International

  • December 10, 2024

    Treasury Finalizes Simplified Foreign Currency Rules

    The U.S. Treasury Department finalized regulations Tuesday that aim to simplify aspects of how corporations determine taxable income or loss with respect to certain affiliates that conduct business in a foreign currency.

  • December 10, 2024

    Jockey Frankie Dettori Named In HMRC Tax Avoidance Battle

    Italian jockey Frankie Dettori has been named as the individual who attempted to maintain his anonymity to keep private his legal battle with HM Revenue and Customs over a tax avoidance scheme, according to a London court judgment.

  • December 09, 2024

    US Investment Cos. Benefit In Updated Norway Tax Treaty

    Regulated U.S. investment and holding companies should be able to reap Norwegian tax treaty benefits on dividends, royalties and capital gains without restriction under an updated agreement announced Monday by the Internal Revenue Service.

  • December 09, 2024

    Microsoft Wrong On Foreign Earnings, Ore. Tells Tax Court

    The Oregon Tax Court was correct to reject alternatives pitched by Microsoft for treatment of its repatriated foreign earnings when calculating Oregon taxable income, the state tax department told the court.

  • December 09, 2024

    UN Tax Pact Should Include Climate Focus, Report Says

    Coming negotiations for a global tax convention at the United Nations should include discussions about designing tax policies that could generate resources to help address climate change, according to a report published Monday by the advocacy group Tax Justice Network.

  • December 09, 2024

    Woman Appeals Tax Court's Canadian Debt Ruling To 9th Circ.

    A woman appealed to the Ninth Circuit a U.S. Tax Court decision that prevented her from challenging a federal tax lien issued by the Internal Revenue Service to secure her $200,000 tax debt to Canada on behalf of the Canadian government. 

  • December 09, 2024

    16 EU Members Call For Revamped Tobacco Taxation

    The European Commission needs to prioritize an overhaul of the bloc's tobacco taxation rules in the upcoming term, a group of 16 member countries said Monday, arguing that major changes in the industry since the rules last updated have left countries to fend for themselves, fragmenting the tax regime.

  • December 09, 2024

    Man Owed $264K Under US-Canada Tax Treaty, Court Says

    A U.S. man living abroad is allowed under the U.S.-Canada tax treaty to claim a foreign tax credit for nearly $264,000 in payments of the Affordable Care Act's net investment income tax, the Federal Claims Court said.

  • December 09, 2024

    Latin America Should Improve Tax Collection, OECD Says

    Latin American and Caribbean countries' average tax-to-gross-domestic-product ratio falls well below the Organization for Economic Cooperation and Development average, and improvements will be key to the area's ability to meet sustainable development goals, the OECD said Monday.

  • December 09, 2024

    UAE Implementing Global Minimum Tax In 2025

    Large multinational businesses in the United Arab Emirates making at least €750 million ($792 million) annually will be subject to the OECD's 15% corporate global minimum tax starting in 2025, the country's Finance Ministry said Monday.

  • December 09, 2024

    Proposed Canadian Tax Holiday Will Cost $1B, Office Says

    Canada's proposed two-month goods-and-services tax holiday on certain goods would result in the loss of at least CA$1.46 billion ($1 billion) in federal tax revenues, a Canadian budget watchdog said Monday.

  • December 09, 2024

    Germany Floats Plans To Adopt Additional Min. Tax Guidance

    Germany's Federal Ministry of Finance is seeking feedback on additional proposed updates to its legislation under an international minimum tax agreement known as Pillar Two, including incorporating global guidance on how to approach deferred taxes.

  • December 09, 2024

    Insurer Launches Estate Planning Cover After Tax Changes

    Royal London said on Monday that it has launched an insurance product designed to help consumers with their end-of-life planning, as a growing number of estates are set to become subject to inheritance tax after recent government changes.

  • December 06, 2024

    DC Circ. Affirms Man's $1.2M 'Seriously Delinquent' Tax Debt

    A Florida man owes more than $1.2 million in federal taxes, the D.C. Circuit said Friday, affirming the Internal Revenue Service's certification of his liability under a law that allows those with a "seriously delinquent" tax debt to have their passport revoked.

  • December 06, 2024

    NZ Considering Edits To 'Internationally Unusual' Tax Regime

    New Zealand's government received feedback that its rules for taxing investments of 10% or less in foreign companies may be discouraging people who hold interests in such entities from moving to the country, and it is seeking feedback on possible solutions, its tax authority said Friday.

  • December 06, 2024

    Gov't Appeals Texas Judge's Block On Anti-Laundering Law

    The U.S. government has appealed a Texas federal judge's order that halted the rollout of new reporting requirements aimed at unmasking anonymous shell companies, setting the stage for the Fifth Circuit to weigh in on the nationwide preliminary injunction.

  • December 06, 2024

    Simpson Thacher Adds Tax Pro From Ropes & Gray

    Simpson Thacher & Bartlett LLP announced the firm has added a tax professional from Ropes & Gray LLP as a partner in its Washington, D.C., office.

  • December 06, 2024

    Authorities Investigating Possible €200M German VAT Fraud

    The European Public Prosecutor's Office carried out searches at a Munich bank as part of an investigation into a man who created a fictitious business to process more than €200 million ($211 million) in funds generated from a value-added tax fraud scheme, the EPPO said Friday.

  • December 06, 2024

    Canada's Chinese Import Surtaxes Expected To Raise $334M

    Canada's new surtaxes on Chinese electric vehicles and steel and aluminum products are estimated to generate CA$473 million ($334 million) over the next five years, though the EV surtax on its own is likely to cause a dip in revenue, a government analysis said.

  • December 06, 2024

    Taxation With Representation: Skadden, Gibson Dunn

    In this week's Taxation With Representation, BlackRock buys HPS Investment Partners, TreeHouse Foods Inc. buys Harris Tea, Aya Healthcare acquires Cross Country Healthcare, and Bruin Capital launches a soccer representation business.

  • December 05, 2024

    11th Circ. Won't Rethink $100M Credit For John Hancock

    The Eleventh Circuit won't reconsider its decision to let John Hancock Life Insurance Co. keep $100 million in foreign tax credits, leaving in place its October ruling against a Florida law firm retirement plan's trustees.

  • December 05, 2024

    OECD Suggests Tax Shifts To Address Greece's Debt

    Greece has a lot of work to do to reduce its nearly 164% public-debt-to-gross domestic product ratio, and one avenue to generate the kind of budget surplus needed is through a suite of tax changes, the Organization for Economic Cooperation and Development said Thursday.

  • December 05, 2024

    OECD Removes Application Deadline For Int'l Pricing Program

    The Organization for Economic Cooperation and Development said Thursday it has removed biannual deadlines for large multinational entities to apply for the International Compliance Assurance Program, a multilateral effort to resolve transfer pricing issues.

  • December 05, 2024

    Australia Mulling More Country-By-Country Reporting Advice

    While the Australian Taxation Office is already working on guidance for the country's newly adopted public country-by-country reporting rules, it is looking for input on what other areas of the provision businesses may need assistance in interpreting.

  • December 05, 2024

    Authorities Say €38M Greece VAT Fraud Tied To Larger Ring

    Authorities in Greece carried out searches in Athens as part of an investigation into a scheme estimated to have caused €38 million ($40 million) in value-added tax losses, which the European Public Prosecutor's Office said Thursday had connections to a larger €2.2 billion scheme.

Expert Analysis

  • Company Considerations For Cash Award Incentives: Part 2

    Excerpt from Practical Guidance
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    Cash awards can help companies address some issues associated with equity awards to compensate employees, but due to potential downsides, they should be treated as a tool in a long-term incentive program rather than a panacea, say Denise Glagau and Kela Shang at Baker McKenzie.

  • Company Considerations For Cash Award Incentives: Part 1

    Excerpt from Practical Guidance
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    Denise Glagau and Kela Shang at Baker McKenzie discuss what companies must consider when offering cash awards outside of U.S. jurisdictions, and explain how some challenges associated with equity awards may be addressed with cash awards.

  • What AML Bill Could Mean For Firms, Funds And FinCEN

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    If passed, an amendment within Congress’ annual defense bill would expand the list of institutions subject to anti-money laundering regulations, from law firms to investment funds, creating potential rulemaking and enforcement challenges for the Financial Crimes Enforcement Network, say attorneys at Arnold & Porter.

  • Unpacking The New Stock Buyback Tax And Its Exceptions

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    Xenia Garofalo and Kyle Colonna at Eversheds Sutherland discuss provisions of the recently enacted tax on corporate stock repurchases, how its exceptions may be applied and what companies should consider when evaluating the cost of new or existing programs.

  • Inside The OECD Transfer Pricing Documentation Guidance

    Excerpt from Practical Guidance
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    The Organization for Economic Cooperation and Development's recently modified documentation guidelines can assist tax administrations in developing requirements for transfer pricing risk assessments and evaluations, and help multinational entity taxpayers demonstrate satisfaction of the arm's-length principle, says Neil Aragones at Lexis Tax.

  • A Close Look At The Decentralized Effort To Tax Digital Assets

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    Clarity on taxation is one of the biggest hurdles to mass adoption of cryptocurrency, and although digital asset innovation has consistently outpaced worldwide government regulation, recent efforts in the U.S. and elsewhere hint at an emerging standard, says Joshua Smeltzer at Gray Reed.

  • Key Takeaways From IRS Reversal On FDII Stance

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    The Internal Revenue Service's recent memo regarding allocation of deferred compensation expenses for purposes of foreign-derived intangible income is a departure from the agency's previous position and may have implications beyond the context of deferred compensation, say attorneys at Miller & Chevalier.

  • New Tax Decree Suggests Expansion In Dutch Transfer Pricing

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    A July 1 decree from Dutch tax authorities updating transfer pricing guidance heralds a major change in how intercompany financial transactions are considered for transfer pricing purposes and forebodes significant audit activity, say Monique van Herksen and Clive Jie-A-Joen at Simmons and Simmons.

  • 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.

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