International

  • May 10, 2024

    Australia Looks To Tweak Tax Exemption For US Entertainers

    Australia wants public comments on a proposal that would simplify the elimination of withholding taxes for U.S. entertainers who make $10,000 or less — or the Australian equivalent — in the country in a given year, the Australian Taxation Office said.

  • May 10, 2024

    Calif. OTA In Untested Area On Ruling That Biz Wants Binding

    A decision by California's Office of Tax Appeals that Microsoft can include 100% of the dividends from foreign affiliates in its California sales factor denominator pleased businesses, who now want the OTA to designate the opinion as precedential, thus binding on it and the state Franchise Tax Board.

  • May 10, 2024

    Osborne Clarke Lawyer To Face Tribunal Over Zahawi SLAPP

    An Osborne Clarke LLP partner who represented Nadhim Zahawi could face a disciplinary tribunal over allegations that he used intimidatory warnings in an attempt to silence a critic who was probing the former Conservative chancellor's tax affairs.

  • May 09, 2024

    Mich. Doctor Ordered To Stay In Jail Until Assets Repatriated

    A Michigan doctor fighting accusations that he failed to report his foreign bank accounts will stay in jail, as a federal court declined to release him Thursday when he didn't comply with an order to deposit over $1 million to cover the judgment against him.

  • May 09, 2024

    Pop Star Shakira's €6.6M Spanish Tax Fraud Case Dropped

    A Spanish court dropped a case alleging that Colombian pop superstar Shakira had willfully defrauded the country of €6.6 million ($7.1 million) worth of taxes in 2018, multiple news outlets reported Thursday.

  • May 09, 2024

    Pension Plans Want Witness Stopped In $2B Danish Dispute

    U.S. pension plans accused by Denmark's tax authority of committing $2.1 billion in fraud against the European country by taking illegal refunds on dividends asked a New York federal court to reject the authority's request to depose a witness who pled guilty in Denmark.

  • May 09, 2024

    Voluntary Carbon Credit Trades Will Trigger UK VAT

    Transactions involving voluntary carbon credits in the U.K. will be assessed value-added tax starting in September, HM Revenue & Customs said Thursday.

  • May 09, 2024

    IRS Turning to Final PFIC Rules This Year, Official Says

    The Internal Revenue Service expects to "begin in earnest" this year on final regulations for partnerships that hold stock in passive foreign investment companies, including guidance that would treat partnerships as an aggregate of their partners, an agency official said Thursday.

  • May 09, 2024

    Country Adjustment Would Undermine Common EU Tax Base

    Allowing countries within the European Union to adjust companies' allocated tax base under proposed rules would undermine the rules' goal of streamlining the corporate tax base, according to business groups. 

  • May 08, 2024

    DOJ Says Man Owes $6.2M After Failing To Report Foreign Biz

    A man owes tax penalties of $6.2 million to the U.S. after failing to disclose his ownership interests in two foreign entities from 1997 to 2004, the government told a California federal court Wednesday.

  • May 08, 2024

    Biz Groups Tell 10th Circ. Economic Substance Doesn't Apply

    The economic substance doctrine doesn't apply when a business considers tax in making a choice between two legally permissible alternatives, two organizations told the Tenth Circuit in their briefs supporting Liberty Global's position in its $109 million tax refund bid.

  • May 08, 2024

    4th Circ. Asks If High Court Ruling Bars Credit Suisse Tipster

    A Fourth Circuit panel questioned Wednesday whether a U.S. Supreme Court ruling prevented it from reviving a whistleblower case by a former Credit Suisse employee alleging the bank helped U.S. citizens evade taxes after paying a $2.6 billion criminal penalty.

  • May 08, 2024

    Auto Cos. Brace For EV Battery Compliance Hurdles

    New federal regulations aimed at shoring up the domestic electric vehicle manufacturing supply chain give automakers a much-needed two-year cushion to navigate a compliance minefield, and to figure out how to reinvigorate the recent waning consumer demand for electric vehicles.

  • May 08, 2024

    Africa Should Solve Own Tax Problems, Nigerian Official Says

    The solutions to Africa's taxation challenges should come from those actually on the continent, not the Western world, the chairman of Nigeria's tax authority said at an African Tax Administration Forum meeting, the authority said Wednesday.

  • May 08, 2024

    EGC Won't Annul EU Decision To Toss Spanish Tax Scheme

    The European General Court will not annul a European Commission decision that a Spanish tax scheme for vessels built in its domestic shipyards must be abandoned because it was incompatible with the European Union's internal market, according to a judgment released Wednesday.

  • May 08, 2024

    Ambulance Co.'s Former Owner Gets 6 Years For Tax Evasion

    The former owner of an ambulance company was sentenced to more than six years in federal prison for failing to pay employment taxes to the federal government and obstructing the Internal Revenue Service as it tried to collect, according to Virginia federal court documents.

  • May 08, 2024

    A Foley Hoag Co-Chair Joins Litigation Firm As Name Partner

    Litigation and dispute resolution firm Elliott Kwok Levine & Jaroslaw LLP will operate under a new name after welcoming as its newest name partner a former federal prosecutor who most recently co-chaired Foley Hoag LLP's white-collar crime and government investigations practice.

  • May 08, 2024

    UN To Publish Draft Terms Of Reference For Tax Pact In June

    National governments agreed Wednesday to publish the first draft of terms of reference for the United Nations Framework Convention on International Tax Cooperation for a two-week consultation during the week beginning June 3.

  • May 08, 2024

    EU Races To Deals On Withholding Tax, Digital VAT

    European Union countries are trying to clear the final hurdles for deals on May 14 regarding a withholding tax refund law and a package to modernize value-added tax reporting, although some potential vetoes remain after a preparatory meeting, EU sources said Wednesday.

  • May 08, 2024

    Offshore Drilling Co. Demands $70M Refund From IRS

    The IRS wrongfully withheld $69.7 million in tax refunds to an offshore drilling company, despite acknowledging that the refunds are justified by net operating loss carrybacks authorized by a pandemic law and then promising to pay, the company said in Texas federal court.

  • May 08, 2024

    EU Agrees To Send Russian Assets' Revenue To Ukraine

    European Union countries reached a deal Wednesday to transfer the net income from frozen and immobilized Russian state assets to EU funds for rebuilding Ukraine and buying arms for the country, an EU commissioner said.

  • May 08, 2024

    EU Discusses Monitoring Measures Against Tax Havens

    The European Union is considering an annual monitoring process over defensive measures against tax havens in force in the 27 bloc countries, an EU official said Wednesday.

  • May 08, 2024

    Slow Tax Decisions By EU States Are Harmful, Lawmaker Says

    The slow pace of European Union countries in reaching decisions on tax issues harms the bloc's economy, a conservative member of the European Parliament said in a document sent to journalists Wednesday.

  • May 08, 2024

    EU Calls For Responses On Information Exchange Law

    The European Union's executive branch is seeking responses on the law that governs the exchange of information between tax authorities in the group of 27 nations, as a senior EU tax official said it was time to "assess the need for fine tuning."

  • May 07, 2024

    Biz Orgs. Ask 10th Circ. To Toss Economic Substance Ruling

    The Tenth Circuit must not uphold a Colorado federal court's ruling that it didn't need to determine whether economic substance doctrine was relevant before disallowing an intercompany transaction by Liberty Global Inc., three business groups told the Tenth Circuit in briefs Tuesday.

Expert Analysis

  • How The OECD Global Tax Proposal Could Affect M&A

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    Following agreement on the Organization for Economic Cooperation and Development’s Pillar Two proposal to introduce a global minimum tax, domestic implementation is expected to have a significant impact on international M&A transactions, with financial modeling, deal structuring, risk allocation and joint venture arrangements likely to be affected, say lawyers at Freshfields.

  • UK Shares-Tax Proposals Offer Long-Awaited Modernization

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    The U.K. government's recent consultation on the introduction of a new tax on transactions in securities raises detailed legal and practical issues, but the prospect of a single digital stamp tax offering both streamlined legislation and administration will be welcomed, say Zoë Arnautov and Mark Sheiham at Simmons & Simmons.

  • IRS Foreign Tax Credit Pause Is Welcome Course Correction

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    A recent IRS notice temporarily suspending application of 2022 foreign tax credit regulations provides wanted relief for the many U.S. multinational companies and other taxpayers that otherwise face the risk of significant double taxation in their international operations, say attorneys at Mayer Brown.

  • IRS Criminal Probe Spells Uncertainty For Malta Pension Plans

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    The IRS’ recent scrutiny of Malta pension plan arrangements — and its unusual issuance of criminal administrative summonses — confirms that it views many of these plans as illegal tax evasion schemes, and the road ahead will not be smooth and steady for anyone involved, say attorneys at Kostelanetz.

  • IRS Announcement Will Aid Cos. In Buyback Tax Planning

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    Recent IRS transitional guidance regarding current requirements for reporting and payment of the stock repurchase excise tax will help corporate taxpayers make decisions about records retention and establishing reserves for future tax payments, say Xenia Garofalo and Kyle Colonna at Eversheds Sutherland.

  • Flawed Analysis Supports Common Law Tax Deficiency Ruling

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    The Colorado federal district court’s recent decision in Liberty Global, holding that the U.S. Department of Justice may assert a common law tax claim without the notice of tax deficiency required by the Internal Revenue Code, relies on a contorted reading of the statute and irrelevant case law, say Loren Opper and Christie Galinski at Miller Canfield.

  • Review Of Repatriation Tax Sets Justices On Slippery Slope

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    The U.S. Supreme Court’s recent decision to review the constitutionality of the repatriation tax in Moore v. U.S. has implications for many tax rules involving unrealized amounts and could leave the court on the brink of invalidating large swaths of the Internal Revenue Code, say attorneys at Eversheds Sutherland.

  • What To Make Of IRS' New Advance Pricing Guidance

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    Recent guidance on the IRS' goals for its advance pricing agreement system provides helpful insight into review and decision-making procedures for advance pricing agreement requests, but it also raises questions about the IRS' objectives, say Richard Slowinski and Stefanie Kavanagh at Alston & Bird.

  • Reserved Investor Fund Would Plug Gap In UK Finance Market

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    The reserved investor fund recently proposed by HM Treasury has the potential to be a welcome tax-efficient addition to the U.K.’s canon of products for real estate investments, with attractive features for companies and, in particular, large asset managers, say lawyers at Herbert Smith.

  • 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.

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