International
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.

Pressure For Corp. Tax Transparency May Just Be Beginning
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
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.

Belgian Ministry May Appeal Ban On FATCA Data Transfers
Belgium's finance ministry may or may not appeal a decision by the country's data protection agency forbidding transfers of information about Americans there to the IRS under the Foreign Account Tax Compliance Act, a ministry spokeswoman told Law360 Thursday after a ministry lawyer said the appeal would happen.
Featured Stories
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Pressure For Corp. Tax Transparency May Just Be Beginning
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.
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Cost Puzzle Poses Hurdle To Claiming Bonus Energy Credits
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.
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Spain Seen Preparing Ambitious Tax Agenda As EU Chair
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
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How Foreign Info Return Penalty Case May Benefit Taxpayers
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.
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The Nuts And Bolts Of IRS Domestic Content Tax Credit
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.
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Taxing The Digital Economy: The Good, The Bad And The Ugly
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.
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Big Tax Changes For Multinational Cos. In Budget Proposal
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.
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Senate Credit Suisse Report Puts Attention On Banks, Trusts
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.
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Seeking IRS Accountability For Faulty Microcaptive Notice
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.
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Biden Admin. Proposals Both Encourage And Thwart EV Adoption
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.
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The Key Issues Keeping Transfer Pricing A Top Tax Concern
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.
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Curtailing Offshore Tax-Advantaged Investment In China
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.
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Cos. May Want To Wait Out US-EU Green Incentives Fight
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.
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India's Budget Proposals May Ease Entry For Certain Sectors
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.
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High Court Ax Of Atty-Client Privilege Case Deepens Split
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.
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US-India Advance Pricing Resolutions Should Reassure Cos.
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.