International
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July 22, 2024
Challenge To Romanian Trading Tax Referred To ECJ
Europe's highest court has been handed a challenge to trading tax in Romania, as a national court seeks guidance on whether EU law would prevent a member country from creating an extra tax liability for some participants in the wholesale energy market.
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July 19, 2024
Edwin Coe Adds To Team Ahead Of Planned UK Tax Changes
Edwin Coe LLP is preparing for an expected surge in disputes following the U.K.'s planned tax changes by hiring as a partner a Harbottle & Lewis lawyer with expertise in litigation and tax planning, according to a news release.
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July 19, 2024
Luxembourg Floats Corp. Tax Cut To Boost Attractiveness
Corporations in Luxembourg may see their income tax rate drop by a percentage point in a bid to make the country more attractive to businesses as part of a larger proposed tax package presented by its finance minister.
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July 19, 2024
6 Nations Must Improve Transparency Measures, OECD Says
Six countries were found largely compliant with the Organization for Economic Cooperation and Development's tax transparency and exchange of information measures due to needed improvements to their beneficial ownership information mechanisms, the organization said Friday.
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July 19, 2024
Attorney Denied Separate Trial In $2.1B Danish Tax Fraud
An attorney facing trial alongside his clients for alleged ties to a $2.1 billion Danish tax fraud has been denied a separate hearing by a New York federal court, which remained unconvinced that his co-workers' advice to the clients could rebound on him prejudicially in a joint trial.
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July 19, 2024
Taxation With Representation: A&O Shearman, Gibson Dunn
In this week's Taxation With Representation, Cleveland-Cliffs Inc. buys Stelco Holdings Inc., KBR acquires LinQuest Corp., Blue Owl Capital Inc. purchases Atalaya Capital Management LP, and Amphenol Corp. buys two mobile networks units from CommScope.
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July 19, 2024
2 Arrested In €8.8M VAT Fraud Involving Cleaning Products
Italian financial police arrested two people Friday who are suspected of leading an €8.8 million ($9.6 million) value-added tax fraud scheme involving cleaning products and beverages, the European Public Prosecutor's Office said.
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July 19, 2024
Gov't Floats Draft Proposal For OBR 'Fiscal Lock' Powers
HM Treasury proposals for a new "fiscal lock" in a draft Budget Responsibility Bill will allow the Office for Budget Responsibility to scrutinize any tax-and-spend decisions with a cost factor of 1% of gross domestic product or more.
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July 19, 2024
International Tax Policy To Watch In The 2nd Half Of 2024
An abundance of loose threads pervades the international tax landscape as the first year of the global minimum tax unfolds, with the battle over digital services taxes still smoldering and diplomats talking tougher taxes on the wealthy. Here, Law360 looks at international tax policy to watch in the second half of 2024.
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July 19, 2024
EU Parliament's Tax Body To Elect Chair On July 23
The European Parliament's subcommittee on taxation plans to elect its chair and vice chairs when it meets on July 23, the Parliament confirmed in a statement on Friday.
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July 18, 2024
Treasury Starting To Address Amount B, Official Says
The U.S. Department of the Treasury is just starting to decide how to handle a transfer pricing regime under a prong of the OECD-led global tax overhaul, a Treasury official said Thursday.
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July 18, 2024
Tax Pros Say Gov'ts Stretching 'Realistic Alternative' Analysis
Tax authorities including the Internal Revenue Service are overstepping in their use of "realistic alternative" arguments, substituting their own judgment for that of businesses, transfer pricing specialists said Thursday.
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July 18, 2024
Ex-Venable Trusts And Estates Partner Joins Stradling In LA
Stradling Yocca Carlson & Rauth PC announced that it launched a trusts and estates practice with the hiring of an experienced Los Angeles-based partner from Venable LLP.
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July 18, 2024
Most Top US Cos. To Report Tax Under Aussie Bill, Study Says
Australia's Senate is expected to consider adoption next month of the world's most extensive public country-by-country reporting rules, which would require 51% of large U.S. multinational corporations to disclose tax arrangements retroactively from July 1, according to a study published Thursday.
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July 18, 2024
UK Brothers Sentenced For £3.2M Offshore Tax Evasion
A pair of brothers each received suspended two-year prison sentences for charges related to a tax evasion scheme where they hid more than £3.2 million ($4.1 million) using companies in Gibraltar and the British Virgin Islands, HM Revenue & Customs said Thursday.
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July 18, 2024
Rising Star: Latham's Eric Kamerman
Eric Kamerman of Latham & Watkins LLP in recent years handled the tax aspects of several multibillion-dollar acquisitions of powerhouses in British soccer and American fashion, earning him recognition as one of the tax attorneys under age 40 honored by Law360 as Rising Stars.
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July 18, 2024
Top International Tax Cases To Watch In The 2nd Half Of 2024
Tax attorneys will be tracking several high-stakes cases in the second half of 2024 that could define the bounds of the IRS' ability to craft regulations or lodge direct challenges aimed at what it sees as the tax avoidance maneuvers of multinational corporations. Here, Law360 looks at key international tax cases to follow during the rest of the year.
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July 18, 2024
GE Can't Claim Credit For £189M In Double Tax, Court Says
A U.K.-registered subsidiary of General Electric does not qualify for at least £189 million ($245 million) in double tax relief under a U.S.-U.K. treaty because it lacks a U.S. presence akin to a domicile, a London appellate court ruled.
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July 18, 2024
Von Der Leyen Confirmed For New Term Leading EU Executive
The European Parliament reelected Ursula von der Leyen to a second five-year term as the head of the European Commission on Thursday after a speech in which she advocated cutting red tape for businesses.
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July 17, 2024
Much Of Pillar 1 Treaty Agreed On, OECD Official Says
Agreement has been reached on the bulk of a multilateral pact to implement new taxing rights that are part of a revamp of the international tax system and on expansions to a part of the taxing rights plan, an OECD official said Wednesday.
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July 17, 2024
Gov't Views On OECD Risk Guidance Vary, Economists Say
In allocating risk among different components of a business for transfer pricing purposes, analysts need to consider governments' varying interpretations of guidance from the Organization for Economic Cooperation and Development, a panel of economists said Wednesday.
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July 17, 2024
Aussie Gov't Seeks Tighter Promoter Penalties After PwC Leak
Australia is poised to penalize a wider range of advisers who promote tax schemes to multinational corporations and beef up its Tax Practitioners Board's ability to investigate cases after it uncovered PwC sharing confidential draft laws with clients, according to a consultation that began Wednesday.
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July 17, 2024
Germany Sends Budget With €23B In Tax Cuts To Parliament
Germany's executive body approved a legislative package Wednesday that includes €23 billion ($25.2 billion) in tax cuts for citizens and companies across the next two years, sending it to the country's parliament for consideration.
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July 17, 2024
Disney To Join IBM's Bid To Bring NY Tax Fight To Justices
The Walt Disney Co. joined IBM in asking the U.S. Supreme Court for more time to file a petition for review of a New York high court decision that upheld tax on royalties received from foreign affiliates.
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July 17, 2024
Connell Foley Adds Wilson Elser Tax Pro In Group Upgrade
Connell Foley LLP strengthened its tax and estate team this week with the promotion of several attorneys up to partner and the addition of a mergers and acquisitions and corporate restructuring tax expert previously of counsel at Wilson Elser Moskowitz Edelman & Dicker LLP.
Expert Analysis
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International Tax Reform's Implications For Transfer Pricing
As the Organization for Economic Cooperation and Development overhauls the global tax rules on base erosion and profit shifting, and the Biden administration rolls out new U.S. tax proposals, multinational enterprises need to prepare for the effects of these tax changes on their transfer pricing structures, say Mandy Li and Shuang Feng at MGO.
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Justices' Preemptive Tax Challenge Ruling Shows Divisions
The U.S. Supreme Court's recent decision in CIC Services v. Internal Revenue Service reveals divisions among the justices about when potentially burdensome tax regulations can be challenged, making the holding less clear and less valuable, say George Isaacson and David Swetnam-Burland at Brann & Isaacson.
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Takeaways From 2 New FBAR Rulings
In light of two recent California federal court decisions, capping penalties for nonwillful violations of foreign bank account reporting but broadening the willfulness standard, U.S. taxpayers must be vigilant about understanding their reporting obligations, and prepare for the Internal Revenue Service to target willful conduct, which yields much higher penalties, say Friedemann Thomma and Marianna Felshtiner at Venable.
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El Salvador's Use Of Bitcoin Complicates US Commercial Law
El Salvador recently became the first country to recognize Bitcoin as currency, presenting significant implications for U.S. commercial law as the development will likely trigger the cryptocurrency to now fall within the definition of "money" under the Uniform Commercial Code, say Joe Carlasare and Eric Fogel at SmithAmundsen.
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Justices' Nod To Preemptive Tax Challenges May Caution IRS
The U.S. Supreme Court's recent decision in CIC Services v. Internal Revenue Service, allowing pre-enforcement challenges of tax reporting rules despite the Anti-Injunction Act, is likely to make the U.S. Department of the Treasury more careful about its own compliance obligations under the Administrative Procedure Act, says Robert Carney at Caplin & Drysdale.
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Let's End The Offshoring Of US Patents
Congress should work toward removing the loophole that allows companies to avoid U.S. taxes by moving their patents offshore, and ensure profits are taxed where the sales take place, says Sen. Patrick Leahy, D-Vt.
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Long Road Ahead For Biden's Individual Tax Hike Proposal
Dustin Stamper at Grant Thornton provides insight into President Joe Biden's recently proposed individual tax increases to pay for his American Families Plan, and explains how competing interests among congressional Democrats and Republicans may shape the final provisions and prolong their implementation.
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What Value-Added Tax Might Look Like In The US
Christiaan Van Der Valk and Charles Maniace at Sovos consider the value-added tax, a primary source of revenue for many countries, and what it might mean for the U.S. were it implemented to raise funds for large-scale federal initiatives such as President Joe Biden's infrastructure plan.
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US Needs Better, Nonpunitive Approach To Greening Trade
Instead of imposing tariffs on goods produced where foreign governments have assisted in cleaning up the environment, the U.S. should make trade policy green by helping industries reduce their environmental impact and encouraging every foreign government to do the same, say Elliot Feldman and Michael Snarr at BakerHostetler.
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What OECD Scrutiny Means For Anti-Corruption In Brazil
Attorneys at Paul Hastings examine how an unprecedented standing subgroup recently created by the Organization for Economic Cooperation and Development to monitor Brazil's anti-corruption efforts reflects significant uncertainty regarding the country's commitment to enforcement, and what companies can do to address foreign bribery risk and strengthen compliance programs.
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The International Outlook For US Border Carbon Adjustments
The Biden administration may see enacting a border carbon adjustment system as a good way to advance climate goals and protect domestic industries and jobs, but any such plan must take into account the need to respect existing international trade agreements, say attorneys at Akin Gump.
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The Domestic Landscape For US Border Carbon Adjustments
With the Biden administration possibly eyeing border carbon adjustments on imported goods as a means to mitigate climate change, attorneys at Akin Gump discuss such policies' potential benefits to domestic businesses, and the political and technical challenges to their enactment in the U.S.
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Prepare For Global Collaboration In Crypto Tax Enforcement
Recent Internal Revenue Service victories involving John Doe summonses served on cryptocurrency exchanges — and statements by the Joint Chiefs of Global Tax Enforcement about global collaboration in cryptocurrency-related tax investigations — should prompt assessment of prior virtual currency transactions and remediation before an enforcement agency shows up at the door, say attorneys at McDermott.