International
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May 16, 2024
EU Tax On Excess Corp Profits Could Yield €107B, Study Says
A European Union tax on excessive corporate profits could yield about €107 billion ($116 billion) to partly finance the common EU budget or other urgent investments, leftists in the European Parliament said Thursday.
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May 16, 2024
Treasury Provides Extra Relief For Bonus Energy Tax Credits
The U.S. Treasury Department provided additional safe harbors Thursday that clean energy project developers can use to qualify for bonus tax credits for domestically sourcing their steel and aluminum parts in response to the Biden administration's new trade restrictions on solar products from China.
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May 16, 2024
Lithuania PM Wants Frozen Russian Assets To Help Ukraine
Lithuania's prime minister said Thursday that Russia's frozen assets should be used to help Ukraine fight off aggression from its larger neighbor, saying that a recent European decision to use profits from frozen assets should be only a first step.
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May 15, 2024
Russian Gas Ex-CFO Can't Nix $44M FBAR Suit, Judge Rules
The former chief financial officer of a Russian gas company who was sentenced to seven years in prison for hiding money in Swiss banks can't escape the government's civil suit seeking nearly $44 million in reporting penalties, a Florida federal judge ruled Wednesday.
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May 15, 2024
EU Court Upholds Ruling Against Spanish Ship Tax Scheme
The European Union's General Court upheld Wednesday a European Commission ruling that a Spanish tax scheme for ships constructed in the nation's domestic shipyards was incompatible with the EU's internal market.
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May 15, 2024
Schulte Roth Adds Ex-Kleinberg Kaplan Partner To Tax Group
Schulte Roth & Zabel LLP added a former Kleinberg Kaplan Wolff & Cohen PC partner with a focus on private investment funds to its tax group in New York.
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May 15, 2024
3 Key Takeaways From Floated Foreign Trust Reporting Rules
Proposed rules for reporting transactions with foreign trusts recently issued by the U.S. Treasury Department provide breathing room on disclosure requirements for certain offshore retirement accounts, but leave open some questions about classification. Here, Law360 breaks down three sections of the proposed foreign trust reporting regulations.
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May 15, 2024
South African Tax Official Says Data Swaps Too Limited
South Africa's requests to exchange information on taxpayers with authorities around the world are often denied for criminal investigations of tax crimes, while automatic exchanges sometimes lack the full identifying information of taxpayers, the commissioner of the country's tax agency said Wednesday.
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May 15, 2024
Taxpayers Let Down By HMRC Digital Service, Says Watchdog
HM Revenue and Customs has let down taxpayers by failing to deliver better online services, according to a report published on Wednesday by the public spending watchdog.
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May 15, 2024
Swiss Seek Feedback On Crypto Information Exchange
Switzerland's executive body, the Federal Council, is seeking feedback from the public on its plan to adopt two Organization for Economic Cooperation and Development standards that will update the country's automatic exchanges of information to account for crypto-assets, it said Wednesday.
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May 15, 2024
11 Arrested In €25M Italian VAT Fraud Case
Italian police arrested 11 suspects in a value-added tax fraud ring involving electronic products that resulted in losses of over €25 million ($27.2 million), the European Public Prosecutor's Office said Wednesday.
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May 15, 2024
Gentiloni Warns EU States Not To Be Too Harsh With Budgets
European Union tax commissioner Paolo Gentiloni warned EU countries Wednesday not to be too aggressive with budget cuts, even as some may have to take a more restrictive fiscal stance this year and next than had been planned.
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May 15, 2024
German Finance Minister Wants Lower Tax Burden
Germany's finance minister said he would like to see the tax burden lowered as part of a broader push to make life less burdensome for industry as the country tries to stimulate economic growth.
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May 15, 2024
EU Finance Ministers Plan Road To Tax Revamp
European Union finance ministers agreed on a work program to implement about 40 measures to improve business financing, including a targeted makeover of tax systems in member countries covering corporate taxes, capital gains and tax breaks for interest payments.
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May 14, 2024
A Fifth Of Big Cos. Use Tax Transparency Standard, Org. Says
About a fifth of the largest 1,000 public companies worldwide have voluntarily used a public country-by-country reporting standard created by an international independent standards organization, the nonprofit said Tuesday.
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May 14, 2024
Law Prof Comes To Treasury's Aid In 3M Transfer Pricing Fight
The U.S. Department of the Treasury did not act arbitrarily when it wrote transfer pricing regulations that allowed the government to disregard foreign legal restrictions on royalty payments when allocating income to 3M from an affiliate, a law professor told the Eighth Circuit on Tuesday.
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May 14, 2024
Solarium Sunbaths Not Tax-Free Wellness, Sweden Says
After receiving multiple questions about whether paying to sunbathe in a solarium is eligible for Sweden's tax-free wellness allowance, the country's tax agency said Tuesday that such activity is not eligible.
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May 14, 2024
Microsemi Calls IRS' Penalty Approval 'Woefully Inadequate'
An Internal Revenue Service supervisor's sign-off on a transfer pricing penalty for Microsemi was "woefully inadequate" to meet statutory requirements for penalty approval, the semiconductor manufacturer told the U.S. Tax Court.
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May 14, 2024
Aussie Budget Proposes Green Credits, Capital Gains Change
Australia would offer tax credits for hydrogen production and critical mineral mining and update its foreign resident capital gains tax rules as part of a proposed 2024-25 budget released Tuesday.
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May 14, 2024
British Industry Group Calls For Green Energy Tax Breaks
The U.K. needs to "outsmart rather than outspend" other countries to grow in the green energy sector, a British business advocacy group said, calling for the government to create a 40% so-called green innovation tax credit, among other tax breaks.
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May 14, 2024
Ex-Whiteford Taylor Business Co-Chair Joins Baker Donelson
Baker Donelson Bearman Caldwell & Berkowitz PC has welcomed a new shareholder who spent more than a decade with the Internal Revenue Service and previously co-chaired Whiteford Taylor & Preston LLP's business department, the firm announced on Monday.
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May 14, 2024
EU Finance Ministers Strike Deal On Withholding Tax Refunds
European Union finance ministers agreed Tuesday to a withholding tax refund law, as previous holdouts Poland and the Czech Republic withdrew their objections.
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May 14, 2024
EU Chair To Fight On For VAT Deal After Estonia's Rejection
The chair of the European Union's council of finance ministers said he will fight to get unanimous support for a wide-ranging reform of value-added tax rules after Estonia blocked agreement to the law Tuesday.
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May 14, 2024
Aussie Senate Faces Separation Of Promoter Penalty, Gas Tax
The Australian government is poised to double the penalty for corporate promoters of tax avoidance schemes, but it may first have to compromise by separating its bill from another one dealing with a tax on offshore gas exports, according to a legislative report.
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May 13, 2024
Corp. Transparency Act An Overbroad Dragnet, 11th Circ. Told
Congress exceeded its authority in passing the Corporate Transparency Act, which prompted the U.S. Treasury Department to solicit personal information for law enforcement purposes from those that registered and owned state-registered entities, a small-business group told the Eleventh Circuit on Monday.
Expert Analysis
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Ideas For Closing BigLaw's Diversity Gap
If enough law firms undertake some universal diversity best practices, such as connecting minority lawyers to key client relationships and establishing accountability for those charged with spearheading progress, the legal industry could look a lot different in the foreseeable future, says Frederick Nance, global managing partner at Squire Patton.
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How Law Firms Can Hire And Retain More Black Attorneys
The pipeline of Black lawyers is limited, so BigLaw firms must invest in Black high school students, ensure Black attorneys receive origination credit and take other bold steps to increase Black representation in the industry, says Benjamin Wilson, chairman at Beveridge & Diamond.
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BigLaw Needs More Underrepresented Attorneys As Leaders
Hiring more women, people of color and members of the LGBTQ community to BigLaw positions of power is the first key to making other underrepresented attorneys believe they have an opportunity for a path to leadership, says Ernest Greer, co-president at Greenberg Traurig.
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Advancing Racial Justice In The Legal Industry And Beyond
In addition to building and nurturing a diverse talent pipeline, law firms should collaborate with general counsel, academics and others to focus on injustices within the broader legal system, says Jonathan Harmon, chairman at McGuireWoods.
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Diversity Work Doesn't Have To Be Reserved For Partners
Serving on my firm's diversity committee as an associate has allowed me to improve access, support and opportunity for minority attorneys at the firm, while building leadership skills and fostering meaningful relationships with firm management and industry professionals, says Camille Bent at BakerHostetler.
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Foreign Income Regs Provide Some Clarity But Issues Remain
The U.S. Department of the Treasury recently released final regulations on global intangible low-taxed income and foreign-derived intangible income that largely addressed the numerous technical issues plaguing these sections but left the high GILTI rate and other substantive problems unresolved, says Robert Kiggins at Culhane Meadows.
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New Unified High-Tax Election Brings Planning Challenges
The U.S. Department of the Treasury's recently released high-tax election regulations for global intangible low-taxed income create unwanted planning challenges by conforming to the stricter Internal Revenue Code Subpart F high-tax exclusion, rather than aligning with the GILTI election rules as many hoped, say attorneys at Mayer Brown.
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EU's Tax-Centered State Aid Campaign May Have Peaked
The European Commission's recent tax-related state aid investigations of the likes of Apple, McDonald's and Nike may have reached their limit as changes in international tax rules, the rapid growth of digital companies and COVID-19 reprioritize the commission's anti-competitive initiatives to broader issues focused on tech giants, says Joyce Beebe at Rice University.
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Get Ready For IRS Repatriation Enforcement
Beginning this fall, taxpayers should expect to see IRS enforcement efforts with respect to their repatriation tax liabilities, including audits that will likely focus on taxpayers' earnings and profits calculations, classification of assets as cash versus noncash, and how taxpayers determined foreign tax credits, say David Fischer and Teresa Abney at Crowell & Moring.
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Canadian Tax Ruling Boosts Cross-Border Deal Confidence
The Queen v. Cameco Corp., a recent Canadian appellate decision and the first case to test Canada's transfer pricing recharacterization rules, has significant implications for cross-border intragroup transactions and the intersection of Canadian tax law with the Organization for Economic Cooperation and Development’s guidance, says Matt Billings at Duff & Phelps.
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HSBC Suit Shows Challenge Of Designing Tax Relief Laws
Investors' recent lawsuit against HSBC over film-related tax avoidance schemes spotlights the difficult balancing act of crafting practical tax relief legislation while safeguarding against abuse, says Andrew Parkes at Andersen Tax.
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Regulatory Concerns For US Cos.' Offshore Service Centers
As more U.S. companies open and use offshore service-delivery centers amid the pandemic, assessment of important tax, intellectual property, cybersecurity and employment considerations can help mitigate regulatory risk and maximize the company's return on investment, says Sonia Baldia at Baker McKenzie.
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5 Biz Tax Reforms To Aid Long-Term Pandemic Recovery
As Congress negotiates another COVID-19 relief package, it should consider business tax measures that provide liquidity and encourage economic recovery by focusing budgetary resources on activities and circumstances connected to the pandemic and associated economic slowdown, says George Callas at Steptoe & Johnson.