International

  • December 16, 2024

    HMRC Chief Defends Record On Fighting Tax Evasion

    The chief executive of HM Revenue & Customs told Parliament on Monday that the British tax authority has reduced the level of tax noncompliance in response to claims it needs a better strategy on tax evasion.

  • December 16, 2024

    Info On Over 1,900 Tax Rulings Swapped In OECD Last Year

    Tax jurisdictions within the Organization for Economic Cooperation and Development spontaneously shared information related to over 1,900 tax rulings involving foreign companies in 2023, the OECD said Monday, highlighting the widespread adoption of its transparency framework aimed at mitigating harmful tax practices.

  • December 16, 2024

    Hong Kong Commits To OECD Crypto Reporting Framework

    Hong Kong plans to take part in the Organization for Economic Cooperation and Development's framework for automatically exchanging financial information regarding crypto-assets starting in 2028, the jurisdiction's Inland Revenue Department said.

  • December 13, 2024

    IRS Aims To Ramp Up Partnership Audits, Official Says

    The Internal Revenue Service plans to ramp up partnership audits in the next couple of years to boost the current audit rate of 0.05% as the agency props up a new unit that solely focuses on examining large partnerships, an agency attorney said Friday.

  • December 13, 2024

    OECD Seeks Input On Ring-Fencing Mining Income Guidance

    The Organization for Economic Cooperation and Development said Friday that it is looking for feedback on proposed guidance for tax administrations looking to set up ring-fencing measures for mining operations in order to limit investors' ability to offset expenditures and revenues between projects.

  • December 13, 2024

    Swiss Gov't Rejects Retroactive Tax On Gifts Above $56M

    The Swiss federal government formally rejected a wealth tax proposal by the youth wing of the Social Democratic Party of Switzerland on Friday, saying a retroactive 50% tax on gifts and inheritances above 50 million Swiss francs ($56 million) was "politically questionable."

  • December 13, 2024

    Canada Must Reassess Tax Bills For Ex-Blue Jays, Court Says

    Pension contributions made by two former Major League Baseball stars while they played for the Toronto Blue Jays should be counted in their annual income, the Tax Court of Canada ruled in a victory for the former players.

  • December 13, 2024

    CFC Tax Issues Can't Be Solved Via Treaties, Officials Say

    Bilateral treaties between the U.S. and other countries where a controlled foreign corporation may face withholding tax issues aren't able to effectively resolve those disputes, Internal Revenue Service and Treasury officials said Friday.

  • December 13, 2024

    IRS Mulls Turning Off Foreign Currency Rules For CFCs

    The Internal Revenue Service is in the early stages of considering whether foreign currency gain or loss recognition rules could be turned off in certain situations for controlled foreign corporations, an agency official said Friday.

  • December 13, 2024

    Halliburton Consistent On Claims For $35M Refund, Court Told

    Halliburton has not changed its reasons for claiming a tax refund on a $35 million payment it made to a foreign government to protect its employees from harassment, the company told a Texas federal court, saying the U.S. wrongly accused it of a flip-flop.

  • December 13, 2024

    Taxation With Representation: Kirkland, Davis Polk, Wachtell

    In this week's Taxation With Representation, Google and TPG Rise Climate partner with Intersect Power, Gen Digital Inc. acquires MoneyLion Inc., Patient Square Capital acquires Patterson Companies Inc., and the Buffalo Bills and Miami Dolphins sell minority ownership shares to private equity firms.

  • December 13, 2024

    Canada 2-Month Sales Tax Holiday Begins Saturday

    A two-month goods-and-services tax holiday in Canada on certain goods such as gifts and restaurant meals will begin Saturday after having passed the Senate and receiving royal ascension.

  • December 13, 2024

    Contractor Loses Bail For Texting Alleged Tax Cheat Allies

    A District of Columbia federal judge revoked bail for a former defense contractor accused of running a $350 million tax-evasion scheme that prosecutors call one of the largest in U.S. history, after the government said he'd been texting his alleged co-conspirators.

  • December 13, 2024

    Loper Bright May Influence Tax Less, IRS Chief Counsel Says

    The U.S. Supreme Court decision this year overturning a decades-long standard to defer to federal agencies' regulatory interpretations has encouraged the Internal Revenue Service to better explain its rules, its outgoing chief counsel said Friday.

  • December 12, 2024

    IRS Wants Choice Retained In Dual Loss Rules, Official Says

    The Internal Revenue Service is working to preserve flexibility for taxpayers in rules aimed at preventing companies from using the same economic loss twice after concerns were raised about how the rules could negatively interact with the Pillar Two global minimum tax, an official said Thursday.

  • December 12, 2024

    IRS Seeks Feedback On Limits In Previous Taxed Profit Rules

    The Internal Revenue Service will consider whether rules included in recently proposed guidance on previously taxed earnings and profits to limit instances where U.S. multinationals may use basis to offset gain are too restrictive, an official said Thursday.

  • December 12, 2024

    CJEU Upholds €1.8M Tax On Volvo Group In Belgium

    Belgium can impose a "fairness tax" totaling €1.8 million ($1.9 million) on nonresident companies without a permanent office in the country, the Court of Justice of the European Union said Thursday.  

  • December 12, 2024

    2nd Circ. Won't Rethink Dual Citizen's FBAR Penalties

    The Second Circuit will not review its September decision finding that a dual U.S.-French citizen is liable for tax penalties for failing to file reports of foreign bank and financial accounts, the court said Thursday.

  • December 12, 2024

    Swiss To End Credit Offsetting India's Tax Treaty Snub

    The Swiss government will no longer offer a credit to taxpayers designed to offset India's rejection of Swiss claims to benefits offered in other Indian tax treaties because India's top court decided to uphold its government's position, according to a notice.

  • December 12, 2024

    German Fund Managers Charged In €45M Cum-Ex Scheme

    Two fund managers have been charged in Germany for "particularly serious" tax evasion over their alleged role in a €45 million ($47 million) cum-ex dividend tax fraud, prosecutors confirmed Thursday.

  • December 12, 2024

    IRS Hopes To Issue Amount B Pricing Guidance Within Weeks

    Treasury is working to finish its guidance on the simplified transfer pricing approach to baseline marketing and distribution known as Amount B by the end of the year, a U.S. official said Thursday.

  • December 12, 2024

    Treasury Seeks To Pause Anti-Laundering Law Injunction

    The U.S. Treasury Department asked a Texas federal judge to pause his nationwide preliminary injunction of the Corporate Transparency Act pending an appeal of his recent decision that found Congress likely overstepped its constitutional authority when it wrote the anti-money laundering law.

  • December 12, 2024

    Less Than Half Of Latin America Sees Taxes As Contributions

    Only 47% of surveyed Latin American taxpayers consider their taxes as a contribution to the overall good of society as opposed to a cost they are forced to pay, the Organization for Economic Cooperation and Development said Thursday, saying the figure was below the global average.

  • December 12, 2024

    Gibraltar Considering Global Minimum Tax Bill

    Gibraltar's Parliament is considering the implementation of two parts of the Organization for Economic Cooperation and Development's 15% global corporate minimum income tax on large multinational entities making over €750 million ($786 million) annually.

  • December 12, 2024

    Mexico To Join Int'l Pricing Program In 2025, Official Says

    Mexico plans in 2025 to join the International Compliance Assurance Program, a multilateral effort to resolve transfer pricing issues, an official from that country's tax authority said Thursday.

Expert Analysis

  • Stock Buyback Excise Tax Guidance A Mixed Bag For SPACs

    Author Photo

    Recent IRS guidance on the new stock repurchase excise tax includes a welcome exception for publicly traded special-purpose acquisition companies but does not exclude redemptions in connection with a de-SPAC transaction, and further guidance is needed to clarify ambiguities around the exception's application, say Olga Bogush and Evgeny Magidenko at ArentFox Schiff.

  • The IRS' APA Rulemaking Journey: There And Back Again

    Author Photo

    Attorneys at Dentons examine recent challenges in which taxpayers successfully argued Internal Revenue Service rulemaking was invalid under the Administrative Procedure Act, how tax exceptionalism and U.S. Supreme Court regulatory deference prompted such challenges, and similar challenges the agency will likely face following this line of cases.

  • ECJ Fiat Ruling Sets Clear Boundaries For EU State Aid Law

    Author Photo

    The European Court of Justice's recent landmark decision in Fiat v. Commission limiting the commission’s attempts to circumvent the lack of EU powers in the area of tax law has important implications in EU state aid law and beyond, say Andreas Reindl and Pietro Stella at Van Bael.

  • Unpacking The Interim Guidance On New Stock Buyback Tax

    Author Photo

    The U.S. Department of the Treasury and Internal Revenue Service's recent notice on applying the newly effective excise tax on stock repurchases provides much-needed clarity on the tax's scope, which is much broader than anticipated given its underlying policy rationale, say attorneys at Eversheds Sutherland.

  • IRS Will Use New Resources To Increase Scrutiny In 2023

    Author Photo

    The new year promises to be a busy one for the Internal Revenue Service, which is poised to apply the boost in funding provided by the Inflation Reduction Act to bolster and expand its enforcement capability, and there are four areas to watch, say attorneys at Skadden.

  • How Japan's Implementation May Change The Pillar 2 Debate

    Author Photo

    Japan’s outline of proposed legislation adopting a primary component of the Organization for Economic Cooperation and Development's 15% global minimum tax will increase pressure on countries — including the U.S. — that have not committed to adopting Pillar Two, says Takato Masuda of Nishimura & Asahi.

  • Foreign Tax Credit Proposal Is Some Help, But More Is Needed

    Author Photo

    New foreign tax credit regulations proposed by the U.S. Treasury Department provided some measure of relief on cost recovery and royalty withholding, two of the most troublesome aspects of the 2021 final foreign tax credit regulations, but the final regulations are still harmful to many taxpayers, making litigation inevitable, say attorneys at Fenwick.

  • IRS' Tax Gap Statistics Don't Paint A Full Compliance Picture

    Author Photo

    The Internal Revenue Service's recent report indicating a widening tax gap sheds important light on tax compliance, underlines key pressure points and provides insights into how tax administration could be improved; but tax gap estimates also have their limits, says Joyce Beebe at Rice University.

  • How High Court Could Change FBAR Penalty Landscape

    Author Photo

    On Wednesday, the U.S. Supreme Court will hear Bittner v. U.S., a case that will affect many people penalized for failing to file a Report of Foreign Bank and Financial Accounts, and there are important procedural implications should the government's position be reversed, say Reuben Muller and Andreas Apostolides at Cole Schotz.

  • IRS Memo May Change IP Royalty Tax Prepayment Planning

    Author Photo

    A recent Internal Revenue Service advice memorandum finding a taxpayer was not permitted to prepay tax on contingent royalties after contributing intellectual property offshore is a noteworthy departure from earlier guidance that highlights potential differences between actual and deemed licenses, says William Skinner at Fenwick.

  • What IRS Funding Increase Means For Taxpayers

    Author Photo

    The Internal Revenue Service will first use the influx of funding from the Inflation Reduction Act to address customer support and personnel issues, but with over half the money allocated to enforcement, corporations and high-net-worth individuals will face increased scrutiny, say Patrick McCann Jr. and Jasen Hanson at Chamberlain Hrdlicka.

  • 6 Tax Considerations For Life Sciences Collaboration Deals

    Author Photo

    Given recent IRS guidance and changes to certain tax rates and deductions, biotech and life sciences companies entering into collaboration agreements should assess several unique taxation issues affecting matters ranging from research and development expenditures to profit-sharing terms, say attorneys at Orrick and Andersen Tax.

  • Rushed Multilateral Negotiations Caused Two-Pillar Tax Mess

    Author Photo

    Cracks appearing in the two pillars of the 2021 global tax plan stem from a multilateral tax policy process that rushed to issue rules without first resolving fundamental differences between countries or ensuring that the U.S., a key player, could implement them, says Jefferson VanderWolk at Squire Patton.

Can't find the article you're looking for? Click here to search the Tax Authority International archive.