International

  • May 07, 2024

    India's Top Court Upholds Tax On Employee Perks

    A catch-all provision in India's tax on employee perks does not grant excessive power to the tax authority, and the tax rate on interest-free loans as perks is not unconstitutional, the Supreme Court of India affirmed Tuesday.

  • May 07, 2024

    Industry Groups Suggest Changes To Aussie Reporting Rules

    A coalition of global fund industry associations asked Australia to further amend its proposal for public country-by-country tax data reporting by including, among other measures, a provision that would allow companies to withhold sensitive information, according to a letter released Tuesday by the U.S. Treasury Department.

  • May 07, 2024

    India High Court Says Biz's Tax Refunds Can't Be Held Back

    Indian tax authorities must refund value-added taxes of 225 million rupees ($2.7 million) to a business instead of withholding them to offset future tax liabilities, the country's top court ruled.

  • May 07, 2024

    Latin American, Caribbean 2022 Tax Revenue Up, OECD Says

    Tax revenue in Latin American and Caribbean countries rose in 2022, thanks in large part to gains in the gas and oil sector, but the average tax-to-gross domestic product ratio in the region still lags behind the OECD average, the organization said Tuesday.

  • May 07, 2024

    14 Arrested In €15M VAT Fraud Ring Tied To Lubricating Oil

    Authorities arrested 14 people as part of an investigation into a crime ring that evaded more than €15 million ($16.1 million) in value-added taxes and other levies tied to lubricating oil, the European Public Prosecutor's Office said Tuesday.

  • May 07, 2024

    EU Pauses Drive For Deal On Energy Tax

    The chair of European Union finance ministers gave up attempts to reach an agreement on a landmark energy taxation law because of sharply diverging views among EU countries, a source from Belgium's EU presidency confirmed Tuesday.

  • May 07, 2024

    Austrian Finance Chief Backs Tax Breaks For Full-Time Work

    Austria's finance minister said he backed proposals to use the tax system to encourage individuals to work full time, including freeing overtime work from taxation.

  • May 07, 2024

    Treasury Floats Foreign Trust Reporting Rules

    The U.S. Treasury Department proposed regulations Tuesday that provide guidance on the requirements for individuals to report their transactions with foreign trusts to the Internal Revenue Service, including the receipt of large gifts.

  • May 06, 2024

    10th Circ. Urged To Alter Substance Finding In Liberty Global

    To preserve the stability of federal tax law, the Tenth Circuit should reverse a lower court's finding that it needn't determine the economic substance doctrine is relevant before disallowing a transaction's tax benefits, the National Foreign Trade Council said Monday, supporting telecommunications firm Liberty Global.

  • May 06, 2024

    Man's FBAR Filing Makes Challenge Moot, 7th Circ. Says

    The Seventh Circuit upheld Monday the dismissal of a man's challenge to the constitutionality of filing reports of foreign accounts because after filing the suit, the man reported his bank account, making the case moot.

  • May 06, 2024

    Japan Floats Top Seat For Small Islands At UN Tax Convention

    The United Nations committee responsible for negotiating a framework convention on tax should have a co-chair for small island states in a subgroup that leads drafting of proposals, Japan's government said Monday.

  • May 06, 2024

    Marcum Expands Into Mich. By Adding Croskey Lanni

    Accounting and advisory firm Marcum LLP acquired Detroit-based Croskey Lanni PC, adding six partners and more than 50 associates, Marcum announced Monday.

  • May 06, 2024

    Austrian Tax Investigations Collected €49M In 2023

    Austrian tax investigators carried out 210 investigations in 2023, securing a total of €48.86 million ($52.6 million) in back taxes, with perpetrators possibly owing as much as €100 million in fines, the country's finance ministry said Monday.

  • May 06, 2024

    EU Court Asked To Rule On Italian Nix Of Biz Tax Deductions

    The European Union's highest court was asked to rule on Italy's policy denying Italian parent companies certain tax deductions of corporate taxes paid by their subsidiaries in other EU countries, a question arising from an Italian bank's court challenge, a document published Monday showed.

  • May 06, 2024

    Macron-Backed Group Backs G20 Wealth Tax In Election Pitch

    A group campaigning in the European Parliament elections that is backed by French President Emmanuel Macron supports a wealth tax in the world's largest economies, according to a campaign platform published Monday.

  • May 04, 2024

    IRS Seeks More Info On Purpose Test In Buyback Tax Regs

    The IRS is seeking more information on fine-tuning a test in proposed rules on the stock buyback tax meant to assess whether the principal purpose of a U.S. subsidiary's funding purchase of its foreign parent's stock is to avoid the tax, an agency attorney said Saturday.  

  • May 03, 2024

    US Resisting More Scoping On Amount B, Economist Says

    In negotiations over the streamlined transfer pricing approach for baseline marketing and distribution functions known as Amount B, the U.S. has resisted calls for additional scoping criteria that would exclude more companies from the safe harbor, a former U.S. Treasury economist said Friday.

  • May 03, 2024

    Foreign Trust Reporting Rules Coming Soon, IRS Official Says

    The Internal Revenue Service is about to issue proposed regulations that will provide guidance on the reporting obligations for individuals who have transactions with foreign trusts, an agency official said Friday.

  • May 03, 2024

    HMRC Director Rejoins KPMG To Boost Tax Dispute Offering

    A former deputy director at HM Revenue & Customs has returned to KPMG as director of KPMG Law's tax disputes teams, the firm has announced.

  • May 03, 2024

    Africa Seeks Early UN Reform On Transfer Pricing, Exchanges

    Legally binding protocols that reform transfer pricing and exchange of information to the benefit of all countries where multinational corporations operate should be developed simultaneously with the U.N. framework convention on global tax, the U.N.'s African bloc, India and others said Friday.

  • May 03, 2024

    Estonia Implements 2 EU Tax Laws After Delays

    Estonia officially enacted two European Union-wide tax measures that it was late putting into national law, both relating to the OECD's standards for global minimum taxation of large companies.

  • May 03, 2024

    Aussie Treasury Seeks Input On Powers After PwC Scandal

    With investigations into PwC Australia's leak of classified tax plan documents ongoing, the Australian government is asking the public whether it thinks its regulatory powers over tax and accounting firms are sufficient, its Treasury announced Friday.

  • May 03, 2024

    New Fiscal Rules Force EU Countries To Limit Deficits

    New European Union fiscal rules that recently kicked in will force EU countries to restrict public budget deficits by better balancing tax revenues with government spending, the European Commission said Thursday.

  • May 03, 2024

    US Trade Position Seen Contradicting Stance In Pillar 1 Talks

    The U.S. trade representative's withdrawal of support for digital trade proposals has caused tax policy observers to worry that the U.S. position on trade is undermining that of U.S. Treasury Department officials negotiating a taxing rights overhaul at the OECD known as Pillar One.

  • May 03, 2024

    Finland's Stance On Swiss Treaty Recalls Ended Portugal Deal

    Finland's plan to renegotiate its tax treaty with Switzerland in response to concerns about pension tax avoidance has some observers worried that the country will cancel that accord as it did a treaty with Portugal in recent years.

Expert Analysis

  • 5th Circ. Ruling Reminds Attys That CBP Can Search Devices

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    The Fifth Circuit’s recent Malik v. Department of Homeland Security decision adds to the chorus of federal courts holding that border agents don’t need a warrant to search travelers’ electronic devices, so attorneys should consider certain special precautions to secure privileged information when reentering the U.S., says Jennifer Freel at Jackson Walker.

  • Enforcement Of International Tax Reporting Is Heating Up

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    Since the U.S. Supreme Court’s February decision in Bittner v. U.S. changed how penalties for failure to report offshore accounts are calculated, recent developments suggest the government is preparing to step up enforcement and vigorously pursue the collection of resulting penalties, say Daniel Silva and Agustin Ceballos at Buchalter.

  • IRS Notice Clarifies R&E Amortization, But Questions Remain

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    The IRS and Treasury Department’s recent notice clarifying the treatment of specified research and experimental expenditures under Section 174 provides taxpayers and practitioners with substantive guidance, but it misses the mark in delineating which expenditures are amortizable, say attorneys at Eversheds Sutherland.

  • Preparing Your Legal Department For Pillar 2 Compliance

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    Multinational entities should familiarize themselves with Pillar Two of the Organization for Economic Cooperation and Development’s BEPs 2.0 project and prepare their internal legal tracking systems for related reporting requirements that may go into effect as early as January, says Daniel Robyn at Ernst & Young.

  • What Large Language Models Mean For Document Review

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    Courts often subject parties using technology assisted review to greater scrutiny than parties conducting linear, manual document review, so parties using large language models for document review should expect even more attention, along with a corresponding need for quality control and validation, say attorneys at Sidley.

  • Participating In Living History Makes Me A Better Lawyer

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    My role as a baron in a living history group, and my work as volunteer corporate counsel for a book series fan association, has provided me several opportunities to practice in unexpected areas of law — opening doors to experiences that have nurtured invaluable personal and professional skills, says Matthew Parker at the Nebraska Department of Health and Human Services.

  • Private Equity Owners Can Remedy Law Firms' Agency Issues

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    Nonlawyer, private-equity ownership of law firms can benefit shareholders and others vulnerable to governance issues such as disparate interests, and can in turn help resolve agency problems, says Michael Di Gennaro at The Law Practice Exchange.

  • How Taxpayers Can Prep As Justices Weigh Repatriation Tax

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    The U.S. Supreme Court might strike down the 2017 federal tax overhaul's corporate repatriation tax in Moore v. U.S., so taxpayers should file protective tax refund claims before the case is decided and repatriate previously taxed earnings that could become entangled in dubious potential Section 965 refunds, say Jenny Austin and Gary Wilcox at Mayer Brown.

  • OFAC Designation Prosecutions Are Constitutionally Suspect

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    Criminal prosecutions based on the Office of Foreign Assets Control’s sanctions-related listing decisions — made with nearly unfettered discretion through an opaque process — present several constitutional issues, so it is imperative that courts recognize additional rights of review, say Solomon Shinerock and Annika Conrad at Lewis Baach.

  • How The OECD Global Tax Proposal Could Affect M&A

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    Following agreement on the Organization for Economic Cooperation and Development’s Pillar Two proposal to introduce a global minimum tax, domestic implementation is expected to have a significant impact on international M&A transactions, with financial modeling, deal structuring, risk allocation and joint venture arrangements likely to be affected, say lawyers at Freshfields.

  • UK Shares-Tax Proposals Offer Long-Awaited Modernization

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    The U.K. government's recent consultation on the introduction of a new tax on transactions in securities raises detailed legal and practical issues, but the prospect of a single digital stamp tax offering both streamlined legislation and administration will be welcomed, say Zoë Arnautov and Mark Sheiham at Simmons & Simmons.

  • IRS Foreign Tax Credit Pause Is Welcome Course Correction

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    A recent IRS notice temporarily suspending application of 2022 foreign tax credit regulations provides wanted relief for the many U.S. multinational companies and other taxpayers that otherwise face the risk of significant double taxation in their international operations, say attorneys at Mayer Brown.

  • IRS Criminal Probe Spells Uncertainty For Malta Pension Plans

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    The IRS’ recent scrutiny of Malta pension plan arrangements — and its unusual issuance of criminal administrative summonses — confirms that it views many of these plans as illegal tax evasion schemes, and the road ahead will not be smooth and steady for anyone involved, say attorneys at Kostelanetz.

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