International
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May 10, 2024
Osborne Clarke Lawyer To Face Tribunal Over Zahawi SLAPP
An Osborne Clarke LLP partner who represented Nadhim Zahawi could face a disciplinary tribunal over allegations that he used intimidatory warnings in an attempt to silence a critic who was probing the former Conservative chancellor's tax affairs.
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May 09, 2024
Mich. Doctor Ordered To Stay In Jail Until Assets Repatriated
A Michigan doctor fighting accusations that he failed to report his foreign bank accounts will stay in jail, as a federal court declined to release him Thursday when he didn't comply with an order to deposit over $1 million to cover the judgment against him.
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May 09, 2024
Pop Star Shakira's €6.6M Spanish Tax Fraud Case Dropped
A Spanish court dropped a case alleging that Colombian pop superstar Shakira had willfully defrauded the country of €6.6 million ($7.1 million) worth of taxes in 2018, multiple news outlets reported Thursday.
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May 09, 2024
Pension Plans Want Witness Stopped In $2B Danish Dispute
U.S. pension plans accused by Denmark's tax authority of committing $2.1 billion in fraud against the European country by taking illegal refunds on dividends asked a New York federal court to reject the authority's request to depose a witness who pled guilty in Denmark.
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May 09, 2024
Voluntary Carbon Credit Trades Will Trigger UK VAT
Transactions involving voluntary carbon credits in the U.K. will be assessed value-added tax starting in September, HM Revenue & Customs said Thursday.
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May 09, 2024
IRS Turning to Final PFIC Rules This Year, Official Says
The Internal Revenue Service expects to "begin in earnest" this year on final regulations for partnerships that hold stock in passive foreign investment companies, including guidance that would treat partnerships as an aggregate of their partners, an agency official said Thursday.
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May 09, 2024
Country Adjustment Would Undermine Common EU Tax Base
Allowing countries within the European Union to adjust companies' allocated tax base under proposed rules would undermine the rules' goal of streamlining the corporate tax base, according to business groups.
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May 08, 2024
DOJ Says Man Owes $6.2M After Failing To Report Foreign Biz
A man owes tax penalties of $6.2 million to the U.S. after failing to disclose his ownership interests in two foreign entities from 1997 to 2004, the government told a California federal court Wednesday.
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May 08, 2024
Biz Groups Tell 10th Circ. Economic Substance Doesn't Apply
The economic substance doctrine doesn't apply when a business considers tax in making a choice between two legally permissible alternatives, two organizations told the Tenth Circuit in their briefs supporting Liberty Global's position in its $109 million tax refund bid.
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May 08, 2024
4th Circ. Asks If High Court Ruling Bars Credit Suisse Tipster
A Fourth Circuit panel questioned Wednesday whether a U.S. Supreme Court ruling prevented it from reviving a whistleblower case by a former Credit Suisse employee alleging the bank helped U.S. citizens evade taxes after paying a $2.6 billion criminal penalty.
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May 08, 2024
Auto Cos. Brace For EV Battery Compliance Hurdles
New federal regulations aimed at shoring up the domestic electric vehicle manufacturing supply chain give automakers a much-needed two-year cushion to navigate a compliance minefield, and to figure out how to reinvigorate the recent waning consumer demand for electric vehicles.
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May 08, 2024
Africa Should Solve Own Tax Problems, Nigerian Official Says
The solutions to Africa's taxation challenges should come from those actually on the continent, not the Western world, the chairman of Nigeria's tax authority said at an African Tax Administration Forum meeting, the authority said Wednesday.
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May 08, 2024
EGC Won't Annul EU Decision To Toss Spanish Tax Scheme
The European General Court will not annul a European Commission decision that a Spanish tax scheme for vessels built in its domestic shipyards must be abandoned because it was incompatible with the European Union's internal market, according to a judgment released Wednesday.
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May 08, 2024
Ambulance Co.'s Former Owner Gets 6 Years For Tax Evasion
The former owner of an ambulance company was sentenced to more than six years in federal prison for failing to pay employment taxes to the federal government and obstructing the Internal Revenue Service as it tried to collect, according to Virginia federal court documents.
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May 08, 2024
A Foley Hoag Co-Chair Joins Litigation Firm As Name Partner
Litigation and dispute resolution firm Elliott Kwok Levine & Jaroslaw LLP will operate under a new name after welcoming as its newest name partner a former federal prosecutor who most recently co-chaired Foley Hoag LLP's white-collar crime and government investigations practice.
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May 08, 2024
UN To Publish Draft Terms Of Reference For Tax Pact In June
National governments agreed Wednesday to publish the first draft of terms of reference for the United Nations Framework Convention on International Tax Cooperation for a two-week consultation during the week beginning June 3.
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May 08, 2024
EU Races To Deals On Withholding Tax, Digital VAT
European Union countries are trying to clear the final hurdles for deals on May 14 regarding a withholding tax refund law and a package to modernize value-added tax reporting, although some potential vetoes remain after a preparatory meeting, EU sources said Wednesday.
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May 08, 2024
Offshore Drilling Co. Demands $70M Refund From IRS
The IRS wrongfully withheld $69.7 million in tax refunds to an offshore drilling company, despite acknowledging that the refunds are justified by net operating loss carrybacks authorized by a pandemic law and then promising to pay, the company said in Texas federal court.
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May 08, 2024
EU Agrees To Send Russian Assets' Revenue To Ukraine
European Union countries reached a deal Wednesday to transfer the net income from frozen and immobilized Russian state assets to EU funds for rebuilding Ukraine and buying arms for the country, an EU commissioner said.
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May 08, 2024
EU Discusses Monitoring Measures Against Tax Havens
The European Union is considering an annual monitoring process over defensive measures against tax havens in force in the 27 bloc countries, an EU official said Wednesday.
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May 08, 2024
Slow Tax Decisions By EU States Are Harmful, Lawmaker Says
The slow pace of European Union countries in reaching decisions on tax issues harms the bloc's economy, a conservative member of the European Parliament said in a document sent to journalists Wednesday.
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May 08, 2024
EU Calls For Responses On Information Exchange Law
The European Union's executive branch is seeking responses on the law that governs the exchange of information between tax authorities in the group of 27 nations, as a senior EU tax official said it was time to "assess the need for fine tuning."
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May 07, 2024
Biz Orgs. Ask 10th Circ. To Toss Economic Substance Ruling
The Tenth Circuit must not uphold a Colorado federal court's ruling that it didn't need to determine whether economic substance doctrine was relevant before disallowing an intercompany transaction by Liberty Global Inc., three business groups told the Tenth Circuit in briefs Tuesday.
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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.
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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.
Expert Analysis
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What IRS Funding Increase Means For Taxpayers
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.
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6 Tax Considerations For Life Sciences Collaboration Deals
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.
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Rushed Multilateral Negotiations Caused Two-Pillar Tax Mess
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.
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Key Considerations For Seeking Relief From Double Taxation
Caroline Setliffe and E. Miller Williams at Eversheds Sutherland lay out the Organization for International Cooperation and Development’s mutual agreement procedure for settling double-taxation disputes, and discuss six factors U.S. taxpayers doing business in multiple countries should consider when determining the most advantageous form of relief.
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2 Tax Decisions Hold Key Transfer Pricing Takeaways
Richard Slowinski and Stefanie Kavanagh at Alston & Bird discuss two recent decisions in cases against the IRS — Eaton Corp. from the Sixth Circuit and Medtronic from the Tax Court — that may help clarify when the agency can cancel an advance pricing agreement, but leave unanswered questions about which pricing method applies to high-value intercompany licensing transactions.
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Digital Taxation Is Necessary, But Tough To Manage
The U.S. government has started to tackle complex new tax laws as the digital economy continues to grow, but this demands guidelines that will facilitate the growth while protecting investors and the government's finances, say attorneys at Cadwalader.
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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.