenues to raise revenue, the International Monetary Fund said.

  • June 13, 2024

    Denmark Considering $302M Entrepreneur Tax Break Package

    Denmark's finance ministry announced a package of more than 2.1 billion kroner ($302 million) in tax breaks and other measures for entrepreneurs that it says will help drive innovation and overall grow the country's attractiveness for startups.

  • June 13, 2024

    Labour Manifesto Targets Wealthy To Fill Funding Gaps

    Labour set out plans in its election manifesto on Thursday to raise a total of more than £8.5 billion ($10.8 billion) in tax reforms that target wealthy taxpayers, although some analysts questioned whether the measures will add up.

  • June 13, 2024

    EU Eyeing Exchange Rules Linked To Min. Tax, Official Says

    The European Union is looking to introduce rules regarding the exchange of information pertaining to the global minimum corporate tax, a top official in the EU's executive branch said Thursday.

  • June 13, 2024

    Swiss Finance Minister Defends Tax Competition

    Switzerland's finance minister defended tax competition, saying citizens' right to move to lower-tax jurisdictions helps keep public authorities from taxing and spending to excess.

  • June 13, 2024

    EU Scales Back Talks On Proposed Law To Combat Shell Cos.

    European Union countries have broadly agreed to work on a scaled-back legislative proposal to combat shell companies that would give each country more freedom to decide what anti-abuse action to take, an EU official said.

  • June 12, 2024

    Senate Budget Chair Seeks End To Carried Interest Tax Break

    Lawmakers should end the favorable tax treatment of income from carried interest compared with ordinary earned income, Senate Budget Committee Chairman Sheldon Whitehouse said Wednesday.

  • June 12, 2024

    Digital Taxes May Take Hold Regardless Of Treaty Signing

    An internationally agreed-upon freeze on digital levies may continue to thaw even if countries meet their impending deadline to sign a related treaty for new corporate tax rules, in part because the accord faces a hazy path to formal ratification.

  • June 12, 2024

    Feds Strike Deal Ending $7M FBAR Penalty Cases

    The U.S. government agreed to settle a pair of foreign bank account reporting cases in which it had sought a total of $7 million from a former insurance broker and his wife's estate, according to a court order filed Wednesday in California federal court.

  • June 12, 2024

    Groups Push Back On Stock Buyback Tax Test's Scope

    The U.S. Treasury Department's proposed stock buyback tax rules go too far in trying to assess whether the main purpose of a U.S. subsidiary's funding purchase of its foreign parent's stock is to avoid the tax, two groups said in comments released Wednesday.

  • June 12, 2024

    Aussie Senate's Final PwC Report Focuses On Integrity Recs

    Australia's Senate released its final report Wednesday regarding PwC's marketing of confidential draft tax laws to clients, pushing for both consulting firms and the government to assure that the firms, particularly the Big Four, act with integrity.

  • June 12, 2024

    Treasury Issued Over $1B In Clean Vehicle Tax Credits

    The clean vehicle tax credit of up to $7,500 has saved buyers more than $1 billion in total upfront costs since January, the U.S. Treasury Department announced Wednesday, saying the figures represent a major milestone in lowering transportation costs since the incentive was updated in 2022.

  • June 12, 2024

    Italy Investigating €13M VAT Fraud Involving Chinese Fabric

    An Italian judge issued a freezing order against four people and a company as investigations continue into a scheme involving the illegal importation of Chinese fabric that caused over €13 million ($14.1 million) in value-added tax losses, the European Public Prosecutor's Office said Wednesday.

Expert Analysis

  • Exploring An Alternative Model Of Litigation Finance

    Author Photo

    A new model of litigation finance, most aptly described as insurance-backed litigation funding, differs from traditional funding in two key ways, and the process of securing it involves three primary steps, say Bob Koneck, Christopher Le Neve Foster and Richard Butters at Atlantic Global Risk LLC.

  • A Vision For Economic Clerkships In The Legal System

    Author Photo

    As courts handle increasingly complex damages analyses involving vast amounts of data, an economic clerkship program — integrating early-career economists into the judicial system — could improve legal outcomes and provide essential training to clerks, say Mona Birjandi at Data for Decisions and Matt Farber at Secretariat.

  • A Look At New IRS Rules For Domestically Controlled REITs

    Author Photo

    The Internal Revenue Services' finalized Treasury Regulations addressing whether real estate investment trusts qualify as domestically controlled adopt the basic structure of previous proposals, but certain new and modified rules may mitigate the regulations' impact, say attorneys at Simpson Thacher.

  • E-Discovery Quarterly: Recent Rulings On Text Message Data

    Author Photo

    Electronically stored information on cellphones, and in particular text messages, can present unique litigation challenges, and recent court decisions demonstrate that counsel must carefully balance what data should be preserved, collected, reviewed and produced, say attorneys at Sidley.

  • Don't Use The Same Template For Every Client Alert

    Author Photo

    As the old marketing adage goes, consistency is key, but law firm style guides need consistency that contemplates variety when it comes to client alert formats, allowing attorneys to tailor alerts to best fit the audience and subject matter, says Jessica Kaplan at Legally Penned.

  • Think Like A Lawyer: Follow The Iron Rule Of Trial Logic

    Author Photo

    Many diligent and eager attorneys include every good fact, point and rule in their trial narratives — spurred by the gnawing fear they’ll be second-guessed for leaving something out — but this approach ignores a fundamental principle of successful trial lawyering, says Luke Andrews at Poole Huffman.

  • The Art Of Asking: Leveraging Your Contacts For Referrals

    Author Photo

    Though attorneys may hesitate to ask for referral recommendations to generate new business, research shows that people want to help others they know, like and trust, so consider who in your network you should approach and how to make the ask, says Rebecca Hnatowski at Edwards Advisory.

  • Unpacking The Bill To Extend TCJA's Biz-Friendly Tax Breaks

    Author Photo

    Attorneys at Skadden examine how a bipartisan bill currently being considered by the U.S. Senate to save the Tax Cuts and Jobs Act's tax breaks for research and development costs, and other expiring business-friendly provisions, would affect taxpayers.

  • Deciding What Comes At The End Of WTO's Digital Tariff Ban

    Author Photo

    Companies that feel empowered by the World Trade Organization’s recent two-year extension of the ban on e-commerce tariffs should pay attention to current negotiations over what comes after the moratorium expires, as these agreements will define standards in international e-commerce for years to come, say Jan Walter, Hannes Sigurgeirsson and Kulsum Gulamhusein at Akin Gump.

  • 4 Ways To Refresh Your Law Firm's Marketing Strategy

    Author Photo

    With many BigLaw firms relying on an increasingly obsolete marketing approach that prioritizes stiff professionalism over authentic connection, adopting a few key communications strategies to better connect with today's clients and prospects can make all the difference, say Eric Pacifici and Kevin Henderson at SMB Law.

  • This Earth Day, Consider How Your Firm Can Go Greener

    Author Photo

    As Earth Day approaches, law firms and attorneys should consider adopting more sustainable practices to reduce their carbon footprint — from minimizing single-use plastics to purchasing carbon offsets for air travel — which ultimately can also reduce costs for clients, say M’Lynn Phillips and Lisa Walters at IMS Legal Strategies.

  • Cum-Ex Prosecutions Storm Shows No Sign Of Abating

    Author Photo

    The ongoing trial of Sanjay Shah in Denmark is a clear indicator that efforts remain focused on holding to account the alleged architects and beneficiaries of cum-ex trading, and with these prosecutions making their way across Europe, it is a more turbulent time now than ever, says Niall Hearty at Rahman Ravelli.

  • Practicing Law With Parkinson's Disease

    Author Photo

    This Parkinson’s Awareness Month, Adam Siegler at Greenberg Traurig discusses his experience working as a lawyer with Parkinson’s disease, sharing both lessons on how to cope with a diagnosis and advice for supporting colleagues who live with the disease.

Can't find the article you're looking for? Click here to search the Tax Authority International archive.