International
-
July 03, 2024
Tax Pros Want To Ensure Cooperation Between UN, OECD
A group representing more than half a million tax advisers across three continents said Wednesday that governments and stakeholders should ensure that the Organization for Economic Cooperation and Development and the United Nations work closely in forming global tax policy.
-
July 03, 2024
Federal Tax Policy To Watch In The 2nd Half Of 2024
Congressional lawmakers are grappling with the looming 2025 expiration of the 2017 GOP tax overhaul, a situation made more difficult by the coming elections in November that could define what, if any, tax legislation is eventually signed into law this year. Here, Law360 examines federal tax policy to watch in the second half of 2024.
-
July 02, 2024
NJ Couple Ordered To Pay $2.5M In FBAR Penalties
A New Jersey couple were ordered to pay $2.5 million in penalties and interest for failing to report their foreign bank accounts in Switzerland, according to court documents.
-
July 02, 2024
Eaton Needs To Cough Up Docs In IRS Probe, US Says
The U.S. government urged an Ohio federal judge to order power management multinational Eaton to produce records on certain European employees in response to an IRS investigation, arguing the company's contention the court lacks jurisdiction is "pure sophistry."
-
July 02, 2024
Saudi Arabia Extends COVID-19 Tax Penalty Exemptions
Saudi Arabia's tax authority extended pandemic-inspired broad exemptions from certain tax-related penalties and fines, such as those for late filings and payments, through the end of the year.
-
July 02, 2024
Financial Crime Body Updating Risk Assessment Guidance
An intergovernmental task force announced it is seeking public input on ways it could improve guidance for its process for countries to determine their risks of bad actors using their financial systems for money laundering.
-
July 02, 2024
Belgium Delays Pillar 2 Reporting For Some Groups
Belgium's finance ministry on Tuesday pushed back the deadline to Sept. 16 for some entities in scope of its implementation of the OECD's Pillar Two global 15% minimum tax to comply with the country's mandatory notification system.
-
July 02, 2024
Netherlands Still A Conduit For Tax Evasion, Report Says
The Netherlands remains a conduit for multinational companies channeling their profits to countries with low tax rates despite some tax measures introduced by the Dutch government, a study sent to Law360 on Tuesday said.
-
July 02, 2024
Hungary Envoy Praises Its Low Taxes After PM Slams Min. Tax
Hungary's representative to the European Union said Tuesday that Budapest's low tax rate was instrumental in bolstering the business environment in the country as he responded to a question about his prime minister slamming the global minimum tax.
-
July 02, 2024
New Dutch Government Sworn In, Plans Tax Reform
The new four-party conservative Dutch government took office Tuesday on a program that includes tax reform for companies and individuals.
-
July 01, 2024
Womble Bond Adds Int'l Tax Partner In Houston Office
Womble Bond Dickinson has added a partner to its corporate and securities group in Houston who will focus on tax law and cross-border transactions, the firm announced.
-
July 01, 2024
US-Taiwan Biz Groups Push For True Double-Tax Treaty
Top-ranking Senate members should push for the start of consultations on a bilateral tax treaty to avoid double taxation between the U.S. and Taiwan as opposed to measures already included in a stalled larger bill, two groups focused on business relations between the countries said.
-
July 01, 2024
Judge Acquits Firm Co-Founder, 27 Others Over Panama Papers
When authorities raided the now defunct Panamanian law firm Mossack Fonseca as part of their investigation into the international money laundering case known as the Panama Papers, they didn't follow the chain of custody for evidence they seized, so 28 people accused in the conspiracy must be acquitted, a Panamanian judge has ruled.
-
July 01, 2024
Nelson Mullins Adds 9-Attorney Tax Team In Houston
Nelson Mullins Riley & Scarborough LLP announced Monday that five partners and four other tax attorneys have joined its new Houston office from Chamberlain Hrdlicka White Williams & Aughtry, including a former Texas Supreme Court justice.
-
July 01, 2024
Firm Can't Cast Off $1.5M Tax Levy In Alter Ego Case
A Baltimore law firm can't stop a $1.5 million tax levy that allowed the IRS to freeze its bank account, a Maryland federal judge ruled, saying the firm failed to prove at this point in its suit that one of its clients lacked an interest in the money.
-
July 01, 2024
3 More Indicted In €54M VAT Fraud Involving Car Sales
Authorities indicted three more suspects for their roles in a value-added tax fraud scheme involving the international trade of more than 10,000 cars that caused over €53.7 million ($57.6 million) in VAT losses, the European Public Prosecutor's Office said Monday.
-
July 01, 2024
OECD Tax Chief Affirms Pillar 1 Progress As Deadline Passes
Negotiations continue on Pillar One at the Organization for Economic Cooperation and Development even after a deadline passed to release the final text of a multilateral convention to establish the project's taxing right known as Amount A, the director of the OECD's tax policy office said Monday.
-
July 01, 2024
New EU Chair Hungary Aims To Discuss VAT At Fall Meeting
Hungary, the new chair of European Union member states, plans to discuss at a fall meeting a proposed change to value-added tax law that would require platform companies such as Airbnb and Uber to collect VAT for service providers.
-
July 01, 2024
EU Bans Giving Tax Consulting Services To Belarus
The European Union has introduced a ban on providing tax consulting and many other professional services to Belarus in a wide-ranging package of measures largely aimed at preventing the circumvention of the bloc's sanctions against Russia, a statement said.
-
June 28, 2024
Chevron's End Is Just The Start For Energized Agency Foes
By knocking down a powerful precedent that has towered over administrative law for 40 years, the U.S. Supreme Court's right wing Friday gave a crowning achievement to anti-agency attorneys. But for those attorneys, the achievement is merely a means to an end, and experts expect a litigation blitzkrieg to materialize quickly in the aftermath.
-
June 28, 2024
In Chevron Case, Justices Trade One Unknown For Another
The U.S. Supreme Court's decision to overrule a decades-old judicial deference doctrine may cause the "eternal fog of uncertainty" surrounding federal agency actions to dissipate and level the playing field in challenges of government policies, but lawyers warn it raises new questions over what rules courts must follow and how judges will implement them.
-
June 28, 2024
IRS Finalizes Broker Rules For Digital Asset Sales
Brokers of digital assets such as cryptocurrency and non-fungible tokens will face tax reporting requirements for the first time similar to those for brokers of securities and other financial instruments under final regulations issued Friday by the Internal Revenue Service.
-
June 28, 2024
UK Appeals Court Rules Businesses Can't Claim Allowances
Two U.K. businesses may not claim capital allowances from a transaction that was carried out as part of a marketed tax avoidance scheme, a British appeals court ruled Friday, overturning a lower court's decision.
-
June 28, 2024
Chevron Ruling No Sea Change For Tax Court, Judge Says
The U.S. Tax Court will continue to rely on the IRS and Treasury's expertise in the tax code following the U.S. Supreme Court's landmark decision to overturn the 40-year-old Chevron doctrine that directed courts to defer to federal agencies' interpretations of ambiguous law, a judge said Friday.
-
June 28, 2024
Taxation With Representation: Kirkland, Vinson, Skadden
In this week's Taxation with Representation, Aareal Bank AG and Advent International sell a property management and maintenance software company, Webtoon Entertainment Inc. and Tamboran Resources Corp. price initial public offerings, SM Energy Company acquires oil and gas assets, and Nokia sells Alcatel Submarine Networks to the French state.
Expert Analysis
-
Questions To Ask If Doing Business In A Corruption Hot Spot
Businesses facing new scrutiny after the U.S. Department of Justice's recently announced task force for combating human trafficking in Central America, the release of the Pandora Papers and continuing fallout from 2019's Panama Papers, should address compliance risks by having employees ask three questions about every transaction, say attorneys at White & Case.
-
How The Global Tax Agreement Could Backfire For Biden
If the $3.5 trillion spending package fails, the federal tax code will not conform to the recent 15% global minimum tax agreement spearheaded by the U.S., which would embarrass the Biden administration and could lead to retaliatory tax measures by other nations, says Alex Parker at Capitol Counsel.
-
Pandora Papers Reveal Need For Greater Tax Enforcement
The recent Pandora Papers leak is a reminder of the importance of transparency laws and proper funding for enforcement efforts against tax evasion as bad actors increasingly operate in the shadows, says Daren Firestone and Kevin Crenny at Levy Firestone.
-
Parsing New Int'l Tax Reporting Rules For Pass-Throughs
Attorneys at Grant Thornton unpack the Internal Revenue Service’s new pass-through entity reporting requirements for international tax matters and the accompanying guidance for penalty relief, and suggest how companies should prepare for what may be the most significant change to the partnership compliance function in decades.
-
A Look At Global Tax Enforcement Developments: Part 2
Excerpt from Practical Guidance
Sean Craig at LexisNexis examines recent investigations by the Joint Chiefs of Global Tax Enforcement and their impact on U.S. taxpayers, as well as the growing significance of transfer pricing disputes and policies for future enforcement.
-
A Look At Global Tax Enforcement Developments: Part 1
Excerpt from Practical Guidance
Sean Craig at LexisNexis looks at how international initiatives, such as the Joint Chiefs of Global Tax Enforcement, are addressing cryptocurrency-related tax evasion, and how the COVID-19 pandemic and increasing demands for governmental welfare programs are driving global tax policy.
-
EU Climate Plan Should Involve Taxing Pollution, Not Borders
In order to crack down on greenhouse gas emissions, the European Union proposes to levy carbon emissions at its borders and to overhaul its long-standing energy tax framework, but the latter would hold polluters directly accountable, giving it the better chance for success, says Rebecca Christie at Bruegel.
-
Prepare For Global Tax Regime's New Biz Dispute Risks
Companies should take steps to mitigate the business dispute risks of the new international tax framework, which over a hundred countries agreed to in July, as implementing the new regime will be expensive and require substantial organizational restructuring efforts, says Tim McCarthy at Dykema.
-
Prepare For More Audits Of Tax Info And Withholding Filings
Financial institutions and other corporate taxpayers should focus compliance efforts on tax information reporting and withholding, given recent indications from the Biden administration that the IRS will increase enforcement, and the administration's need to fund its infrastructure plan and other costly initiatives, say attorneys at Mayer Brown.
-
Anti-Boycott Compliance Still Key In UAE Business Dealings
Notwithstanding recent amendments to U.S. anti-boycott laws that reflect the United Arab Emirates' withdrawal from the Arab boycott of Israel, companies doing business in the UAE and elsewhere still need to maintain effective anti-boycott compliance programs to avoid reporting violations or penalties, says Howard Weissman at Miller Canfield.
-
9th Circ. Adds Pressure To Reject Substance Over Form
The Ninth Circuit’s recent decision rejecting taxes on a family's Roth IRA payments that were made through a foreign sales corporation represents a refreshing trend among federal appeals courts to reject substance-over-form principles and instead look to congressional intent, say Lawrence Hill and Caitlin Tharp at Steptoe & Johnson.
-
Will The OECD Plan Fix International Taxation?
Lilian Faulhaber at Georgetown Law breaks down the Organization for Economic Cooperation and Development’s plan for international tax reform, recently joined by 130 countries, and whether it will solve the problems it was designed to address, including the need for multinational companies to pay their fair share of taxes in the digitized world economy.
-
What Biden's Tax Proposals May Mean For Int'l Private Clients
Jennifer Wioncek and Paul D’Alessandro at Bilzin Sumberg discuss the U.S. Department of the Treasury's recently released explanation of the Biden administration's tax proposals and how the changes would affect income and wealth transfer planning for international private clients.