International
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April 24, 2024
GOP Reps Seek IRS Nonprofit Info After China Reports
House Ways and Means Republicans asked the Internal Revenue Service to provide information about how it monitors tax-exempt organizations for possible violations of their status after reports China may be funding and improperly influencing nonprofits, according to a letter sent Wednesday.
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April 24, 2024
Treasury Limits Reach Of Look-Through Rule In Final Regs
The U.S. Treasury Department finalized regulations Wednesday that retain but narrow the scope of a proposal to, in a manner of speaking, look through the corporate owners of real estate investment entities to determine whether they are domestically controlled.
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April 24, 2024
Tax Pros Suggest How HMRC Can Assess Digitalization Effort
HM Revenue & Customs should abide by a set of benchmarks when evaluating tests of its digitalization program for income tax self-assessment forms, two groups representing U.K. tax professionals said.
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April 24, 2024
Ex-England Footballer Banned As Director For Unpaid Tax
Former England football international John Barnes has been banned from being a company director after his business failed to pay more than £190,000 ($236,000) in tax, a U.K. government agency announced on Wednesday.
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April 24, 2024
Papua New Guinea Commits To Automatic Tax Info Exchange
Papua New Guinea has committed to enacting the Organization for Economic Cooperation and Development's standard for automatic exchange of financial account information in tax matters by September 2027, the OECD said Wednesday.
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April 24, 2024
EU Keeps Gibraltar, Panama, UAE On AML Blacklist
Gibraltar, Panama and the United Arab Emirates should remain on the European Union's blacklist of high-risk countries for money laundering, the European Parliament said, stopping the EU from following the lead of a global organization promoting standards for countries to fight those crimes.
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April 24, 2024
EU Expected To OK Withholding Tax, Digital VAT Laws In May
European Union finance ministers are expected to agree on a new withholding tax refund law and a package to modernize value-added tax reporting at their May 14 meeting, an EU official said Wednesday, speaking on the condition of anonymity.
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April 24, 2024
EU Says 3 States Aren't Correctly Following AML Law
The European Commission said Wednesday that three European Union countries — Ireland, France and Latvia — aren't correctly implementing the bloc's laws against money laundering, meaning that the countries now have two months to correct the shortcomings.
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April 23, 2024
Treasury Says Aussie Royalty Ruling Contradicts US, OECD
Australia's updated draft ruling regarding when payments for the rights to distribute software would be considered royalties conflicts with OECD and U.S. standards on the treatment of such deals, a U.S. Department of the Treasury official said in a letter made public Tuesday.
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April 23, 2024
Biz Ownership Law Constitutional, Lawmakers Tell 11th Circ.
The Corporate Transparency Act is a garden-variety exercise of Congress' powers to address threats to national security, foreign affairs, commerce and tax collection, five Democratic lawmakers told the Eleventh Circuit, disputing a ruling that the law is unconstitutional.
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April 23, 2024
DC Circ. Backs Tax Penalties Against Swiss Couple
A Swiss couple who incurred $500,000 in penalties for failing to report millions of dollars they held in Swiss bank accounts can't get out of paying, the D.C. Circuit ruled Tuesday, rejecting their argument that the IRS didn't properly approve the fines.
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April 23, 2024
Int'l Pricing Pact Guidance Is Coming Soon, IRS Official Says
Updated Internal Revenue Service guidance that would help multinational corporations pursue advance pricing agreements will likely be released in a few months, an agency official said Tuesday.
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April 23, 2024
Disney, IBM Stuck With Tax On Royalties, NY Top Court Holds
New York's highest court rejected Disney and IBM's arguments that the state unconstitutionally denied their attempts to take tax deductions on royalties received from foreign affiliates, holding Tuesday that the law at issue didn't discriminate against interstate commerce.
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April 23, 2024
EV Levy Could Blunt Swiss Climate Plan Pains, Report Says
The first report on the long-term fiscal impact of climate change mitigation measures in Switzerland, released Tuesday, projects a major negative impact on public funds as certain tax sources dry up, but a planned replacement levy on electric vehicles could lessen that effect.
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April 23, 2024
Irish Minister Warns Corp. Tax Windfall Still Shrouds Deficit
Ireland's budget is projected to have an €8.6 billion ($9.2 billion) surplus this year, but the country's finance minister again cautioned Tuesday that without the slowly decreasing windfall corporate tax receipts there would actually be a deficit.
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April 23, 2024
Tax Experts Want Cut To Healthcare Insurance Levy
Tax experts on Tuesday urged the U.K. government to partially suspend a levy on healthcare insurance products, after it revealed record premium tax revenue of £8.1 billion ($10.1 billion) last year.
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April 23, 2024
Talk Of Int'l Wealth Tax Fuels Debate On UN Vs. OECD
Discussion of an international tax on the world's wealthiest individuals has intensified a debate about whether international tax policy would be better steered by the Organization for Economic Cooperation and Development or the United Nations.
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April 23, 2024
EU Parliament OKs Extending Duty-Free Imports From Ukraine
The European Parliament approved the suspension of the European Union's customs duties and quotas on Ukrainian imports into the EU for one year until June 2025 on Tuesday, overcoming discord in March over farm imports that threatened the deal.
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April 22, 2024
Scotiabank Fights To Keep Peru VAT Claim Alive
The Bank of Nova Scotia urged the World Bank's international arbitration institution in recently released documents not to dismiss the arbitration of its value-added tax dispute against Peru, saying the case raises issues of fact.
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April 22, 2024
Congress Can Enact Corp. Transparency, Orgs Tell 11th Circ.
Congress is empowered to require American companies to report their beneficial owners to the federal government because there is ample evidence they've previously been used to fund hostile foreign actors, evade sanctions and traffic drugs, two think tanks told the Eleventh Circuit in an amici brief.
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April 22, 2024
Partnership Can't Claim $22.7M Loss, Tax Court Says
The U.S. Tax Court on Monday upheld the IRS' decision to deny a $22.7 million loss deduction claimed by a Connecticut partnership, finding that underlying transactions involving a bankrupt Brazilian company's debt obligations amounted to a disguised property sale.
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April 22, 2024
Sweden Proposes Tax Breaks Ahead Of Budget Negotiations
The Swedish Finance Ministry proposed adjusting its so-called expert tax incentive, which businesses use to attract external workers, among a series of tax changes offered up Monday.
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April 22, 2024
Trader Behind £1.4B Tax Fraud Thought Trades Were Valid
A British trader accused of being the mastermind of a fraudulent trading scheme that cost Denmark's tax authority £1.4 billion ($1.7 billion) genuinely believed that the trades worked, his lawyer told a London court on Monday.
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April 22, 2024
Finland Discovers €30M In Undeclared Crypto Profits
Finnish taxpayers made at least €30 million ($32 million) in undeclared cryptocurrency trade profits in 2022, Finland's tax authority said Monday, reminding taxpayers to include such profits in their filings this year.
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April 22, 2024
UAE Considering R&D Tax Break, Seeks Feedback
The United Arab Emirates is seeking public input to help design a possible research and development tax incentive proposal to help drive innovation and growth, its Ministry of Finance said.
Expert Analysis
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Why Cum-Ex Tax Fraud Probes Are On The Rise
Neil Williams at Rahman Ravelli outlines why European regulatory investigations into cum-ex — a 1990s-era dividend arbitrage trading practice involving tax rebate claims worth tens of billions of euros — are gaining momentum years after the activities that sparked them, and who should be concerned.
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Managing New IRS Global High-Wealth Audits
Global high-wealth individuals on the receiving end of an audit letter under the Internal Revenue Service Large Business and International Division's new program should prepare for a thorough examination process that includes their entire network of persons and affiliated entities, say attorneys at MoFo.
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Employers Should Act Now To Mitigate Remote Work Tax Risk
Where employees have been overseas since the start of COVID-19 and are nearing the 183-day tax threshold, there is little time left for U.S. employers to incorporate tax planning into policies to ensure more flexible working arrangements do not create tax complexities and risks, says Richard Tonge at Grant Thornton.
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Pros And Cons Of State Transfer Pricing Program Participation
A company's decision to settle a transfer pricing dispute through a state program — such as those recently announced by North Carolina and Indiana — will turn on the quality of its documentation, its willingness to pay for certainty and the perceived level of aggressiveness of the state's revenue department, say attorneys at Eversheds Sutherland.
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BigLaw Cannot Reap Diversity Rewards Without Inclusion
BigLaw firms often focus on increasing their diversity numbers, but without much attention to equity and inclusion, minority lawyers face substantial barriers after they get their foot in the door, says Patricia Brown Holmes, managing partner at Riley Safer.
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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.