International

  • May 20, 2022

    Group Blasts Global Tax Deal's Financial Services Exclusion

    Draft rules implementing the global tax overhaul agreement increasingly appear to be designed in a way that neutralizes their effectiveness, an organization representing developing countries said in its response to a public comment period that ended Friday.

  • May 20, 2022

    Indian High Court Says Advisory Unit Can't Require Import Tax

    A tax council that advises India's government can't require payment of taxes by domestic importers on shipping costs for their goods, the Supreme Court of India ruled, rejecting the government's argument that it was bound by the council's recommendations.

  • May 20, 2022

    Tech Trade Group Warns UK To Abandon Online Sales Tax

    Moving forward with an online sales tax in the U.K. would risk undermining an international agreement to overhaul the global tax system, a trade association for technology and telecommunications warned.

  • May 20, 2022

    Trade Group Urges Broader Biz Exclusions In Global Tax Deal

    A proposal to exclude the earnings of some financial service providers from the agreement to overhaul the international tax system should encompass additional types of businesses, an international business trade association said.

  • May 20, 2022

    Taxation With Representation: Latham, Cravath, Kirkland

    In this week's Taxation With Representation, the Carlyle Group struck a deal to buy ManTech, SMBC Aviation Capital is buying Goshawk Aviation, and Colgate Energy Partners III plans to combine with Centennial Resource Development through a merger of equals.

  • May 20, 2022

    Netflix Paying $58.9M To Settle Italian Tax Dispute

    Netflix will pay €55.8 million ($58.9 million) to the Italian government to settle an investigation by a Milan prosecutor into alleged tax avoidance between 2015 and 2019, a company spokesperson confirmed Friday.

  • May 20, 2022

    German Finance Minister Hopes For Minimum Tax Deal Soon

    Germany's finance minister said Friday that he hopes the European Union will soon reach an agreement on a minimum tax directive that is currently blocked in the EU's council of member countries.

  • May 19, 2022

    Switzerland May Expand Tax Information Exchange Network

    Switzerland would exchange taxpayer information with 12 additional countries under a proposal being sent to Swiss lawmakers by the government's council of executive leaders.

  • May 19, 2022

    UK Contractor In Avoidance Scheme Denied Payroll Credit

    A British information technology contractor who participated in a tax avoidance scheme cannot claim deductions based on his employer's share of payroll taxes to reduce his £80,000 ($110,000) tax bill, an appeals court ruled.

  • May 19, 2022

    EU Asks Germany To Amend Pension Tax Law

    The European Commission said Thursday that it is asking Germany to amend a provision of its social security law for residents working abroad to allow them to make voluntary state pension contributions.

  • May 19, 2022

    Uzbekistan Joins OECD Tax Forum On Transparency

    Uzbekistan has joined the 160-plus-member Organization for Economic Cooperation and Development forum responsible for enacting international tax transparency standards, the OECD announced Thursday.

  • May 19, 2022

    IRS Memo Reverses Agency Position On FDII Calculation

    The Internal Revenue Service updated internal guidance for how the agency should account for deferred compensation expenses for purposes of calculating the deduction available for foreign-derived intangible income.

  • May 19, 2022

    UK Eyes Extension Of Hybrid Mismatch Exemption

    The U.K. is weighing the renewal of an exemption from rules against so-called hybrid mismatch arrangements now that it can ignore a European Union directive phasing out the tax break, draft regulations published Thursday show.

  • May 19, 2022

    Workers' Leave-Based Donations For Ukraine To Be Untaxed

    Employees who waive their vacation time or other paid time off in exchange for their employers making donations to Ukrainian causes in light of the Russian war will not owe tax on those donations, according to IRS guidance released Thursday.

  • May 19, 2022

    EU Parliament Backs Minimum Tax In Advisory Vote

    The European Parliament overwhelmingly backed the application in the European Union of a global minimum corporate tax in an advisory vote Thursday, adding pressure to Poland to lift its veto on the measure.

  • May 18, 2022

    Fla. District Court Says It Still Has Say In FBAR Penalty Fight

    A Florida man still faces penalties originally set at $18 million for not reporting foreign bank accounts, a federal district court ruled, saying it retained jurisdiction even after a circuit court remand for the Internal Revenue Service to recalculate penalties.

  • May 18, 2022

    Resident's Foreign Pension Ruled Tax-Exempt In Ireland

    An Irish resident is eligible for a tax exemption on foreign pension payments, the Irish Tax Appeals Commission ruled.

  • May 18, 2022

    Hone Maxwell Opens Office In Tijuana, Mexico

    California-based Hone Maxwell LLP has opened a new office in Tijuana, Mexico, to service tax and business clients, the firm announced.

  • May 18, 2022

    Citing Pandemic, Taiwan Extends Common Reporting Deadline

    Because of the COVID-19 pandemic, financial institutions in Taiwan now have a month longer, through Aug. 1, to file account-holder information to be exchanged with other countries, according to a government news release published Wednesday.

  • May 18, 2022

    Wyden Probes Formula Maker's Stock Buybacks Amid Shortage

    Abbott Laboratories helped trigger a baby formula shortage by apparently neglecting the state of its manufacturing infrastructure as it spent billions on stock buybacks, Senate Finance Committee Chair Ron Wyden said Wednesday, initiating an investigation into the company's tax practices.

  • May 18, 2022

    EU To Propose Scrapping VAT On Joint Defense Procurement

    The European Commission plans this fall to propose removing value-added tax from military equipment jointly procured by European Union member countries, commission President Ursula von der Leyen said Wednesday.

  • May 18, 2022

    UK Tories Won't Rule Out Energy Windfall Tax

    British Prime Minister Boris Johnson maintained opposition Wednesday to a windfall tax on unusually profitable oil and gas producers — a measure designed to reinvest in a program to push down rising consumer bills — but avoided ruling the measure out entirely.

  • May 18, 2022

    US Asks Justices To Weigh In On FBAR Max Penalty Dispute

    The federal government urged the U.S. Supreme Court to clear up a circuit split over the maximum assessable foreign bank account reporting penalty, arguing the $10,000 penalty should be imposed on a per-account basis rather than for each unfiled form.

  • May 18, 2022

    Poland's Min. Tax Objection Toes Line Between Policy, Politics

    Poland's objection to a European Union directive that would implement a minimum corporate rate under the Organization for Economic Cooperation and Development's global tax overhaul is blurring lines between political and policy concerns, tax observers say.

  • May 18, 2022

    France Targets June 17 For EU Minimum Tax Deal

    France is eyeing June 17 as the date on which European Union finance ministers will reach unanimous agreement on an internationally agreed-upon minimum tax, the country's finance minister said in remarks confirmed by his office Wednesday.

Featured Stories

  • Poland's Min. Tax Objection Toes Line Between Policy, Politics

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    Poland's objection to a European Union directive that would implement a minimum corporate rate under the Organization for Economic Cooperation and Development's global tax overhaul is blurring lines between political and policy concerns, tax observers say.

  • GILTI Sticking Points May Emerge In Global Min. Tax Rules

    Natalie Olivo

    The current language of an international minimum tax agreement may leave room for countries to arrive at their own technical interpretations about how to treat the U.S. measure for global intangible low-taxed income, particularly if Congress doesn't enact key changes.

  • EU Unlikely To Shed Unanimity Requirement For Tax Changes

    Todd Buell

    The European Union's rules that require unanimous agreement among member countries on matters of tax policy are unlikely to change despite calls from politicians and citizens to end the practice.

Expert Analysis

  • Global Tax Chiefs Should Look To US Whistleblower Programs

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    As the Joint Chiefs of Global Tax Enforcement develops its international whistleblower program to address tax evasion and money laundering schemes in new areas like cryptocurrency, it should take lessons from highly successful U.S. programs on which features to include and pitfalls to avoid, say Neil Getnick and Nico Gurian at Getnick & Getnick.

  • What Microcaptive Reporting Ruling May Mean For The IRS

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    In CIC v. Internal Revenue Service, a Tennessee federal court’s decision to set aside an IRS requirement to disclose microcaptive insurance arrangements may be a step toward evidentiary standards to show that the potential for abuse in a lawful transaction is sufficient to support heightened disclosure requirements, says Samuel Lauricia at Weston Hurd.

  • US Should Leverage Tax Rules To Deter Business With Russia

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    The U.S. should further restrict the flow of resources available for the Putin regime's war in Ukraine by denying U.S. businesses that operate in Russia or Belarus foreign tax credits and global intangible low-taxed income preferences, and by terminating its tax treaty with Russia, says Reuven Avi-Yonah at University of Michigan Law School.

  • US Investors Stand To Benefit From Brazil's New Forex Law

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    Brazil's New Foreign Exchange Law facilitates negotiations and reduces bureaucracy for foreign investments, making it a good time for U.S. investors looking for projects with a positive environmental, social and governance impact to allocate funds to Brazilian energy and infrastructure, say Jorge Kamine and Juliana Pimentel at Willkie.

  • A Landmark UK Enforcement Case For Crypto-Assets

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    HM Revenue and Customs' recent seizure of nonfungible tokens from three people under investigation for value-added tax fraud promises to be the first of many such actions against crypto-assets, so investors should preemptively resolve potential tax matters with U.K. law enforcement agencies to avoid a rude awakening, says Andrew Park at Andersen.

  • Simplifying Tax Issues For Nonresident Athletes In Canada

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    Tax compliance can be particularly challenging for nonresident professional athletes playing in Canada, but as NHL contract negotiations approach a close, it's worth looking at some ways the tax burden can be mitigated, say Marie-France Dompierre and Marc Pietro Allard at Davies Ward.

  • Steps For Universities As DOJ Shifts Foreign Influence Policy

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    Notwithstanding Wednesday's U.S. Department of Justice announcement terminating the initiative targeting Chinese influence and raising the bar for criminal prosecutions, universities should ensure their compliance controls meet new disclosure standards and that they can efficiently respond to inquiries about employees' foreign connections, say attorneys at Covington.

  • Corporate Reporting Considerations As Tax Meets ESG

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    With the U.S. Securities and Exchange Commission filing season upon us amid increasing pressure for greater transparency around effective tax rates and tax strategies, multinational companies must decide how they will approach voluntary tax reporting and prepare their responses if they want to control the narrative, say Michael Lebovitz and Jenny Austin at Mayer Brown.

  • The Highs And Lows Of Tax Controversy In 2021

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    Lawrence Hill at Steptoe & Johnson reviews the ups and downs of tax controversy practice in 2021, including the continued effects of the pandemic, troubling decisions on attorney-client privilege and an IRS comeback on transfer pricing.

  • Lessons From IRS For A New HMRC Whistleblowing Model

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    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.

  • The Benefits Of Competent Authority In Int'l Tax Disputes

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    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.

  • How OECD Transfer Tax Initiative Affects Smaller Businesses

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    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.

  • What The New OECD Double-Tax Procedure Statistics Tell Us

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    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.