International

  • March 22, 2024

    UK Seeking Feedback On 2027 Carbon Border Tax Plan

    HM Revenue & Customs and HM Treasury are seeking feedback on the U.K.'s plan to introduce a carbon border tax on certain carbon-intensive imports by 2027.

  • March 22, 2024

    EU Leaders Seek Limited Tax Revamp To Boost Capital Market

    European Union leaders urged all bloc policymakers Friday to pursue a plan to improve business financing, including a targeted makeover of the tax systems in the member countries regarding corporate taxes, capital gains and tax breaks for interest payments.

  • March 21, 2024

    Treasury Hoping Pillar 2 Guidance Favors R&D Tax Credits

    The U.S. Treasury Department is looking for future administrative guidance on the international minimum tax agreement known as Pillar Two to give favorable treatment to U.S. research and development tax credits, but it will likely come with guardrails, a Treasury official said Thursday.

  • March 21, 2024

    GoDaddy Can't Block Transfer Of $4 Million Set Aside For VAT

    A consortium that sold shares of an internet company to GoDaddy.com can receive a $4 million transfer of escrow funds that GoDaddy claimed were instead needed to pay value-added tax on the share sale, a Dutch court ruled.

  • March 21, 2024

    UN Could Enhance Global Tax Agenda Setting, Officials Say

    The United Nations could play an important role in shaping the agenda for global tax negotiations so it better reflects the priorities and concerns of developing countries, a variety of tax officials said Thursday during a conference.

  • March 21, 2024

    IRS Proposes Exceptions For 3rd-Party Summons Notices

    The IRS proposed rules Thursday that would allow some exceptions to a requirement that the agency notify taxpayers within 45 days before issuing summonses to third parties in tax assessment and collection cases, including for certain time-sensitive examinations.

  • March 21, 2024

    EU Countries Bash Deal On Duty-Free Imports From Ukraine

    Several European Union countries objected to the agreement among EU lawmakers to extend the suspension of the bloc's custom duties and quotas on Ukrainian imports, criticizing a lack of caps on agricultural products.

  • March 21, 2024

    Australia Seeking Input On Global Minimum Tax Bills

    Australia's Treasury is seeking public feedback on three draft bills published Thursday that would implement the Organization for Economic Cooperation and Development's global corporate minimum tax.

  • March 21, 2024

    Wyden Probes Swiss Bank's Ties To Billionaire Under Scrutiny

    The Senate Finance Committee's Democratic majority launched an inquiry into Swiss bank Pictet Group's involvement with a U.S. billionaire under criminal investigation, raising questions about the bank's deferred prosecution agreement and $123 million fine by the U.S. Justice Department, committee Chairman Ron Wyden announced Thursday.

  • March 21, 2024

    Quintairos Prieto Taps Atlanta Atty To Lead New Tax Group

    Quintairos Prieto Wood & Boyer PA said it had created a tax division that will be led by an Atlanta-based partner who has guided clients on civil and criminal tax law, reinforcing its national expertise in litigation, regulatory and corporate law matters.

  • March 21, 2024

    €58M VAT Toner Fraud Case Lands Four Convictions In Italy

    Four people were convicted in Italy for their roles in a value-added tax fraud scheme involving printer toner and other office supplies that resulted in €58 million ($63 million) in illicit profits, the European Public Prosecutor's Office said.

  • March 21, 2024

    PwC Still Withholding Names Of Aussie Leak Recipients

    PwC is continuing to refuse to name the six recipients of confidential drafts of Australian tax laws despite repeated requests from the country's government, the firm said in documents published Thursday.

  • March 21, 2024

    HSBC Settles Investors' £240M Claim Over Disney Tax Scheme

    HSBC has settled a £240 million ($304 million) claim brought by more than 100 investors alleging that the bank misled them to finance a Disney film tax relief scheme it developed which turned out to be worthless.

  • March 21, 2024

    UK Insurance Tax Bill Rises To £8.1B Amid Soaring Premiums

    The Insurance Premium Tax raised more than £8.1 billion ($10.3 billion) so far this financial year, according to official figures Thursday, while premiums continue to rise.

  • March 21, 2024

    ECJ Adviser Rejects Taxing Foreign Pension Funds Differently

    Taxing dividends paid to foreign public pension funds while exempting dividends paid to the source country's general retirement savings funds contravenes European Union law, an adviser to the bloc's highest court said Thursday, backing Finnish pension funds' challenge of a Swedish law.

  • March 20, 2024

    IRS Releases Foreign Housing Expense Limits For 2024

    The Internal Revenue Service released adjustments to the limitation on foreign housing expense deductions and exclusions for 2024 on Wednesday.

  • March 20, 2024

    EU Proposes Sending Russian Assets' Revenue To Ukraine

    The European Commission proposed on Wednesday transferring the net income from frozen and immobilized Russian state assets to European Union funds for rebuilding Ukraine and buying arms for that country.

  • March 20, 2024

    How The Supreme Court Could Narrow Chevron

    After hours of oral argument in a closely watched administrative law case, it appeared that some U.S. Supreme Court justices could be open to limiting the opportunities for lower courts to defer to federal agencies' legal interpretations in disputes over rulemaking — and legal experts said there are a number of ways they could do it.

  • March 20, 2024

    OECD Reports More Compliance With Tax Treaty Standards

    The Organization for Economic Cooperation and Development reported Wednesday that members of the group's inclusive framework — countries that have agreed to adopt minimum standards of an international anti-base erosion plan — have increased their compliance with the standard intended to prevent treaty shopping.

  • March 20, 2024

    IRS Withholding Docs On Partnership Audits, Baker Atty Says

    The Internal Revenue Service has not responded to a request for documents pertaining to the agency's scrutiny of large partnerships and should be forced to disclose them, an attorney with Baker McKenzie told a D.C. federal court.

  • March 20, 2024

    EU Floats Alternative To Unanimity As Bloc Eyes Growth

    The European Commission floated an alternative Wednesday to unanimity voting on matters such as tax as it seeks to streamline the way the bloc reaches decisions amid talk of expanding the number of EU countries.

  • March 20, 2024

    IRS Grants Income Exclusion To Those Fleeing 6 Countries

    Individuals who fled conditions in Ukraine, Belarus, Sudan, Haiti, Niger and Iraq after specific dates in 2023 can exclude foreign earned income, and can exclude or deduct housing costs, from gross income that year because of adverse conditions in the countries, the IRS said.

  • March 20, 2024

    Law360 Announces The Members Of Its 2024 Editorial Boards

    Law360 is pleased to announce the formation of its 2024 Editorial Advisory Boards.

  • March 20, 2024

    King & Spalding Adds Ex-PwC Tax Pro As Partner In NY

    An experienced tax attorney has joined King & Spalding LLP in New York after working at PricewaterhouseCoopers LLP for six years.

  • March 20, 2024

    HMRC Makes U-Turn On Helpline Cuts After Backlash

    The U.K. tax authority backtracked Wednesday on plans to close down several helplines for taxpayers from April through September after facing criticism from politicians and industry groups.

Expert Analysis

  • 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.

  • IRS Memo May Change IP Royalty Tax Prepayment Planning

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    A recent Internal Revenue Service advice memorandum finding a taxpayer was not permitted to prepay tax on contingent royalties after contributing intellectual property offshore is a noteworthy departure from earlier guidance that highlights potential differences between actual and deemed licenses, says William Skinner at Fenwick.

  • What IRS Funding Increase Means For Taxpayers

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    The Internal Revenue Service will first use the influx of funding from the Inflation Reduction Act to address customer support and personnel issues, but with over half the money allocated to enforcement, corporations and high-net-worth individuals will face increased scrutiny, say Patrick McCann Jr. and Jasen Hanson at Chamberlain Hrdlicka.

  • 6 Tax Considerations For Life Sciences Collaboration Deals

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    Given recent IRS guidance and changes to certain tax rates and deductions, biotech and life sciences companies entering into collaboration agreements should assess several unique taxation issues affecting matters ranging from research and development expenditures to profit-sharing terms, say attorneys at Orrick and Andersen Tax.

  • Rushed Multilateral Negotiations Caused Two-Pillar Tax Mess

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    Cracks appearing in the two pillars of the 2021 global tax plan stem from a multilateral tax policy process that rushed to issue rules without first resolving fundamental differences between countries or ensuring that the U.S., a key player, could implement them, says Jefferson VanderWolk at Squire Patton.

  • Key Considerations For Seeking Relief From Double Taxation

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    Caroline Setliffe and E. Miller Williams at Eversheds Sutherland lay out the Organization for International Cooperation and Development’s mutual agreement procedure for settling double-taxation disputes, and discuss six factors U.S. taxpayers doing business in multiple countries should consider when determining the most advantageous form of relief.

  • 2 Tax Decisions Hold Key Transfer Pricing Takeaways

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    Richard Slowinski and Stefanie Kavanagh at Alston & Bird discuss two recent decisions in cases against the IRS — Eaton Corp. from the Sixth Circuit and Medtronic from the Tax Court — that may help clarify when the agency can cancel an advance pricing agreement, but leave unanswered questions about which pricing method applies to high-value intercompany licensing transactions.

  • Digital Taxation Is Necessary, But Tough To Manage

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    The U.S. government has started to tackle complex new tax laws as the digital economy continues to grow, but this demands guidelines that will facilitate the growth while protecting investors and the government's finances, say attorneys at Cadwalader.

  • Company Considerations For Cash Award Incentives: Part 2

    Excerpt from Practical Guidance
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    Cash awards can help companies address some issues associated with equity awards to compensate employees, but due to potential downsides, they should be treated as a tool in a long-term incentive program rather than a panacea, say Denise Glagau and Kela Shang at Baker McKenzie.

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