International

  • May 03, 2024

    Finland's Stance On Swiss Treaty Recalls Ended Portugal Deal

    Finland's plan to renegotiate its tax treaty with Switzerland in response to concerns about pension tax avoidance has some observers worried that the country will cancel that accord as it did a treaty with Portugal in recent years.

  • May 03, 2024

    Taxation With Representation: Skadden, Wachtell, Davis Polk

    In this week's Taxation With Representation, L'Occitane International said its executive director and chair is leading an offer to buy the company's shares he doesn't already own, UMB Financial agreed to purchase Heartland Financial USA, Medline said it agreed to acquire Ecolab's global surgical solutions business and The Mosaic Co. said it agreed to sell its stake in a phosphate production joint venture.

  • May 03, 2024

    IRS Can Assess Foreign Info Disclosure Penalty, DC Circ. Says

    The D.C. Circuit on Friday overturned a major U.S. Tax Court ruling that had struck down the Internal Revenue Service's authority to assess and administratively collect penalties from taxpayers for failing to file an information return on their interests in a foreign corporation.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

Expert Analysis

  • Attorneys, Law Schools Must Adapt To New Era Of Evidence

    Author Photo

    Technological advancements mean more direct evidence is being created than ever before, and attorneys as well as law schools must modify their methods to account for new challenges in how this evidence is collected and used to try cases, says Reuben Guttman at Guttman Buschner.

  • 1st Tax Easement Convictions Will Likely Embolden DOJ, IRS

    Author Photo

    After recent convictions in the first criminal tax fraud trial over allegedly abusive syndicated conservation easements, the IRS and U.S. Department of Justice will likely pursue other promoters for similar alleged conspiracies — though one acquittal may help attorneys better evaluate their clients' exposure, say Bill Curtis and Lauren DeSantis-Then at Polsinelli.

  • Tips For Litigating Against Pro Se Parties In Complex Disputes

    Author Photo

    Litigating against self-represented parties in complex cases can pose unique challenges for attorneys, but for the most part, it requires the same skills that are useful in other cases — from documenting everything to understanding one’s ethical duties, says Bryan Ketroser at Alto Litigation.

  • Anticipating Intensified Partnership Enforcement From IRS

    Author Photo

    The Internal Revenue Service's decadeslong difficulties with partnership audits led to the recent announcement of a clear, well-funded, focused initiative, and businesses operating in the partnership form will feel the impact, with definite changes ahead, says Sharon Katz-Pearlman at Greenberg Traurig.

  • Pro Bono Work Is Powerful Self-Help For Attorneys

    Author Photo

    Oct. 22-28 is Pro Bono Week, serving as a useful reminder that offering free legal help to the public can help attorneys expand their legal toolbox, forge community relationships and create human connections, despite the challenges of this kind of work, says Orlando Lopez at Culhane Meadows.

  • The Pop Culture Docket: Judge Espinosa On 'Lincoln Lawyer'

    Author Photo

    The murder trials in Netflix’s “The Lincoln Lawyer” illustrate the stark contrast between the ethical high ground that fosters and maintains the criminal justice system's integrity, and the ethical abyss that can undermine it, with an important reminder for all legal practitioners, say Judge Adam Espinosa and Andrew Howard at the Colorado 2nd Judicial District Court.

  • How And Why Your Firm Should Implement Fixed-Fee Billing

    Author Photo

    Amid rising burnout in the legal industry and client efforts to curtail spending, pivoting to a fixed-fee billing model may improve client-attorney relationships and offer lawyers financial, logistical and stress relief — while still maintaining profit margins, say Kevin Henderson and Eric Pacifici at SMB Law Group.

  • How Law Firms Can Use Account-Based Marketing Strategies

    Author Photo

    Amid several evolving legal industry trends, account-based marketing can help law firms uncover additional revenue-generating opportunities with existing clients, with key considerations ranging from data analytics to relationship building, say Jennifer Ramsey at stage LLC and consultant Gina Sponzilli.

  • Strategic Succession Planning At Law Firms Is Crucial

    Author Photo

    Senior partners' reluctance to retire, the rise of the nonequity partner tier and generational differences in expectations are all contributing to an increasing number of departures from BigLaw, making it imperative for firms to encourage retirement among senior ranks and provide clearer leadership pathways to junior attorneys, says Laura Leopard at Leopard Solutions.

  • Maximizing Law Firm Profitability In Uncertain Times

    Author Photo

    As threats of an economic downturn loom, firms can boost profits by embracing the power of bottom-line management and creating an ecosystem where strategic financial oversight and robust timekeeping practices meet evolved client relations, says Shireen Hilal at Maior Strategic Consulting.

  • 5th Circ. Ruling Reminds Attys That CBP Can Search Devices

    Author Photo

    The Fifth Circuit’s recent Malik v. Department of Homeland Security decision adds to the chorus of federal courts holding that border agents don’t need a warrant to search travelers’ electronic devices, so attorneys should consider certain special precautions to secure privileged information when reentering the U.S., says Jennifer Freel at Jackson Walker.

  • Enforcement Of International Tax Reporting Is Heating Up

    Author Photo

    Since the U.S. Supreme Court’s February decision in Bittner v. U.S. changed how penalties for failure to report offshore accounts are calculated, recent developments suggest the government is preparing to step up enforcement and vigorously pursue the collection of resulting penalties, say Daniel Silva and Agustin Ceballos at Buchalter.

  • IRS Notice Clarifies R&E Amortization, But Questions Remain

    Author Photo

    The IRS and Treasury Department’s recent notice clarifying the treatment of specified research and experimental expenditures under Section 174 provides taxpayers and practitioners with substantive guidance, but it misses the mark in delineating which expenditures are amortizable, say attorneys at Eversheds Sutherland.

Can't find the article you're looking for? Click here to search the Tax Authority International archive.