International

  • October 31, 2024

    Scam Promoter Who Cost UK £2.6M In Taxes Is Banned

    A man who promoted a tax avoidance scam costing the British government tax agency at least £2.6 million ($3.4 million) has been banned by the government from serving as a director of any company for 10 years, the U.K.'s Insolvency Service announced Thursday.

  • October 31, 2024

    Exxon Entitled To Interest Deduction On Qatar Deal

    Exxon Mobil is entitled to an interest expense deduction on payments to Qatar under a natural gas deal, a Texas federal judge ruled, rejecting the U.S. government's classification of an underlying transaction as a royalty rather than a loan.

  • October 31, 2024

    Treasury Official Previews M&A Details For Corp. AMT Rules

    U.S. rulemakers plan to further address how the country's corporate alternative minimum tax applies to transactions including spinoffs and deals that involve a member of a tax consolidated group, a U.S. Treasury Department official said Thursday.

  • October 31, 2024

    EU Expected To Close Final Digital VAT Deal Next Week

    The European Union is close to a final deal on its plan to bring the bloc's value-added tax rules more in line with the digital economy after representatives reached an agreement in principle, the Hungarian presidency of the Council of the EU confirmed Thursday.

  • October 31, 2024

    Gov't Urged To Reform Tax Charges On Pension Scam Victims

    The government should prioritize reform to ensure that victims of pension scams are no longer hit with massive tax bills, an industry body said Thursday.

  • October 31, 2024

    5 Convicted In €54M VAT Fraud Of 10,000 Cars

    A German court convicted five people for taking part in a value-added tax fraud scheme that involved international trade of more than 10,000 cars that caused €53.7 million ($58.3 million) in estimated losses, the European Public Prosecutor's Office said Thursday.

  • October 31, 2024

    The 2024 Law360 Pulse Leaderboard

    Check out the Law360 Pulse Leaderboard to see which firms made the list of leaders in all-around excellence this year.

  • October 31, 2024

    Firms' Hiring Strategies Are Evolving In Fight For Top Spot

    Competition for top talent among elite law firms shows no signs of slowing down, even amid economic uncertainty, with financially strong firms deploying aggressive strategies to attract and retain skilled professionals to solidify their market position.

  • October 31, 2024

    11th Circ. Nixes ERISA Claim To John Hancock's $100M Credit

    John Hancock Life Insurance Co. had no fiduciary duty to pass on to retirement plans $100 million in foreign tax credits that it had taken from taxes paid on foreign investments, a three-judge panel of the Eleventh Circuit said in upholding a lower court ruling.

  • October 31, 2024

    Reeves To Face MPs As Budget Enters Approval Process

    Chancellor Rachel Reeves is due to be grilled by senior MPs on Nov. 6 after she presented the Labour government's first Budget for 14 years, which features a £40 billion ($52 billion) tax package that has raised concerns of new pressure on businesses and retirement savers.

  • October 30, 2024

    Jury Finds Importer Didn't Report $17M On Tax Returns

    A Los Angeles jury found an importer of Chinese clothing guilty of skirting more than $8 million in customs duties and failing to report more than $17 million in cash transactions on tax returns, federal prosecutors in California announced Wednesday.

  • October 30, 2024

    Pillar 2 Likely To Cast Shadow Over US Tax Bill Talks

    The international minimum tax agreement known as Pillar Two won't officially factor into upcoming tax bill negotiations in the U.S. Congress, but the global regime's potential grab at U.S. tax revenue could informally influence policy choices.

  • October 30, 2024

    Tax Court Stands By Couple's Tax Liability After Remand

    An investor couple whose case was remanded by the Sixth Circuit is still liable for over $603,000 in deficient taxes tied to $3 million in claimed losses from a complex foreign-exchange derivative arrangement since their actions were not made with legitimate intentions of turning a profit, the U.S. Tax Court said Wednesday.

  • October 30, 2024

    GOP Lawmakers Criticize Treasury's Start Of Taiwan Tax Talks

    The top tax-writing Republicans in Congress said Wednesday that the U.S. Treasury Department's announcement that it would begin negotiations with Taiwan on a double-tax relief agreement risks undermining legislation to address the issue that is stalled in the Senate.

  • October 30, 2024

    Canadian Can't Claim $15.8M In Losses From Forex Trades

    A Canadian businessman can't claim CA$22 million ($15.8 million) in losses as deductions because the foreign exchange trades generating them were not pursued for profit, the Tax Court of Canada ruled.

  • October 30, 2024

    South African Parliament To Consider Global Minimum Tax

    Qualifying businesses in South Africa would be subject to two parts of the OECD's 15% global minimum tax on large multinational entities making more than €750 million ($815 million) annually under legislation sent to the country's Parliament on Wednesday.

  • October 30, 2024

    UK's VAT Gap Rises £1.4B In 2023-24, Initial Estimate Says

    The gap between the amount of value-added tax the U.K. expected to collect in the 2023-24 tax year and the amount actually collected was an estimated £9.5 billion ($12.3 billion), a £1.4 billion increase over the final estimate for the year prior, HM Revenue & Customs said Wednesday.

  • October 30, 2024

    UK Capital Gains Hike Casts Shadow Over Gov't LSE Aims

    The decision by Chancellor Rachel Reeves to raise the tax paid on gains made when shares are sold could hinder the government's work on making the London Stock Exchange more attractive for stock listings and investors, regulatory experts warn.

  • October 30, 2024

    Last UK Gov't 'Did Not Share' Spending Info With Watchdog

    The independent fiscal watchdog said Wednesday that the last Conservative administration had failed to disclose public spending information, adding that it would have resulted in a "materially different" forecast for government spending if it had been given the data.

  • October 30, 2024

    Pension Pros Say Shutting Inheritance Tax Loophole Overdue

    Retirement industry professionals said Wednesday that the budget announcement by the U.K. government that it would remove a loophole that allowed the transfer of more than £1 million ($1.3 million) of inherited pension wealth without paying inheritance tax was overdue.

  • October 30, 2024

    Labour Gov't Unveils £40B Tax Boost In First Budget

    A £40 billion ($52 billion) tax package unveiled on Wednesday by Britain's new Labour government targets business and investors and aims to plug fiscal gaps with plans including higher levies on payrolls and capital gains.

  • October 29, 2024

    Rimon Adds International Tax Expert In Philadelphia

    Rimon PC has added an expert in international tax and trusts and estates who joined the firm's Philadelphia office after working for his own practice.  

  • October 29, 2024

    Croatia, Australia Reach Double Tax Treaty Agreement

    Croatia and Australia have agreed on a treaty to avoid double taxation that will take effect when passed by the respective legislatures, the Croatian Ministry of Finance said.

  • October 29, 2024

    States Should Cede Profit-Shifting Fight To OECD, Atty Says

    States should shy away from using mandatory worldwide combined reporting to address profit shifting and instead allow the Organization for Economic Cooperation and Development to police tax avoidance from multinational corporations, a business trade group attorney said Tuesday.

  • October 29, 2024

    Switzerland Amends Double Tax Treaty With Kuwait

    Switzerland said Tuesday it has ratified changes to its double taxation treaty with Kuwait that are due to take effect early next year.

Expert Analysis

  • 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.

  • Senate Credit Suisse Report Puts Attention On Banks, Trusts

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    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

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    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

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    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

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    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.

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