International
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July 30, 2024
UK Healthcare Ex-Directors Banned For £30M In Unpaid Taxes
Two former directors of a defunct U.K. healthcare company are banned from holding executive positions at any business after failing to pay more than £30 million ($38.5 million) in taxes, the government's insolvency agency said Tuesday.
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July 30, 2024
Israel Moving To Adopt Portion Of Global Minimum Tax
Israel's Ministry of Finance said it is working to adopt a portion of the Organization for Economic Cooperation and Development's 15% global minimum tax on large multinational entities starting in 2026 while delaying consideration of two other portions.
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July 30, 2024
Tax Pros Vent Displeasure At EU Disclosure Law
Tax professionals commenting on a European Union disclosure law by the deadline Tuesday vented long-held displeasure at the measure, which requires tax preparers to reveal cross-border strategies.
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July 30, 2024
Pension Tax Reform Could Unlock £100B For UK Growth
Changing how pensions are taxed in the U.K. could potentially unlock more than £100 billion ($128 billion) for domestic investment over the next five years, according to a recent analysis by a pensions consultancy.
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July 29, 2024
Utah Biz Groups Latest To Challenge Corp. Disclosure Law
Several small-business associations in Utah became the latest group to challenge the Corporate Transparency Act's disclosure requirements, telling a federal court Monday the statute violates several constitutional provisions, including the guarantee of due process.
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July 29, 2024
Immigrants Paid $96.7B In Taxes In 2022, ITEP Study Says
Unauthorized immigrants paid $96.7 billion in federal, state, and local taxes in 2022 but received few benefits in return, according to a new study released Monday, whose authors said granting such taxpayers work authorization would boost tax revenue and economic activity.
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July 29, 2024
Sites Should Pay Sport Fishing, Archery Import Tax, GAO Says
Congress should make U.S. online marketplaces responsible for any sport fishing and archery excise taxes owed on consumer import sales they're involved with, the Government Accountability Office said in a report released Monday.
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July 29, 2024
UK Seeks Input On Rule Targeting Min. Tax's Safe Harbor
HM Revenue & Customs opened a consultation Monday seeking comments on an anti-arbitrage rule to help prevent large multinational companies from exploiting the safe harbor provision in the Organization for Economic Cooperation and Development's global minimum tax.
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July 29, 2024
ECJ Nixes Swedish Dividends Tax On Foreign Pension Funds
Sweden can't collect a withholding tax on dividends distributed by Swedish companies to public pension funds abroad while exempting its own public funds because that is inconsistent with European Union law requiring the free movement of capital, the European Court of Justice said Monday.
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July 29, 2024
France Restricts Access To Beneficial Ownership Registry
France is dialing back access to its beneficial ownership information registry by introducing what it is calling a filtering system that limits the previously entirely public database starting Wednesday, the French Finance Ministry said Monday.
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July 29, 2024
Gov't Consults On Tax Hikes For Fund Managers, Non-Doms
Chancellor Rachel Reeves said Monday that an autumn Budget planned for Oct. 30 will include feature selected tax rises, a warning accompanied by strong hints from HM Treasury that fund managers and non-domicile taxpayers could take a bigger hit.
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July 29, 2024
EU's Highest Court Upholds Disclosure Law
The European Union's highest court on Monday upheld the bloc's law requiring tax advisers to report potentially aggressive cross-border tax arrangements, rejecting a challenge from Belgian tax attorneys who said their country's implementation of the EU's DAC6 law violated European law.
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July 26, 2024
G20 Declines To Back Brazil's Plan For A Minimum Wealth Tax
Finance ministers from the Group of 20 nations declined to back Brazil's proposal for an agreement on individual wealth taxation similar to the global corporate minimum tax, instead issuing a statement Friday that opted for softer language about cooperation.
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July 26, 2024
Biz Groups Call Corp. Transparency Act Unconstitutional
The U.S. government has failed to show how the Corporate Transparency Act meets narrow exceptions to the Fourth Amendment's search warrant requirements, a group of small businesses told a Michigan federal court Friday in contending that the statute is unconstitutional.
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July 26, 2024
Denmark's Tax Losses From Evasion Fell 70%, Study Says
Denmark's tax losses from offshore evasion by individuals dropped 70% following the implementation of the automatic exchange of banking information between tax authorities, researchers found in a study of the Danish Tax Agency's data.
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July 26, 2024
Chile Considering New Tax Compliance Measures
Chile's Senate Finance Committee approved a tax compliance measure that includes creating an anonymous whistleblower process related to tax crimes, a lifting of bank secrecy measures and an overall modernization of the country's revenue agency, the country's Ministry of Finance said.
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July 26, 2024
Denmark Says Pension Plans Misread Law In $2B Fraud Case
U.S. pension plans accused by Denmark's tax agency of participating in a $2.1 billion fraud scheme involving withholding tax refunds are misconstruing Danish law as it applies to the ownership of shares, the agency told a New York federal court.
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July 26, 2024
Two Admit Trying To Bribe IRS Official On China's Behalf
Two people admitted to secretly acting on behalf of the Chinese government and bribing an undercover agent in connection with a scheme to revoke the tax-exempt status of U.S. participants in a spiritual practice banned in China, according to New York federal court filings.
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July 26, 2024
Taxation With Representation: Wachtell, Polsinelli, Kirkland
In this week's Taxation With Representation, T-Mobile partners with KKR to acquire Metronet, Exclusive Networks gets a takeover offer, KKR buys Instructure Holdings Inc., and Bally's Corp. merges with The Queen Casino & Entertainment Inc.
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July 26, 2024
Australia Clarifies Tax Treatment Of Exploration, Land Rights
The Australian government has amended its petroleum resource rent tax to clarify what is considered "exploration for petroleum" for tax purposes, and changes are coming soon regarding the depreciation of mining, quarrying and prospecting rights, the Australian Taxation Office said.
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July 26, 2024
EU Closes Investigation Into Repealed Hungarian Ad Tax
The European Commission said Friday it has closed its nearly decadelong investigation into a Hungarian advertisement tax that it said violated the European Union's state aid rules, noting that the country has repealed the law in question.
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July 26, 2024
EU Frees Up €1.5B Of Frozen Russian Assets To Aid Ukraine
The European Union's executive branch said Friday that it is freeing up €1.5 billion ($1.6 billion) of revenue generated from immobilized Russian assets to aid Ukraine in defending itself against the Russian invasion.
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July 25, 2024
Global Tax Revamp Continues To Progress, OECD Tells G20
Implementation of the Pillar Two minimum tax portion of the OECD's international plan to address tax base erosion and profit shifting is well underway, while an agreement is close on the Pillar One taxing rights overhaul, the organization told the Group of 20 nations Thursday.
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July 25, 2024
UK Telecom Co. Owes VAT For Phone Plans In £51M Dispute
A U.K. telecommunications provider will not recover £51.1 million ($65.7 million) in value-added tax payments after the First-tier Tribunal ruled that VAT is chargeable on phone plans from the point of sale, not when the services are used.
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July 25, 2024
Global Tax Police Unit Probes More Than 30 Cybercrime Cases
The Joint Chiefs of Global Tax Enforcement, an intergovernmental tax enforcement group, is investigating more than 30 active cybercrime cases tied to financial and tax criminal activities all over the world, the group announced Thursday in its first report.
Expert Analysis
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Justices Must Apply Law Evenly In Shadow Docket Rulings
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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US Investors Stand To Benefit From Brazil's New Forex Law
Brazil's New Foreign Exchange Law facilitates negotiations and reduces bureaucracy for foreign investments, making it a good time for U.S. investors looking for projects with a positive environmental, social and governance impact to allocate funds to Brazilian energy and infrastructure, say Jorge Kamine and Juliana Pimentel at Willkie.
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A Landmark UK Enforcement Case For Crypto-Assets
HM Revenue and Customs' recent seizure of nonfungible tokens from three people under investigation for value-added tax fraud promises to be the first of many such actions against crypto-assets, so investors should preemptively resolve potential tax matters with U.K. law enforcement agencies to avoid a rude awakening, says Andrew Park at Andersen.
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Simplifying Tax Issues For Nonresident Athletes In Canada
Tax compliance can be particularly challenging for nonresident professional athletes playing in Canada, but as NHL contract negotiations approach a close, it's worth looking at some ways the tax burden can be mitigated, say Marie-France Dompierre and Marc Pietro Allard at Davies Ward.
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Steps For Universities As DOJ Shifts Foreign Influence Policy
Notwithstanding Wednesday's U.S. Department of Justice announcement terminating the initiative targeting Chinese influence and raising the bar for criminal prosecutions, universities should ensure their compliance controls meet new disclosure standards and that they can efficiently respond to inquiries about employees' foreign connections, say attorneys at Covington.
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Why I'll Miss Arguing Before Justice Breyer
Carter Phillips at Sidley shares some of his fondest memories of retiring Justice Stephen Breyer both inside and out of the courtroom, and explains why he thinks the justice’s multipronged questions during U.S. Supreme Court oral arguments were everything an advocate could ask for.
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Corporate Reporting Considerations As Tax Meets ESG
With the U.S. Securities and Exchange Commission filing season upon us amid increasing pressure for greater transparency around effective tax rates and tax strategies, multinational companies must decide how they will approach voluntary tax reporting and prepare their responses if they want to control the narrative, say Michael Lebovitz and Jenny Austin at Mayer Brown.
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The Highs And Lows Of Tax Controversy In 2021
Lawrence Hill at Steptoe & Johnson reviews the ups and downs of tax controversy practice in 2021, including the continued effects of the pandemic, troubling decisions on attorney-client privilege and an IRS comeback on transfer pricing.
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Lessons From IRS For A New HMRC Whistleblowing Model
Andrew Park at Andersen considers whether the public interest would be better served in allowing the U.K.'s tax enforcers, HM Revenue & Customs, to offer larger and more certain cash incentives to people blowing the whistle on tax misdemeanors — similar to the IRS model for whistleblowers.
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The Benefits Of Competent Authority In Int'l Tax Disputes
Multinational enterprises seeking relief from double taxation in a changing international tax landscape should consider utilizing the competent authority process, which provides both taxpayers and domestic tax regulators an efficient and effective means of dispute resolution, say David Farhat and Eman Cuyler at Skadden.
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How OECD Transfer Tax Initiative Affects Smaller Businesses
Small and midsize enterprises with cross-border transactions need to consider redefining tax strategies and operational models in light of the Organization for Economic Cooperation and Development's base erosion and profit shifting initiative, even though the agency's new tax guidelines are aimed at large multinational enterprises, says Ganesh Ramaswamy at Kreston Rangamani.
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What The New OECD Double-Tax Procedure Statistics Tell Us
Monique van Herksen and Clive Jie-A-Joen at Simmons & Simmons consider the Organization for Economic Cooperation and Development’s recent report on double taxation cases resolved in 2020 under the mutual agreement procedure process, and examine whether the process has improved dispute resolution mechanisms since its implementation five years ago.
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Navigating FCPA Risks Of Minority-Owned Joint Ventures
The U.S. Department of Justice and U.S. Securities and Exchange Commission will likely continue to focus on third-party risks under the Foreign Corrupt Practices Act, so companies with minority-owned joint ventures should take several steps to mitigate related compliance challenges, say Ben Kimberley at The Clorox Company and Addison Thompson at Covington.