International

  • April 22, 2024

    Finland Discovers €30M In Undeclared Crypto Profits

    Finnish taxpayers made at least €30 million ($32 million) in undeclared cryptocurrency trade profits in 2022, Finland's tax authority said Monday, reminding taxpayers to include such profits in their filings this year.

  • April 22, 2024

    UAE Considering R&D Tax Break, Seeks Feedback

    The United Arab Emirates is seeking public input to help design a possible research and development tax incentive proposal to help drive innovation and growth, its Ministry of Finance said.

  • April 22, 2024

    Austria Eatery Busted 2nd Time On Tax Evasion Suspicion

    A Chinese restaurant in Austria was busted for a second time on suspicion of evading taxes, this time in the amount of €135,000 ($144,000), the country's finance minister announced, declaring that "the Austrian state cannot be an 'all you can eat' buffet for tax fraudsters."

  • April 22, 2024

    EU Probes Tax Breaks To Chinese Solar Panel Companies

    The European Commission has started two investigations into suspected tax breaks and other possibly illegal foreign subsidies to Chinese solar panel companies bidding for public contracts in Romania, notices in the EU's Official Journal showed Monday.

  • April 19, 2024

    KPMG Supports Aussie Pillar 2 Plan, With Reservations

    KPMG supports Australia's plans to implement the OECD's Pillar Two global minimum corporate tax plan in principle, the accounting firm said Friday, but it has some concerns, including with how often the government diverts from the organization's wording.

  • April 19, 2024

    UN Should Eye Unitary Taxes, DSTs For Tax Pact, Report Says

    Governments should use the United Nations tax convention as an opportunity to advance the overhaul of nexus away from transfer pricing and toward formulary apportionment, including digital services taxes, to achieve unitary taxation on corporate profits, scholars at the Brookings Institution said Friday in a report.

  • April 19, 2024

    UK Tax Pros Worried Public Unaware Of Crypto Tax Liabilities

    With the growing interest in crypto-asset trading, a group representing tax professionals in the U.K. said Friday that it is concerned HM Revenue & Customs isn't doing enough to make the public aware of its tax obligations, particularly with the lowered capital gains exemption.

  • April 19, 2024

    IRS Previews New Digital Assets Reporting Form

    The Internal Revenue Service released a draft of a form brokers will have to use for the first time to disclose their digital asset sales to the agency, including instructions for taxpayers whose transactions are subject to the reporting requirements. 

  • April 19, 2024

    DC Circ. Gives Expat's Challenge To GILTI Another Chance

    A D.C. federal court was wrong to dismiss an expatriate attorney's challenge to the global intangible low-taxed income regulations without addressing his argument that he had no other legal avenue, the D.C. Circuit said Friday as it remanded the case to the lower court.

  • April 19, 2024

    Polsinelli Adds Shareholder To Tax Credit Practice In Dallas

    An attorney who spent more than a decade developing a niche practice specializing in tax credit financing has moved her practice to Polsinelli PC's Dallas office after five years at Munsch Hardt Kopf & Harr PC.

  • April 19, 2024

    India Signs Record Amount Of Advance Pricing Agreements

    India's Central Board of Direct Taxes entered into a record 125 advance pricing agreements with Indian taxpayers in fiscal year 2023-24, a 31% increase compared with the previous year, the authority said.

  • April 19, 2024

    Taxation With Representation: Kirkland, Cleary, O'Melveny

    In this week's Taxation With Representation, Resideo Technologies Inc. announced plans to buy Snap One Holdings Corp., APi Group said it bought an elevator maintenance company, Prysmian said it agreed to purchase Encore Wire, and Sayari said it closed on an investment from TPG.

  • April 19, 2024

    Questions Loom Over China's Pillar 2 Participation

    Practical and political problems surrounding the Organization for Economic Cooperation and Development's 15% global minimum corporate tax raise questions about how China and its biggest companies could undermine that regime.

  • April 19, 2024

    EU Official Pushes Automatic Exchange Of Ownership Data

    The automatic exchange of companies' beneficial ownership information would be a powerful tool for tax authorities and should be a future goal for governments, a senior European Union tax official said Friday. 

  • April 18, 2024

    Estonian Tax System's Ease Key To Success, Bank Head Says

    The tax system in Estonia — ranked the top country for international tax competitiveness by the Tax Foundation — is fair and easy to administer, which is key to the country's tax administration successes, the governor of the Bank of Estonia said Thursday.

  • April 18, 2024

    AbbVie Can't Get Deduction For $1.6B Merger Fee, IRS Says

    The IRS defended its denial of AbbVie's claimed deduction for a $1.6 billion payment to a biotechnology company over their failed merger, telling the U.S. Tax Court that the pharmaceutical giant is misconstruing an underlying statute to challenge the agency's decision.

  • April 18, 2024

    IRS Updates Rates For Foreign Insurance Company Equations

    The Internal Revenue Service published updated domestic asset/liability and yields percentages Thursday that foreign life insurance companies as well as foreign property and liability insurance companies need to compute their minimum effectively connected net investment income for tax years starting in 2023.

  • April 18, 2024

    Pawn Shop Owes VAT On Auction Sales, EU Court Says

    A Portuguese pawn shop must pay value-added taxes of €308,000 ($327,000) from sales commissions of auctioned items because the auction is not part of the exempt loan, the Court of Justice of the European Union said Thursday.

  • April 18, 2024

    EU Split Stops Move Toward Corporate Tax Harmonization

    A group of smaller European Union countries stopped a move toward harmonization of national corporate taxes when EU leaders met Thursday to discuss ways to promote investments in European businesses.

  • April 18, 2024

    $32B More In Tax Yielded In Fiscal '23 Closed Audits, IRS Says

    The Internal Revenue Service closed nearly 583,000 tax return audits in fiscal year 2023, resulting in $31.9 billion of recommended additional tax after examination, the agency said Thursday in its annual data book.     

  • April 18, 2024

    Tax Deadline Near For Irish Corporate Warehoused Debt

    Companies in Ireland taking advantage of the country's debt warehousing regime are encouraged to meet with the tax department ahead of a May 1 deadline to arrange agreements to pay off their liabilities, the country's finance minister said.

  • April 18, 2024

    HMRC Opens Consultation On Payroll Tax In Freeports

    The U.K. tax authority is mulling changes to National Insurance, a payroll levy used to fund state pensions and healthcare, for employees working in special economic zones known as freeports.

  • April 18, 2024

    Transfer Pricing And Dancing: Recalling KPMG's Sean Foley

    Sean Foley, who died suddenly in September, was a devoted husband, father, brother and friend and a brilliant colleague. He was one of the world's top experts in an area of international tax known as transfer pricing, where he became the global leader of KPMG's practice.

  • April 18, 2024

    UN Tax Work Should Be Consensus-Driven, EU Official Says

    The work on international taxation at the United Nations should be driven by consensus, as otherwise, whatever agreement comes out of the process won't be accepted globally, a senior European Union tax official said Thursday.

  • April 17, 2024

    EV Tax Credit Restrictions, Trade Bills Advance In House

    The House Ways and Means Committee advanced several trade bills Wednesday that would impose more restrictions for new electric vehicles to qualify for a federal tax credit, assert congressional authority in agreements with foreign governments, and renew the country's largest and oldest trade preferences program.

Expert Analysis

  • 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.

  • Stock Buyback Excise Tax Guidance A Mixed Bag For SPACs

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    Recent IRS guidance on the new stock repurchase excise tax includes a welcome exception for publicly traded special-purpose acquisition companies but does not exclude redemptions in connection with a de-SPAC transaction, and further guidance is needed to clarify ambiguities around the exception's application, say Olga Bogush and Evgeny Magidenko at ArentFox Schiff.

  • The IRS' APA Rulemaking Journey: There And Back Again

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    Attorneys at Dentons examine recent challenges in which taxpayers successfully argued Internal Revenue Service rulemaking was invalid under the Administrative Procedure Act, how tax exceptionalism and U.S. Supreme Court regulatory deference prompted such challenges, and similar challenges the agency will likely face following this line of cases.

  • ECJ Fiat Ruling Sets Clear Boundaries For EU State Aid Law

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    The European Court of Justice's recent landmark decision in Fiat v. Commission limiting the commission’s attempts to circumvent the lack of EU powers in the area of tax law has important implications in EU state aid law and beyond, say Andreas Reindl and Pietro Stella at Van Bael.

  • Unpacking The Interim Guidance On New Stock Buyback Tax

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    The U.S. Department of the Treasury and Internal Revenue Service's recent notice on applying the newly effective excise tax on stock repurchases provides much-needed clarity on the tax's scope, which is much broader than anticipated given its underlying policy rationale, say attorneys at Eversheds Sutherland.

  • IRS Will Use New Resources To Increase Scrutiny In 2023

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    The new year promises to be a busy one for the Internal Revenue Service, which is poised to apply the boost in funding provided by the Inflation Reduction Act to bolster and expand its enforcement capability, and there are four areas to watch, say attorneys at Skadden.

  • How Japan's Implementation May Change The Pillar 2 Debate

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    Japan’s outline of proposed legislation adopting a primary component of the Organization for Economic Cooperation and Development's 15% global minimum tax will increase pressure on countries — including the U.S. — that have not committed to adopting Pillar Two, says Takato Masuda of Nishimura & Asahi.

  • Foreign Tax Credit Proposal Is Some Help, But More Is Needed

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    New foreign tax credit regulations proposed by the U.S. Treasury Department provided some measure of relief on cost recovery and royalty withholding, two of the most troublesome aspects of the 2021 final foreign tax credit regulations, but the final regulations are still harmful to many taxpayers, making litigation inevitable, say attorneys at Fenwick.

  • IRS' Tax Gap Statistics Don't Paint A Full Compliance Picture

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    The Internal Revenue Service's recent report indicating a widening tax gap sheds important light on tax compliance, underlines key pressure points and provides insights into how tax administration could be improved; but tax gap estimates also have their limits, says Joyce Beebe at Rice University.

  • How High Court Could Change FBAR Penalty Landscape

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    On Wednesday, the U.S. Supreme Court will hear Bittner v. U.S., a case that will affect many people penalized for failing to file a Report of Foreign Bank and Financial Accounts, and there are important procedural implications should the government's position be reversed, say Reuben Muller and Andreas Apostolides at Cole Schotz.

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