International

  • June 21, 2024

    UK Tax Fraud Cases Rose 49% Over One-Year Period

    The U.K. tax authority launched more criminal cases for tax fraud for the year ended June 30, 2023, increasing 49% from 63 cases for the previous year to 94, Pinsent Masons LLP said Monday.

  • June 21, 2024

    Supreme Court Leaves Lifeline For Billionaire Income Tax

    The U.S. Supreme Court narrowed but did not entirely block the path to billionaire income tax legislation when the majority's opinion declined to weigh constitutional questions about taxing unrealized gains in its decision to uphold a mandatory repatriation levy.

  • June 21, 2024

    USTR Warns Canada After Digital Services Tax Enactment

    The U.S. Trade Representative's Office remains concerned about Canada's enactment of its digital services tax and is weighing options in defense of potential discrimination against U.S. businesses, a USTR official told Law360 on Friday.

  • June 21, 2024

    Fed. Circ. Backs Subsidy Duties For Canadian Wind Towers

    A Canadian wind tower manufacturer can't get a break on countervailing duties despite being upfront about errors in its sales data, with the Federal Circuit ruling Friday that the errors raise the possibility of additional mistakes.

  • June 21, 2024

    US Formally Suspends Part Of Tax Treaty With Russia

    The U.S. government has provided formal notice to Russia suspending, via mutual agreement, parts of the countries' double-taxation treaty.

  • June 21, 2024

    Big 4 Continue Push For Broader Irish Dividend Exemption

    The Big Four accounting firms reiterated support for Ireland's plans to implement a corporate tax exemption for foreign-sourced dividends and foreign branch profits, but they found the latest proposal still too narrow and complicated to qualify for, according to comments released Friday.

  • June 21, 2024

    Norway Seeking Feedback On Undertaxed Profits Rule

    Norway is looking for feedback on a proposal that would implement the undertaxed profits rule, one component of the Organization for Economic Cooperation and Development's 15% corporate global minimum tax plan, the country's Finance Ministry said.

  • June 21, 2024

    OECD Official Sees Amount B Deal Helping With Amount A

    The Organization for Economic Cooperation and Development is close to a final deal on a key part of its efforts to establish new international taxing rights under Amounts A and B of its Pillar One plans, according to the organization's tax chief.

  • June 21, 2024

    Taxation With Representation: Travers Smith, Potamitis Vekris

    In this week's Taxation With Representation, RSK Group Ltd. gets a £500 million ($632 million) investment, Boston Scientific Corp. acquires Silk Road Medical Inc., Masdar takes a part of Terna Energy SA, and Tate & Lyle PLC buys CP Kelco from JM Huber Corp.

  • June 21, 2024

    EU Digital Tax Is Backup If Pillar 1 Stalls, French Official Says

    Finalizing the Pillar One agreement to reallocate corporate taxing rights globally should remain a paramount goal, but if the effort stalls, the European Union should revive its plan for a digital tax of mostly U.S.-based tech giants, French Finance Minister Bruno Le Maire said Friday.

  • June 21, 2024

    Estonia Again Blocks Agreement On VAT Deal

    For the second straight month, Estonia blocked agreement Friday on a European Union proposal for platform companies such as Airbnb, Uber and Estonia-based Bolt to collect value-added tax on behalf of service providers.

  • June 21, 2024

    Next UK Gov't Urged To Ease Private Healthcare Insurance Tax

    Whoever wins the U.K. election on July 4 should introduce tax breaks on private medical insurance to relieve pressure on the National Health Service, a consultancy warned Friday.

  • June 20, 2024

    German Court Convicts 5 In €52M VAT Fraud In Cars, Masks

    Five people who played roles in a value-added tax fraud scheme involving the trade of luxury cars and medical face masks that caused over €52 million ($55.7 million) in losses were convicted by a Berlin court, the European Public Prosecutor's Office announced Thursday.

  • June 20, 2024

    EU Court Rejects Co.'s Portuguese Tax Breaks Appeal

    An appeal contesting a European Commission decision against a Portuguese tax exemption scheme was rejected by the European General Court, which found a Panama-based food company unable to prove why recovering the illegal state aid should be prohibited.

  • June 20, 2024

    China Denies Tax Crackdown As 2 Cos. Report $80M In Bills

    China's tax authority denied a nationwide crackdown on companies' old tax returns Thursday, less than a week after a chemical firm facing 500 million yuan ($69 million) in additional liabilities halted production and a beverage maker reported owing 85 million yuan.

  • June 20, 2024

    UK Tax Pros Largely Support 2027 Carbon Border Tax Plan

    Two groups representing tax professionals welcomed the U.K. government's plan to introduce a carbon border tax on certain carbon-intensive imports by 2027, but specifics regarding both default embedded emissions values and carveouts for smaller businesses must be ironed out, they said.

  • June 20, 2024

    Norway's $95M Yearly Dividend Tax Losses Spur Joint Audit

    Norway's tax agency announced a joint audit with other Nordic tax agencies, saying it loses an estimated 1 billion kroner ($95 million) a year in withholding taxes that should be paid by foreign shareholders on dividends but aren't due to aggressive tax planning.

  • June 20, 2024

    Canada Lawmakers OK Digital Tax, Advance Min. Tax

    Canada's Senate passed a 3% digital services tax that would target the revenue of large technology companies, following through on a plan that has drawn criticism from the U.S. and groups representing American tech giants.

  • June 20, 2024

    UK Tax Gap Continues Downward Trend, HMRC Says

    The U.K. has continued to shrink its estimated tax gap, reaching a new low of 4.8% in the 2022-2023 tax year, following a trend of decreases over the past almost two decades, HM Revenue & Customs said Thursday.

  • June 20, 2024

    G20 Should Not Give Up On Pillar 1, Gentiloni Says

    The Group of 20 rich and developing countries should not give up on the Pillar One agreement to reallocate corporate taxing rights globally, European Union tax commissioner Paolo Gentiloni said Thursday, pointing to a G20 summit in November as crucial.

  • June 20, 2024

    EU Adopts Sanctions On Russian LNG, Oil Tanker Fleet

    The European Union agreed in principle Thursday on the 14th economic sanctions package against Russia since its war against Ukraine began, targeting liquefied natural gas, dual-use goods and technologies, and a fleet of oil tankers from non-EU countries.

  • June 20, 2024

    Repatriation Tax Doesn't Violate Constitution, Justices Rule

    The U.S. Supreme Court upheld the 2017 federal tax overhaul's mandatory repatriation levy on Thursday, finding the measure applies to the earnings of foreign corporations with U.S. shareholders and therefore does not raise constitutional questions about taxing unrealized income. 

  • June 20, 2024

    German Casino Tax Regime Is Illegal State Aid, EU Says

    Germany's special tax system for public casino operators violates the European Union's law on state aid law, the bloc's executive branch and treaty regulator said on Thursday.

  • June 19, 2024

    EU Commission Tells France, Italy To Lower Budget Deficits

    The European Commission told France, Italy and six other European Union countries to rein in their big budget deficits on Wednesday, although their governments can decide themselves on the details of spending cuts and tax hikes.

  • June 19, 2024

    Problems With VAT Law Still Not Resolved, Estonia Says

    Estonia said Wednesday that it continues to have concerns about a proposed change to the European Union's value added tax law, which the small northeastern European country said would hurt small businesses.

Expert Analysis

  • 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.

  • Taxing The Digital Economy: The Good, The Bad And The Ugly

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    U.S. tech companies should watch for important developments in international taxation, including the resolution of Apple's decade-old state aid case, growing frustration with the Organization for Economic Cooperation and Development's global tax plan and adoption of the digital services tax instead, says Joyce Beebe at Rice University's Baker Institute for Public Policy.

  • Big Tax Changes For Multinational Cos. In Budget Proposal

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    The Biden administration’s fiscal year 2024 budget proposes changes that would materially alter decades-old Internal Revenue Code provisions, requiring a shift in multinational corporations' tax planning strategies comparable to that required after enactment of the Tax Cuts and Jobs Act, say Xenia Garofalo and Kyle Colonna at Eversheds Sutherland.

  • Senate Credit Suisse Report Puts Attention On Banks, Trusts

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    The Senate Finance Committee's recent finding that Credit Suisse violated a plea agreement struck over its role in enabling offshore tax evasion has important ramifications for banks and trusts, including how they onboard, document and report on transactions relevant to U.S. reporting requirements, say Will Barry and Ian Herbert at Miller & Chevalier.

  • Seeking IRS Accountability For Faulty Microcaptive Notice

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    Like the taxpayers in Standard Insurances v. U.S. seeking to expand earlier wins in microcaptive insurance cases that limit IRS use of improperly obtained information, others should consider ways to hold the agency accountable and provide incentive for it to follow the law going forward, says Joshua Smeltzer at Gray Reed.

  • Biden Admin. Proposals Both Encourage And Thwart EV Adoption

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    While the Biden administration has been aggressively focused on promoting electric vehicles from the start, its recently issued guidance on EV tax credits and its restrictive new auto emissions proposal create a sense of implementation whiplash that may frustrate manufacturers and consumers, says Levi McAllister at Morgan Lewis.

  • The Key Issues Keeping Transfer Pricing A Top Tax Concern

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    Several challenges preventing a global economic reemergence from the pandemic era are making practitioners reevaluate commonly used transfer pricing models, and embrace new technologies and ways of doing business, say Farnaz Amini and Sophia Castro Jurado at Marcum.

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