International

  • April 25, 2024

    Ministers From 4 Countries Back Billionaire Tax

    Government ministers from Germany, Spain, South Africa and Brazil said Thursday that they have backed a global plan to ensure that billionaires pay a minimum amount of tax, arguing that the move is necessary to make the tax system more equitable.

  • April 24, 2024

    EU Court Won't Disturb Spanish Tax Break Rulings

    A Spanish company on Wednesday lost its attempt to legitimize a tax scheme declared illegal by the European Commission when the European Union's General Court rejected its appeal, refusing to disturb prior decisions in the long-running dispute.

  • April 24, 2024

    GOP Reps Seek IRS Nonprofit Info After China Reports

    House Ways and Means Republicans asked the Internal Revenue Service to provide information about how it monitors tax-exempt organizations for possible violations of their status after reports China may be funding and improperly influencing nonprofits, according to a letter sent Wednesday.

  • April 24, 2024

    Treasury Limits Reach Of Look-Through Rule In Final Regs

    The U.S. Treasury Department finalized regulations Wednesday that retain but narrow the scope of a proposal to, in a manner of speaking, look through the corporate owners of real estate investment entities to determine whether they are domestically controlled.

  • April 24, 2024

    Tax Pros Suggest How HMRC Can Assess Digitalization Effort

    HM Revenue & Customs should abide by a set of benchmarks when evaluating tests of its digitalization program for income tax self-assessment forms, two groups representing U.K. tax professionals said.

  • April 24, 2024

    Ex-England Footballer Banned As Director For Unpaid Tax

    Former England football international John Barnes has been banned from being a company director after his business failed to pay more than £190,000 ($236,000) in tax, a U.K. government agency announced on Wednesday.

  • April 24, 2024

    Papua New Guinea Commits To Automatic Tax Info Exchange

    Papua New Guinea has committed to enacting the Organization for Economic Cooperation and Development's standard for automatic exchange of financial account information in tax matters by September 2027, the OECD said Wednesday.

  • April 24, 2024

    EU Keeps Gibraltar, Panama, UAE On AML Blacklist

    Gibraltar, Panama and the United Arab Emirates should remain on the European Union's blacklist of high-risk countries for money laundering, the European Parliament said, stopping the EU from following the lead of a global organization promoting standards for countries to fight those crimes.

  • April 24, 2024

    EU Expected To OK Withholding Tax, Digital VAT Laws In May

    European Union finance ministers are expected to agree on a new withholding tax refund law and a package to modernize value-added tax reporting at their May 14 meeting, an EU official said Wednesday, speaking on the condition of anonymity.

  • April 24, 2024

    EU Says 3 States Aren't Correctly Following AML Law

    The European Commission said Wednesday that three European Union countries — Ireland, France and Latvia — aren't correctly implementing the bloc's laws against money laundering, meaning that the countries now have two months to correct the shortcomings.

  • April 23, 2024

    Treasury Says Aussie Royalty Ruling Contradicts US, OECD

    Australia's updated draft ruling regarding when payments for the rights to distribute software would be considered royalties conflicts with OECD and U.S. standards on the treatment of such deals, a U.S. Department of the Treasury official said in a letter made public Tuesday.

  • April 23, 2024

    Biz Ownership Law Constitutional, Lawmakers Tell 11th Circ.

    The Corporate Transparency Act is a garden-variety exercise of Congress' powers to address threats to national security, foreign affairs, commerce and tax collection, five Democratic lawmakers told the Eleventh Circuit, disputing a ruling that the law is unconstitutional.

  • April 23, 2024

    DC Circ. Backs Tax Penalties Against Swiss Couple

    A Swiss couple who incurred $500,000 in penalties for failing to report millions of dollars they held in Swiss bank accounts can't get out of paying, the D.C. Circuit ruled Tuesday, rejecting their argument that the IRS didn't properly approve the fines.

  • April 23, 2024

    Int'l Pricing Pact Guidance Is Coming Soon, IRS Official Says

    Updated Internal Revenue Service guidance that would help multinational corporations pursue advance pricing agreements will likely be released in a few months, an agency official said Tuesday.

  • April 23, 2024

    Disney, IBM Stuck With Tax On Royalties, NY Top Court Holds

    New York's highest court rejected Disney and IBM's arguments that the state unconstitutionally denied their attempts to take tax deductions on royalties received from foreign affiliates, holding Tuesday that the law at issue didn't discriminate against interstate commerce.

  • April 23, 2024

    EV Levy Could Blunt Swiss Climate Plan Pains, Report Says

    The first report on the long-term fiscal impact of climate change mitigation measures in Switzerland, released Tuesday, projects a major negative impact on public funds as certain tax sources dry up, but a planned replacement levy on electric vehicles could lessen that effect.

  • April 23, 2024

    Irish Minister Warns Corp. Tax Windfall Still Shrouds Deficit

    Ireland's budget is projected to have an €8.6 billion ($9.2 billion) surplus this year, but the country's finance minister again cautioned Tuesday that without the slowly decreasing windfall corporate tax receipts there would actually be a deficit.

  • April 23, 2024

    Tax Experts Want Cut To Healthcare Insurance Levy

    Tax experts on Tuesday urged the U.K. government to partially suspend a levy on healthcare insurance products, after it revealed record premium tax revenue of £8.1 billion ($10.1 billion) last year.

  • April 23, 2024

    Talk Of Int'l Wealth Tax Fuels Debate On UN Vs. OECD

    Discussion of an international tax on the world's wealthiest individuals has intensified a debate about whether international tax policy would be better steered by the Organization for Economic Cooperation and Development or the United Nations.

  • April 23, 2024

    EU Parliament OKs Extending Duty-Free Imports From Ukraine

    The European Parliament approved the suspension of the European Union's customs duties and quotas on Ukrainian imports into the EU for one year until June 2025 on Tuesday, overcoming discord in March over farm imports that threatened the deal.

  • April 22, 2024

    Scotiabank Fights To Keep Peru VAT Claim Alive

    The Bank of Nova Scotia urged the World Bank's international arbitration institution in recently released documents not to dismiss the arbitration of its value-added tax dispute against Peru, saying the case raises issues of fact.

  • April 22, 2024

    Congress Can Enact Corp. Transparency, Orgs Tell 11th Circ.

    Congress is empowered to require American companies to report their beneficial owners to the federal government because there is ample evidence they've previously been used to fund hostile foreign actors, evade sanctions and traffic drugs, two think tanks told the Eleventh Circuit in an amici brief.

  • April 22, 2024

    Partnership Can't Claim $22.7M Loss, Tax Court Says

    The U.S. Tax Court on Monday upheld the IRS' decision to deny a $22.7 million loss deduction claimed by a Connecticut partnership, finding that underlying transactions involving a bankrupt Brazilian company's debt obligations amounted to a disguised property sale.

  • April 22, 2024

    Sweden Proposes Tax Breaks Ahead Of Budget Negotiations

    The Swedish Finance Ministry proposed adjusting its so-called expert tax incentive, which businesses use to attract external workers, among a series of tax changes offered up Monday.

  • April 22, 2024

    Trader Behind £1.4B Tax Fraud Thought Trades Were Valid

    A British trader accused of being the mastermind of a fraudulent trading scheme that cost Denmark's tax authority £1.4 billion ($1.7 billion) genuinely believed that the trades worked, his lawyer told a London court on Monday.

Expert Analysis

  • What To Make Of IRS' New Advance Pricing Guidance

    Author Photo

    Recent guidance on the IRS' goals for its advance pricing agreement system provides helpful insight into review and decision-making procedures for advance pricing agreement requests, but it also raises questions about the IRS' objectives, say Richard Slowinski and Stefanie Kavanagh at Alston & Bird.

  • Reserved Investor Fund Would Plug Gap In UK Finance Market

    Author Photo

    The reserved investor fund recently proposed by HM Treasury has the potential to be a welcome tax-efficient addition to the U.K.’s canon of products for real estate investments, with attractive features for companies and, in particular, large asset managers, say lawyers at Herbert Smith.

  • The Reciprocal Tax Bill Is A Warning Shot At Pillar 2

    Author Photo

    A bill recently introduced in the House of Representatives to reciprocally tax countries deemed to have imposed discriminatory taxes on U.S. citizens and businesses takes aim at countries implementing the global minimum tax treaty known as Pillar Two, with which the U.S. has not complied, says Alan Cole at the Tax Foundation.

  • What Tax-Exempt Orgs. Need From Energy Credit Guidance

    Author Photo

    Guidance clarifying the Inflation Reduction Act’s credit regime, expected from the U.S. Department of the Treasury this summer, should help tax-exempt organizations determine the benefits of clean energy projects and integrate alternative energy investments into their activities, say attorneys at Morgan Lewis.

  • How Foreign Info Return Penalty Case May Benefit Taxpayers

    Author Photo

    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

    Author Photo

    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

    Author Photo

    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

    Author Photo

    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

    Author Photo

    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

    Author Photo

    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

    Author Photo

    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

    Author Photo

    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

    Author Photo

    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.

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