International
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July 09, 2024
Irish Budget To Allocate €1.4B To Fund Tax Measures in 2025
The Irish government on Tuesday published the details of its €8.3 billion ($9 billion) budget for 2025, including €1.4 billion set aside to fund tax measures.
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July 09, 2024
India High Court Says Rights To Sell Liquor Aren't Taxed
The rights to sell the alcoholic beverage arrack are not taxed because the liquor vendors who purchase them do not fit into the definition of "buyer" under Indian tax law, the Supreme Court of India ruled.
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July 09, 2024
Finnish Tax Take Drops Amid Slowing Real Estate Market
The Finnish government's tax revenue declined 0.4% last year to €42.3 billion ($45.7 billion) as collections from levies on real estate purchases and car registrations each declined by more than 20%, the country's tax authority said Tuesday in a news release.
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July 09, 2024
EU, India Wary Of Overlap From UN's Global Tax Work
Indian and European Union officials agreed during a meeting that the negotiations around a framework convention on international tax cooperation at the United Nations shouldn't overlap efforts of the ongoing OECD-led global tax overhaul, an EU executive department said.
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July 09, 2024
UK's Non-Dom Taxpayer Count Increased 7%
A growing number of taxpayers in the United Kingdom claimed last year that their permanent home is outside the country, qualifying them for a non-domiciled tax exemption in the crosshairs of lawmakers, HM Revenue & Customs said Tuesday.
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July 09, 2024
5 Firms Steer $513M Ryan-Altus Cross-Border Tax Deal
Dallas-based tax services and software provider Ryan said Tuesday it has inked a deal to acquire the property tax business of Altus Group Ltd. for CA$700 million ($513.4 million), enlisting three firms to assist on a deal that will expand its footprint in Canada, the U.S. and the U.K.
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July 09, 2024
Maltese Case Tests EU Cooperation To Fight VAT Fraud
The case of a Maltese man arrested on suspicion of a key role in Sweden's largest value-added tax fraud illustrates how European countries are trying to boost their imperfect cooperation to combat such fraud, which causes billion-euro losses.
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July 09, 2024
Mishcon De Reya Adds Blick Rothenberg Partner
Mishcon de Reya has added a former director from Blick Rothenberg to its corporate tax team in London as a partner, the firm announced in a statement.
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July 09, 2024
Companies Deliberate Pillar 2 Prep After OECD Signals Relief
Multinational corporations facing the Pillar Two global minimum tax in various jurisdictions are weighing comments from OECD officials that hint at more relief as they decide whether to prepare to comply with the rules now or gamble on the prospects of permanent safe harbors.
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July 09, 2024
Left Group Likely To Chair EU Parliament's Tax Body
A member of the Left group in the European Parliament is expected to chair the body's tax subcommittee, a document seen by Law360 on Tuesday showed.
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July 09, 2024
EU Proposes Diplomatic VAT Exemptions Go Digital
The European Commission proposed that certificates for diplomatic exemptions from value-added taxes should switch from paper versions to an electronic form, a document said.
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July 09, 2024
Commission Asks For EU Pressure On French, Italian Deficits
The European Commission proposed that European Union finance ministers put pressure on France, Italy and five other EU countries to lower their budget deficits, leaving it up to the countries to decide the details of tax hikes and spending cuts, the commission announced Tuesday.
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July 08, 2024
Hong Kong Enacts Patent Box Tax Regime
The Hong Kong government began implementing a tax incentive known as a patent box for income derived from intellectual property in the jurisdiction, the Inland Revenue Department announced.
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July 08, 2024
Top International Tax Cases Of 2024: Midyear Report
With a U.S. Supreme Court decision affirming a key 2017 tax provision on repatriation, millions of dollars in FBAR penalties upheld and a French ruling confirming the U.S. government's access to foreign bank accounts, the IRS stacked up important court victories on international enforcement in the first half of 2024. Here, Law360 reviews those and other significant rulings from the past six months.
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July 08, 2024
Italy Outlines Details On Local Min. Tax Under Global Deal
The Italian Finance Ministry published plans for implementing a global rule that allows countries to tax the local affiliates of multinational corporations if their effective tax rates dip below an internationally agreed-upon 15% minimum.
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July 08, 2024
Reeves Sets Out Plans For Pensions Investing, Fiscal Review
HM Treasury will work to direct pensions investment to British businesses, create a national wealth fund and conduct a fiscal review into government finances, Rachel Reeves said in her first public speech as chancellor on Monday.
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July 08, 2024
EU Court To Rule On Lithuania Denying Corp. Tax Break
A Lithuanian court asked the European Union's highest court to determine whether Lithuania applies EU law correctly when blocking tax exemptions for dividends transferred to a parent company from a subsidiary in another EU country, a document published Monday said.
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July 08, 2024
Feds Seize $63M LA Estate Tied To Armenian Bribe Probe
The U.S. Department of Justice said Monday that it will seize a $63 million Los Angeles estate that it claims was bought with bribe payments for the family of a former Armenian government official.
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July 08, 2024
German Leaders OK Legislative Package With Tax Cuts
Leaders in Germany's three-party government agreed to a legislative package that would result in tax cuts if enacted, an outline of the agreed-to measures said.
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July 08, 2024
Leftist Bloc That Wants To Tax Rich Wins French Election
A left-wing bloc that promises to increase taxes on the rich won a plurality of seats in elections to the lower house of France's legislature but fell far short of gaining an outright majority.
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July 05, 2024
How Reshaped Circuit Courts Are Faring At The High Court
Seminal rulings from the U.S. Supreme Court's latest term will reshape many facets of American society in the coming years. Already, however, the rulings offer glimpses of how the justices view specific circuit courts, which have themselves been reshaped by an abundance of new judges.
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July 05, 2024
Breaking Down The Vote: The High Court Term In Review
The U.S. Supreme Court's lethargic pace of decision-making this term left the justices to issue a slew of highly anticipated and controversial rulings during the term's final week — rulings that put the court's ideological divisions on vivid display. Here, Law360 takes a data dive into the numbers behind this court term.
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July 05, 2024
The Sharpest Dissents From The Supreme Court Term
The U.S. Supreme Court's session ended with a series of blockbuster cases that granted the president broad immunity, changed federal gun policy and kneecapped administrative agencies. And many of the biggest decisions fell along partisan lines.
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July 05, 2024
The Firms That Won Big At The Supreme Court
This U.S. Supreme Court term featured high-stakes oral arguments on issues including gerrymandering, abortion and federal agency authority, and a hot bench ever more willing to engage in a lengthy back-and-forth with advocates. Here's a look at the law firms that argued the most cases and how they fared.
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July 05, 2024
Top Federal Tax Cases To Watch In The 2nd Half Of 2024
In the coming months, the U.S. Treasury and the IRS will defend rules designed to go after what they consider as abusive tax practices, including the economic substance doctrine, the Corporate Transparency Act and the moratorium on employee retention tax credits. Here, Law360 looks at key federal tax cases to watch in the rest of 2024.
Expert Analysis
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Company Considerations For Cash Award Incentives: Part 2
Excerpt from Practical Guidance
Cash awards can help companies address some issues associated with equity awards to compensate employees, but due to potential downsides, they should be treated as a tool in a long-term incentive program rather than a panacea, say Denise Glagau and Kela Shang at Baker McKenzie.
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Company Considerations For Cash Award Incentives: Part 1
Excerpt from Practical Guidance
Denise Glagau and Kela Shang at Baker McKenzie discuss what companies must consider when offering cash awards outside of U.S. jurisdictions, and explain how some challenges associated with equity awards may be addressed with cash awards.
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What AML Bill Could Mean For Firms, Funds And FinCEN
If passed, an amendment within Congress’ annual defense bill would expand the list of institutions subject to anti-money laundering regulations, from law firms to investment funds, creating potential rulemaking and enforcement challenges for the Financial Crimes Enforcement Network, say attorneys at Arnold & Porter.
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Unpacking The New Stock Buyback Tax And Its Exceptions
Xenia Garofalo and Kyle Colonna at Eversheds Sutherland discuss provisions of the recently enacted tax on corporate stock repurchases, how its exceptions may be applied and what companies should consider when evaluating the cost of new or existing programs.
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Inside The OECD Transfer Pricing Documentation Guidance
Excerpt from Practical Guidance
The Organization for Economic Cooperation and Development's recently modified documentation guidelines can assist tax administrations in developing requirements for transfer pricing risk assessments and evaluations, and help multinational entity taxpayers demonstrate satisfaction of the arm's-length principle, says Neil Aragones at Lexis Tax.
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A Close Look At The Decentralized Effort To Tax Digital Assets
Clarity on taxation is one of the biggest hurdles to mass adoption of cryptocurrency, and although digital asset innovation has consistently outpaced worldwide government regulation, recent efforts in the U.S. and elsewhere hint at an emerging standard, says Joshua Smeltzer at Gray Reed.
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Key Takeaways From IRS Reversal On FDII Stance
The Internal Revenue Service's recent memo regarding allocation of deferred compensation expenses for purposes of foreign-derived intangible income is a departure from the agency's previous position and may have implications beyond the context of deferred compensation, say attorneys at Miller & Chevalier.
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New Tax Decree Suggests Expansion In Dutch Transfer Pricing
A July 1 decree from Dutch tax authorities updating transfer pricing guidance heralds a major change in how intercompany financial transactions are considered for transfer pricing purposes and forebodes significant audit activity, say Monique van Herksen and Clive Jie-A-Joen at Simmons and Simmons.
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Is NJ's Voluntary Transfer Pricing Initiative Really Voluntary?
The New Jersey Division of Taxation's voluntary transfer pricing audit initiative promises penalty abatement to taxpayers that elect to participate and agree to the division's proposed adjustments, but the effective penalties associated with nonparticipation raise questions about the program's voluntary nature, say attorneys at McDermott.
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Global Tax Chiefs Should Look To US Whistleblower Programs
As the Joint Chiefs of Global Tax Enforcement develops its international whistleblower program to address tax evasion and money laundering schemes in new areas like cryptocurrency, it should take lessons from highly successful U.S. programs on which features to include and pitfalls to avoid, say Neil Getnick and Nico Gurian at Getnick & Getnick.
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What Microcaptive Reporting Ruling May Mean For The IRS
In CIC v. Internal Revenue Service, a Tennessee federal court’s decision to set aside an IRS requirement to disclose microcaptive insurance arrangements may be a step toward evidentiary standards to show that the potential for abuse in a lawful transaction is sufficient to support heightened disclosure requirements, says Samuel Lauricia at Weston Hurd.
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US Should Leverage Tax Rules To Deter Business With Russia
The U.S. should further restrict the flow of resources available for the Putin regime's war in Ukraine by denying U.S. businesses that operate in Russia or Belarus foreign tax credits and global intangible low-taxed income preferences, and by terminating its tax treaty with Russia, says Reuven Avi-Yonah at University of Michigan Law School.
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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.