International
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May 03, 2024
Final EV Tax Credit Regs Add New Battery Tracing Test
The U.S. Treasury Department unveiled final regulations Friday for the up to $7,500 electric vehicle tax credit that include a more detailed process for automakers to trace the battery supply chain to qualify for the credit's domestic content requirements.
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May 03, 2024
German's Austrian Ski Holiday Ends With Arrest In VAT Probe
A German citizen on a skiing holiday in Austria was arrested over a large-scale value-added tax fraud scheme, the Finance Ministry in Vienna said in a statement on Friday.
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May 02, 2024
Claimed Panama Papers Leaker Fights To Hide ID In €5M Suit
A person claiming to be the Panama Papers leaker told a federal court they would fear for their life if the court made them disclose their identity in a €5 million ($6.3 million) suit against Germany, protesting a magistrate judge's suggestion that the suit be tossed because the person wouldn't identify themselves.
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May 02, 2024
IRS To Boost Audit Rates By 50% On Wealthy, Werfel Says
The Internal Revenue Service plans to nearly triple audit rates on corporations with assets over $250 million and increase audit rates by more than 50% on wealthy taxpayers with more than $10 million in total positive income by 2026, Commissioner Daniel Werfel said Thursday.
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May 02, 2024
Latest Stock Buyback Tax Rules May Still Have Wide Reach
The U.S. Treasury Department recently floated regulations that narrow an earlier proposal aimed at preventing foreign-parented corporations from circumventing a new excise tax on stock buybacks, but the regulations still characterize avoidance in ways that could include routine intercompany transactions.
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May 02, 2024
HMRC Asked To Investigate Firm On Dodging Sanctions
HM Revenue & Customs should investigate a German-owned garage door manufacturer for violating sanctions by importing products from Belarus into the U.K., but instead authorities brushed off the case and now the company might receive a license, a U.K. lawmaker said.
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May 02, 2024
Canada Budget Seeks To Establish Corp. Min. Tax Standards
Budget proposals submitted to Canada's Parliament by the finance minister would implement the Organization for Economic Cooperation and Development's global corporate minimum tax standards as part of the country's overarching budget plans.
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May 02, 2024
OECD-Asia Group Helping Reform Agenda, OECD Head Says
A group that brings together countries from the mostly Western Organization for Economic Cooperation and Development and Southeast Asia to discuss issues, including tax, is helping countries make changes, the head of the OECD said Thursday.
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May 02, 2024
Airlines Slam Increase In German Air Passenger Tax
The increase in Germany's air passenger tax on May 1 will weaken the country's economy and damage the aviation industry's ability to cut down on its carbon use, an airline group said on Thursday.
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May 01, 2024
No Relief For Fla. Adviser Convicted In $80M Trading Scam
The Eleventh Circuit on Wednesday affirmed the conviction of a Florida investment adviser who bilked more than $80 million from the hundreds of people he persuaded to invest in a fraudulent company, after concluding he was not in custody when he made statements to the police.
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May 01, 2024
Middle East, North African Gov'ts Back UN For Corp. Tax Talks
Governments should make a high-level commitment to address corporate tax reform within the United Nations' framework convention on international tax cooperation, an intergovernmental group of Middle Eastern and North African countries said Wednesday.
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May 01, 2024
Think Tank Says 'Distortive' DSTs Not The Right Way Forward
As jurisdictions around the world continue to struggle with how to adequately tax the increasingly digital economy, they should look to expand their consumption taxes, not enact digital services taxes, the Tax Foundation said.
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May 01, 2024
Liberty Global Defends $109M Tax Refund Bid In 10th Circ.
Telecommunications giant Liberty Global urged the Tenth Circuit to revive the company's $109 million tax refund bid, arguing a lower court rejected the claim by wrongly disregarding intercompany transactions that are permitted under legislation involving the repatriation of foreign profits.
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May 01, 2024
UN Must Improve Corp. Tax Rules, Platforms, Some Gov'ts Say
Governments must commit to improving existing corporate tax rules and platforms created at the OECD within the terms of reference for a United Nations framework convention on global tax cooperation, two tax officials who participated in drafting those rules said Wednesday.
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May 01, 2024
HMRC Simplifies Late Filing Penalties For Digital Filers
U.K. taxpayers voluntarily filing their personal income tax returns using a program intended to modernize the country's tax system will receive more leniency and access to a simpler penalty structure in cases of late filing, HM Revenue & Customs said.
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May 01, 2024
Hong Kong Proposes Amended Automatic Info Exchange List
Hong Kong is considering adjusting the list of countries it automatically exchanges financial information with by subtracting nine jurisdictions and adding 11, which the country's tax authority said is in line with recommendations from the Organization for Economic Cooperation and Development.
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May 01, 2024
Swiss Sends Amendment To Serbian Tax Treaty To Parliament
Switzerland's executive body, the Federal Council, sent to the country's parliament Wednesday an amendment for the country's double-taxation treaty with Serbia that would bring it in line with the OECD's base erosion and profit shifting standards, the council said.
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April 30, 2024
India, Belgium, Others Support UN Taking On Wealth Taxation
Governments should make a high-level commitment to reach agreement on the taxation of wealthy individuals within the United Nations framework convention on international tax cooperation, representatives of India, Belgium, Austria, Nigeria and Kenya said Tuesday.
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April 30, 2024
Yellen Says US Pushing To Protect R&D Credit Under Pillar 2
U.S. Treasury Department negotiators are continuing to advocate for more favorable treatment of the country's research and development tax credit under the Pillar Two global minimum tax rules, Treasury Secretary Janet Yellen told the House Ways and Means Committee on Tuesday.
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April 30, 2024
German Banker Gets 3 Years For €93M Cum-Ex Tax Evasion
A German court on Tuesday sentenced a former bank board member to three years and two months in prison for his part in a €93.4 million ($100 million) so-called cum-ex dividend tax fraud.
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April 30, 2024
HMRC Proposes Special Economic Zone Tax Relief Extensions
HM Revenue & Customs proposed Tuesday to extend the time to claim tax relief measures available in special economic zones in the U.K. to 2031 in England and to 2034 in other parts of the country.
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April 30, 2024
The Tax Angle: TCJA Teams, Dear Colleague Letters
From a look at House GOP efforts to prepare for next year's expiration of their 2017 tax overhaul to ongoing attempts by lawmakers to draw attention and support for their own tax legislation, here's a peek into a reporter's notebook on a few of the week's developing tax stories.
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April 30, 2024
Global Climate Tax Could Fund Disaster Aid, Report Says
If OECD countries adopted a tax on the extraction of fossil fuels proposed by over 100 climate organizations, $900 billion could be generated cumulatively by 2030, a majority of which would be earmarked for those hit by climate disasters, some of those groups reported.
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April 30, 2024
EU Tax System Needs To Aid Climate Policy, Accountants Say
European Union lawmakers should design a tax system in their next five-year legislative term that supports the green transition and long-term employment, a European lobby for accountants said in a document posted Tuesday.
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April 29, 2024
Court Can Make Widow Pull $2.5M From Swiss Bank, US Says
A Colorado federal court can force a widow to send $2.5 million from a Swiss bank to the U.S. to repay her late husband's penalties and interest for failing to report his foreign accounts, the U.S. told the court.
Expert Analysis
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Lessons From IRS For A New HMRC Whistleblowing Model
Andrew Park at Andersen considers whether the public interest would be better served in allowing the U.K.'s tax enforcers, HM Revenue & Customs, to offer larger and more certain cash incentives to people blowing the whistle on tax misdemeanors — similar to the IRS model for whistleblowers.
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The Benefits Of Competent Authority In Int'l Tax Disputes
Multinational enterprises seeking relief from double taxation in a changing international tax landscape should consider utilizing the competent authority process, which provides both taxpayers and domestic tax regulators an efficient and effective means of dispute resolution, say David Farhat and Eman Cuyler at Skadden.
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How OECD Transfer Tax Initiative Affects Smaller Businesses
Small and midsize enterprises with cross-border transactions need to consider redefining tax strategies and operational models in light of the Organization for Economic Cooperation and Development's base erosion and profit shifting initiative, even though the agency's new tax guidelines are aimed at large multinational enterprises, says Ganesh Ramaswamy at Kreston Rangamani.
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What The New OECD Double-Tax Procedure Statistics Tell Us
Monique van Herksen and Clive Jie-A-Joen at Simmons & Simmons consider the Organization for Economic Cooperation and Development’s recent report on double taxation cases resolved in 2020 under the mutual agreement procedure process, and examine whether the process has improved dispute resolution mechanisms since its implementation five years ago.
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Navigating FCPA Risks Of Minority-Owned Joint Ventures
The U.S. Department of Justice and U.S. Securities and Exchange Commission will likely continue to focus on third-party risks under the Foreign Corrupt Practices Act, so companies with minority-owned joint ventures should take several steps to mitigate related compliance challenges, say Ben Kimberley at The Clorox Company and Addison Thompson at Covington.
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Questions To Ask If Doing Business In A Corruption Hot Spot
Businesses facing new scrutiny after the U.S. Department of Justice's recently announced task force for combating human trafficking in Central America, the release of the Pandora Papers and continuing fallout from 2019's Panama Papers, should address compliance risks by having employees ask three questions about every transaction, say attorneys at White & Case.
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How The Global Tax Agreement Could Backfire For Biden
If the $3.5 trillion spending package fails, the federal tax code will not conform to the recent 15% global minimum tax agreement spearheaded by the U.S., which would embarrass the Biden administration and could lead to retaliatory tax measures by other nations, says Alex Parker at Capitol Counsel.
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Pandora Papers Reveal Need For Greater Tax Enforcement
The recent Pandora Papers leak is a reminder of the importance of transparency laws and proper funding for enforcement efforts against tax evasion as bad actors increasingly operate in the shadows, says Daren Firestone and Kevin Crenny at Levy Firestone.
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Parsing New Int'l Tax Reporting Rules For Pass-Throughs
Attorneys at Grant Thornton unpack the Internal Revenue Service’s new pass-through entity reporting requirements for international tax matters and the accompanying guidance for penalty relief, and suggest how companies should prepare for what may be the most significant change to the partnership compliance function in decades.
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A Look At Global Tax Enforcement Developments: Part 2
Excerpt from Practical Guidance
Sean Craig at LexisNexis examines recent investigations by the Joint Chiefs of Global Tax Enforcement and their impact on U.S. taxpayers, as well as the growing significance of transfer pricing disputes and policies for future enforcement.
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A Look At Global Tax Enforcement Developments: Part 1
Excerpt from Practical Guidance
Sean Craig at LexisNexis looks at how international initiatives, such as the Joint Chiefs of Global Tax Enforcement, are addressing cryptocurrency-related tax evasion, and how the COVID-19 pandemic and increasing demands for governmental welfare programs are driving global tax policy.
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EU Climate Plan Should Involve Taxing Pollution, Not Borders
In order to crack down on greenhouse gas emissions, the European Union proposes to levy carbon emissions at its borders and to overhaul its long-standing energy tax framework, but the latter would hold polluters directly accountable, giving it the better chance for success, says Rebecca Christie at Bruegel.
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Prepare For Global Tax Regime's New Biz Dispute Risks
Companies should take steps to mitigate the business dispute risks of the new international tax framework, which over a hundred countries agreed to in July, as implementing the new regime will be expensive and require substantial organizational restructuring efforts, says Tim McCarthy at Dykema.