International

  • April 02, 2024

    Small UK Cos. 'Freed' From VAT Payments By Threshold Rise

    Some 28,000 businesses have been "freed" from paying value-added tax as the registration threshold rose from £85,000 ($106,000) to £90,000 in revenue, HM Treasury has said.

  • April 02, 2024

    Watchdog Probes Norway's Carbon Tax Exemption Measures

    A Norwegian plan to exempt from excise duty waste incineration that is subject to the European Union's emissions trading system and to exempt natural gas, which is also subject to the ETS, from carbon tax is the focus of an investigation into state aid, a watchdog said Tuesday.

  • April 01, 2024

    US Support For Pillar 1 Still In Question After House Inquiry

    U.S. lawmakers signaled that they think technical and other issues remain in the OECD's Pillar One taxing rights overhaul during a recent House subcommittee meeting, casting further doubt on the plan's implementation as the timeline to finalize it has slipped.

  • April 01, 2024

    Berkshire Unit Merits Neb. Deduction, State Justices Told

    Nebraska's deduction for certain dividends should apply to income repatriated under the 2017 federal tax overhaul, an attorney for a Berkshire Hathaway entity told the state Supreme Court on Monday.

  • April 01, 2024

    Liechtenstein Adopts GloBE Rules For Corp. Minimum Tax

    Liechtenstein has supplemented its passage of the Organization for Economic Cooperation and Development's global corporate minimum tax by officially adopting the global anti-base erosion rules, which provide regulations to facilitate the minimum tax.

  • April 01, 2024

    BakerHostetler Adds Partner To Tax Practice Group

    BakerHostetler's Washington office has added a partner from Morris Manning and Martin LLP to join its tax practice group, Baker said in a statement Monday.

  • April 01, 2024

    Baker Donelson Adds EY Tax Pro To Houston Office

    A former EY senior manager has joined Baker Donelson Bearman Caldwell & Berkowitz PC's tax group in Houston as counsel, the firm announced.

  • April 01, 2024

    16 Charged In $12.5M VAT Refund Scheme, Poland Says

    Sixteen people have been charged in a scheme to use forged documents to claim false value-added tax refunds for polymer and steel transactions, causing an estimated 50 million Polish zloty ($12.5 million) in damages, Poland's tax authority said.

  • March 29, 2024

    APA Work Doubled In 2023, IRS Report Says

    The Internal Revenue Service finalized more than twice as many advance pricing agreements for U.S. multinational corporations in 2023 as in the previous year, according to an agency report released Friday.

  • March 29, 2024

    Green Energy Credit Sales Spur Surge In Tax Insurance

    A new way for project owners to monetize clean energy tax credits by selling them for cash has turbocharged demand for insurance policies to cover various risks tied to the transactions, which can often be worth hundreds of millions of dollars.

  • March 29, 2024

    EU OKs Irish Film Tax Credit Cap Increase, Extension

    Ireland is bumping up the cap on its 32% film project tax credit to €125 million ($135 million) and extending the program to the end of 2028 after getting the go-ahead from the European Commission, the country's Department of Finance said Friday.

  • March 29, 2024

    Canada Extends Mineral Exploration Tax Relief To 2025

    A 15% Canadian tax credit for investments in mining activities that was set to expire at the end of the month has been extended to March 2025, the country's Department of Finance said.

  • March 29, 2024

    HMRC Issues Draft R&D Credit Guidance For Overseas Work

    HM Revenue & Customs released draft guidance for complying with new restrictions on tax relief for payments to contractors for research and development, as well as payments for externally provided workers, for R&D activity that takes place abroad.

  • March 28, 2024

    PwC Fined $3M Over Auditor Controls, Australia Probe

    The Public Company Accounting Oversight Board leveled a pair of fines totaling more than $3 million against PwC on Thursday, accusing the Big Four accounting firm of failing to maintain policies to ensure auditor independence and of waiting years to inform the U.S. regulator that it was being investigated in Australia.

  • March 28, 2024

    Corp. Transparency Act Overbroad, Mich. Group Tells Court

    The Corporate Transparency Act is overbroad and violates both the Fourth and Fifth Amendments of the U.S. Constitution, the Small Business Association of Michigan told a federal court in a case similar to one currently in the Eleventh Circuit.

  • March 28, 2024

    Hong Kong Considering Patent Box Tax Regime

    Hong Kong's legislature will soon consider a so-called patent box regime that would establish a 5% tax rate on income derived from intellectual property in the jurisdiction, compared with the normal 16.5% tax rate on nonresident royalty income, the country's Inland Revenue Department said Thursday.

  • March 28, 2024

    Canadian In Wash. Owes Over $1M FBAR Penalty, US Says

    A Canadian man living in Washington state owes more than $1 million in penalties for failing to report bank accounts he held in Montreal, the U.S. Department of Justice said in a complaint filed in an attempt to collect the money.

  • March 28, 2024

    Egypt Tax Info Sharing Only Partially Compliant, OECD Says

    Egypt needs to make "significant improvements" to portions of its exchange of information on request mechanisms to bring it in better compliance with Organization for Economic Cooperation and Development standards, the organization said Thursday.

  • March 28, 2024

    Truck Co. Sues Ex-Boss For £216K Over Tax Dodge Scheme

    A British truck dealership is suing its former managing director for more than £216,000 ($273,000), alleging that he left the company liable for a huge back tax bill by setting up a fraudulent salary sacrifice scheme to rent a house.

  • March 28, 2024

    2nd Circ. Urged To Uphold Dual Citizen's FBAR Penalties

    A New York federal court correctly upheld tax penalties against a dual French citizen for hiding millions of dollars in six foreign accounts, the U.S. government told the Second Circuit, urging it to reject the woman's claims that American authorities violated the Hague Convention in pursuing her.

  • March 28, 2024

    Nev. Estate Owes Over $3.8M In FBAR Penalties, Court Rules

    The estate of a Nevada entrepreneur must pay over $3.8 million in penalties and interest for willfully failing to report his foreign bank accounts in Belize, the Bahamas and Panama, a federal district court ruled.

  • March 28, 2024

    New Zealand Parliament Passes Global Minimum Tax

    The New Zealand Parliament has passed a wide-ranging tax bill that includes establishing the Organization for Economic Cooperation and Development's global corporate minimum tax.

  • March 28, 2024

    EU VAT Draft Draws Flak Over Cost For Online Platforms

    A proposed overhaul of the European Union's value-added tax rules to make them fit for the digital age faces questions about how the draft law treats platform companies in transportation, such as Uber or EU-based Bolt, when it comes to charging VAT.

  • March 28, 2024

    EU Justice Head To Step Aside To Run For Rights Group Post

    The European Union's president granted the bloc's justice commissioner leave to pursue a leadership role with a European human rights organization, the European Commission said.

  • March 28, 2024

    EU States OK Duty-Free Imports From Ukraine To June 2025

    European Union countries have overcome objections and backed the suspension for another year of customs duties and quotas on Ukrainian imports but only after tightening caps on some agricultural products. 

Expert Analysis

  • IRS Foreign Tax Credit Pause Is Welcome Course Correction

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    A recent IRS notice temporarily suspending application of 2022 foreign tax credit regulations provides wanted relief for the many U.S. multinational companies and other taxpayers that otherwise face the risk of significant double taxation in their international operations, say attorneys at Mayer Brown.

  • IRS Criminal Probe Spells Uncertainty For Malta Pension Plans

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    The IRS’ recent scrutiny of Malta pension plan arrangements — and its unusual issuance of criminal administrative summonses — confirms that it views many of these plans as illegal tax evasion schemes, and the road ahead will not be smooth and steady for anyone involved, say attorneys at Kostelanetz.

  • IRS Announcement Will Aid Cos. In Buyback Tax Planning

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    Recent IRS transitional guidance regarding current requirements for reporting and payment of the stock repurchase excise tax will help corporate taxpayers make decisions about records retention and establishing reserves for future tax payments, say Xenia Garofalo and Kyle Colonna at Eversheds Sutherland.

  • Flawed Analysis Supports Common Law Tax Deficiency Ruling

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    The Colorado federal district court’s recent decision in Liberty Global, holding that the U.S. Department of Justice may assert a common law tax claim without the notice of tax deficiency required by the Internal Revenue Code, relies on a contorted reading of the statute and irrelevant case law, say Loren Opper and Christie Galinski at Miller Canfield.

  • Review Of Repatriation Tax Sets Justices On Slippery Slope

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    The U.S. Supreme Court’s recent decision to review the constitutionality of the repatriation tax in Moore v. U.S. has implications for many tax rules involving unrealized amounts and could leave the court on the brink of invalidating large swaths of the Internal Revenue Code, say attorneys at Eversheds Sutherland.

  • What To Make Of IRS' New Advance Pricing Guidance

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    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

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    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

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    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

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    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

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    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

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    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

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    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

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    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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