International

  • May 26, 2023

    Tax Mediation May Adopt Full Confidentiality, Judge Says

    U.S. Tax Court rules for mediation proceedings may eventually include specific confidentiality requirements similar to those in other federal courts, a Tax Court judge said Friday.

  • May 26, 2023

    NY Couple, US Discuss Settling $135K FBAR Case

    The federal government is in talks to settle a case seeking $135,000 in penalties from a New York couple the U.S. said failed to report their interests in foreign bank accounts, according to a report filed Friday in New York federal court.

  • May 26, 2023

    US-Saudi Man To Detail Swiss Accounts In $1.2M FBAR Case

    A dual U.S.-Saudi citizen has agreed to produce records on multiple Swiss bank accounts in a case headed to trial over $1.2 million in foreign bank account reporting penalties, a Florida federal judge said in an order issued Friday.

  • May 26, 2023

    India Lists Exemptions To Angel Tax

    Financial market participants from 21 countries are exempt from India's so-called angel tax under a notification published in the Indian government gazette.

  • May 26, 2023

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service released its weekly bulletin, which included a notice that segment rates for calculating pension plan funding rose in May.

  • May 26, 2023

    Taxation With Representation: Wachtell Lipton, Latham

    In this week's Taxation With Representation, Stratasys merges with Desktop Metal, Mizuho Financial Group buys out Greenhill & Co., and AIG makes a sale to RenaissanceRe Holdings.

  • May 25, 2023

    Calif. Woman's Estate Owes FBAR Penalties, US Says

    The estate of a dead California woman whom the U.S. accused of creating a "maze of offshore entities" with her husband faces a federal lawsuit alleging that she willfully failed to report her interest in foreign bank accounts.

  • May 25, 2023

    EU Court Should Hear Gambling Tax Case, ECJ Adviser Says

    The European Court of Justice should set aside a lower court's order that allowed the European Commission to ignore a slot machine trade group's arguments that a German state tax's deductibility was a form of illegal state aid, an adviser said Wednesday.

  • May 25, 2023

    US Sees Narrow Focus In Ore. Couple's FBAR Trial

    An Oregon couple's trial will hinge on whether their failure to disclose their account at a bank in Iran in 2011 was willful, the U.S. said in federal court.

  • May 25, 2023

    House GOP Bill Aims Reciprocal Tax At OECD Participants

    Countries deemed by the U.S. Treasury Department to have imposed discriminatory taxes, such as the backstop rule in the OECD's 15% global minimum tax, would face a new reciprocal levy under legislation unveiled Thursday by the Republicans on the House Ways and Means Committee.

  • May 24, 2023

    Microsemi Criticizes IRS In Tax Court Over $28M In Penalties

    Semiconductor company Microsemi Corp. said Wednesday that confusion about initial IRS determinations of penalties against it and supervisory approvals of those penalties force the U.S. Tax Court to reject arguments from the IRS that the agency had complied with rules regarding the penalties.

  • May 24, 2023

    5 Countries Still Open To Tax Abuse, EU Says

    Five European Union member countries still have tax systems liable to be abused by those engaging in aggressive tax avoidance, despite the significant strides the bloc has made to tighten its tax systems, the European Commission said Wednesday.

  • May 24, 2023

    German Court Approves City Tax On Disposable Packaging

    A tax on disposable packaging in the city of Tübingen was declared mostly legal Wednesday by Germany's Federal Administrative Court, which reversed a lower court's decision on the matter.

  • May 24, 2023

    Belgium To Stop Sharing Data On US Residents With IRS

    The Belgian government won't transfer data about Americans living in the country to the IRS under the Foreign Account Tax Compliance Act after concluding the practice is unlawful under European Union law, its data protection authority said Wednesday.

  • May 24, 2023

    Canada Tax Court Tosses Gov't Reply For Colorful Language

    The Tax Court of Canada tossed the government's reply to an investment firm challenging CA$89.1 million ($65.5 million) in income assessments, saying the reply contained legal conclusions as well as colorful language. 

  • May 24, 2023

    Int'l Accounting Rules Amended To Help Cos. Facing Min. Tax

    The international standard-setting body for the accounting profession issued amended rules that provide relief for companies subject to the 15% global corporate minimum tax.

  • May 24, 2023

    Tech Group Advises Manufacturing Credit Guidance Changes

    Notification and record retention requirements the U.S. Treasury Department proposed for the so-called advanced manufacturing investment credit are duplicative and overly burdensome, a major business association for the technology sector said.

  • May 24, 2023

    Australia Treasury Refers PwC Leaks For Criminal Probe

    A former PwC partner's leak of the Australian national government's proposals for cracking down on tax avoidance was referred to federal law enforcement for a possible criminal investigation, the country's Treasury said Wednesday.

  • May 24, 2023

    US Drops FBAR Claim Against Mexican Dual Citizen

    The U.S. dropped a claim seeking to recover foreign bank account reporting penalties from a dual citizen of Mexico while continuing to press for $100,000 in reporting penalties against the woman's husband, a green card holder, according to a California federal court.

  • May 24, 2023

    Md. Man, US Ask Judge To Approve $631K In FBAR Penalties

    A Maryland man will become liable for $631,000 in penalties for willfully failing to file reports of foreign bank accounts if a federal judge approves a judgment he and the government proposed Wednesday.

  • May 24, 2023

    Swiss Open Consultation On Minimum Tax Procedures

    Switzerland's governing council on Wednesday outlined steps for administering the 15% global corporate minimum tax and invited the public to comment on the plan until September.

  • May 24, 2023

    RI Woman Owes $89K In FBAR Penalties, Court Told

    A Rhode Island woman owes nearly $89,000 for failing to properly disclose her Russian and French bank accounts for six years, the U.S. government told a federal court Wednesday.

  • May 23, 2023

    IRS Clarifies Foreign Partner Liabilities On Certain Stock Sales

    A foreign partner is subject to tax on gains when a partnership sells stock in a regularly traded corporation if the partner owns 5% or more of the stock through its stake in the partnership, according to an Internal Revenue Service memo.

  • May 23, 2023

    Co. Had Nexus With Detroit For Taxes, City Tells Mich. Court

    A holding company that sold its interest in a Canadian-based tobacco testing company had "substantial and continuous" business activities in Detroit that allow the city to impose withholding tax on it, the city told the Michigan Court of Appeals.

  • May 23, 2023

    Mont. Eliminates Corp. Tax Havens Under Water's-Edge Laws

    Montana updated statutes governing a so-called water's-edge election for corporate income tax purposes, eliminating a list of countries considered tax havens from income and apportionment factors, under a bill signed by the governor.

Featured Stories

  • Pressure For Corp. Tax Transparency May Just Be Beginning

    Natalie Olivo

    Shareholders of major U.S. corporations increasingly are pushing for tax transparency, and while proposals haven't yet passed, calls for disclosure may continue to grow if asset managers believe the information could help them safeguard against potential risks to their investments.

  • Cost Puzzle Poses Hurdle To Claiming Bonus Energy Credits

    Kat Lucero

    Developers of clean energy projects may face challenges claiming the bonus tax credits available for sourcing key materials in the U.S. because recent guidance calls for using certain manufacturing costs — which are often confidential or not readily available — in determining their eligibility.

  • Spain Seen Preparing Ambitious Tax Agenda As EU Chair

    Todd Buell

    Spain is expected to pursue an ambitious tax policy agenda for its six-month stint leading meetings of European Union ministers, as it will try to move through an ever-growing list of tax proposals, observers say.

Expert Analysis

  • How Foreign Info Return Penalty Case May Benefit Taxpayers

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    The U.S. Tax Court's recent decision that the Internal Revenue Service cannot penalize taxpayers for failing to file foreign corporation information returns may give similarly situated taxpayers an opportunity to also avoid penalties, provided they protect their rights before the decision is overturned or mooted by legislation, say attorneys at Arnold & Porter.

  • The Nuts And Bolts Of IRS Domestic Content Tax Credit

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    Recent IRS guidance provides specifics on how renewable energy projects can qualify for bonus tax credits by meeting U.S. domestic content rules, but also creates a qualification framework that will be complicated for project developers to navigate, say Scott Cockerham and Wolfram Pohl at Orrick.

  • Taxing The Digital Economy: The Good, The Bad And The Ugly

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    U.S. tech companies should watch for important developments in international taxation, including the resolution of Apple's decade-old state aid case, growing frustration with the Organization for Economic Cooperation and Development's global tax plan and adoption of the digital services tax instead, says Joyce Beebe at Rice University's Baker Institute for Public Policy.

  • Big Tax Changes For Multinational Cos. In Budget Proposal

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    The Biden administration’s fiscal year 2024 budget proposes changes that would materially alter decades-old Internal Revenue Code provisions, requiring a shift in multinational corporations' tax planning strategies comparable to that required after enactment of the Tax Cuts and Jobs Act, say Xenia Garofalo and Kyle Colonna at Eversheds Sutherland.

  • Senate Credit Suisse Report Puts Attention On Banks, Trusts

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    The Senate Finance Committee's recent finding that Credit Suisse violated a plea agreement struck over its role in enabling offshore tax evasion has important ramifications for banks and trusts, including how they onboard, document and report on transactions relevant to U.S. reporting requirements, say Will Barry and Ian Herbert at Miller & Chevalier.

  • Seeking IRS Accountability For Faulty Microcaptive Notice

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    Like the taxpayers in Standard Insurances v. U.S. seeking to expand earlier wins in microcaptive insurance cases that limit IRS use of improperly obtained information, others should consider ways to hold the agency accountable and provide incentive for it to follow the law going forward, says Joshua Smeltzer at Gray Reed.

  • Biden Admin. Proposals Both Encourage And Thwart EV Adoption

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    While the Biden administration has been aggressively focused on promoting electric vehicles from the start, its recently issued guidance on EV tax credits and its restrictive new auto emissions proposal create a sense of implementation whiplash that may frustrate manufacturers and consumers, says Levi McAllister at Morgan Lewis.

  • The Key Issues Keeping Transfer Pricing A Top Tax Concern

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    Several challenges preventing a global economic reemergence from the pandemic era are making practitioners reevaluate commonly used transfer pricing models, and embrace new technologies and ways of doing business, say Farnaz Amini and Sophia Castro Jurado at Marcum.

  • Curtailing Offshore Tax-Advantaged Investment In China

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    The U.S. government's plans to establish a new outbound investment regime hold the potential to arrest Chinese companies' increasing use of offshore, tax-advantaged locations to raise capital, says David Plotinsky at Morgan Lewis.

  • Cos. May Want To Wait Out US-EU Green Incentives Fight

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    As the European Union considers measures to compete with the Inflation Reduction Act's incentives for U.S. production of clean tech, and EU and U.S. officials discuss a possible compromise, companies in the green sector should consider taking a wait-and-see approach to investment decisions, says Todd Thacker at Goldberg Segalla.

  • India's Budget Proposals May Ease Entry For Certain Sectors

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    India’s recently released budget includes proposals to facilitate doing business in Gujarat International Finance Tec-City and moderate thousands of compliance requirements, opening up new opportunities for foreign businesses in the digital infrastructure, manufacturing and renewable energy sectors, say Mukesh Butani and Seema Kejriwal at BMR Legal.

  • High Court Ax Of Atty-Client Privilege Case Deepens Split

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    The U.S. Supreme Court's recent dismissal of In re: Grand Jury as improvidently granted maintains a three-way circuit split on the application of attorney-client privilege to multipurpose communications, although the justices have at least shown a desire to address it, say Trey Bourn and Thomas DiStanislao at Butler Snow.

  • US-India Advance Pricing Resolutions Should Reassure Cos.

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    The United States' and India's tax authorities' recent resolution of a significant number of pending advance pricing agreements should reduce taxpayer uncertainty, reassure companies of the nations' good working relationship and improve India's investment environment, say Miller Williams and Caroline Setliffe at Eversheds Sutherland.