International

  • December 03, 2024

    Australia Expects Royalties, Reporting Guidance In Early 2025

    The Australian Taxation Office said it expects to release draft guidance in February related to a ruling on when payment agreements for software are considered royalties, followed by guidance for exemptions from its new country-by-country reporting laws in March.

  • December 03, 2024

    Charity's Ex-Partner Gets 10 Years For £1.5M Gift Aid Fraud

    A former finance business partner at national charity Save The Children UK has been jailed for 10 years for stealing £1.5 million ($1.9 million) through fraudulent Gift Aid claims, HM Revenue & Customs announced Tuesday.

  • December 03, 2024

    Comment Deadline Extended For Corp. Alternative Min. Tax

    Treasury and the Internal Revenue Service said Tuesday that they will accept comments on proposed rules for the new 15% corporate alternative minimum tax on corporations with reported profits of $1 billion or more until Jan. 16, a roughly one-month extension from the previous deadline.

  • December 02, 2024

    Russia Looks To 4 FSIA Cases In Bid To Stay $5B Award Suit

    Russia urged a D.C. federal judge to pause a case against it by a Yukos Oil Co. unit seeking to enforce $5 billion in arbitral awards, saying Monday that four parallel Foreign Sovereign Immunities Act cases are pending before the Supreme Court and the D.C. Circuit that could affect the suit.

  • December 02, 2024

    Texas Truck Co. Owes Chinese Tire Import Tax, 5th Circ. Says

    A Houston truck company that sold tires made by a Chinese manufacturer is on the hook for excise taxes as the beneficial owner of the tires, the Fifth Circuit decided in an opinion Monday that reversed a ruling freeing the company from its nearly $2 million tax bill.

  • December 02, 2024

    'Harry Potter' Actor Must Pay £1.8M Tax Bill, Tribunal Says

    Actor Rupert Grint, who portrayed Ron Weasley in the Harry Potter film series, faces a £1.8 million ($2.3 million) tax bill after the U.K.'s First-tier Tribunal ruled that tax avoidance was a primary purpose of an entity created to manage his career.

  • December 02, 2024

    IRS Floats Pooling, Annual Accounting In Offshore Profit Regs

    U.S. multinational companies will be required to create annual shareholder accounts and adhere to new pooling concepts to properly account for previously taxed earnings and profits under proposed rules floated by the U.S. Treasury Department and Internal Revenue Service.

  • December 02, 2024

    A&O Shearman Tax Pro Jumps To Hogan Lovells In DC

    Hogan Lovells said Monday that it has brought on a former Allen Overy Shearman Sterling tax partner who specializes in spinoffs, cross-border deals and other corporate transactions.

  • December 02, 2024

    IRS Finalizes Partnership Liability Regs After 11 Years

    The Internal Revenue Service unveiled final regulations governing the allocation of partnership liabilities 11 years after releasing the proposed rules, saying no subsequent legislative and regulatory changes had taken place to compel the agency to otherwise renew the rulemaking process.

  • December 02, 2024

    Australia Passes Public Country-By-Country Reporting

    Multinational businesses with large operations in Australia are required to publicly disclose information about their operations in tax havens as designated by the government under a country-by-country reporting law that lawmakers adopted following a two-year saga over concerns about the data's confidentiality.

  • December 02, 2024

    Skat Settles With Ex-Barclays Director In £1.4B Fraud Case

    The Danish tax authority has settled its claim against a former Barclays Capital director and four companies that it sued alongside dozens of others over an alleged scheme to defraud it of £1.4 billion ($1.8 billion) in tax revenue.

  • December 02, 2024

    Sports Direct's Ashley Says HMRC Bungled His Data Request

    Sports Direct International PLC founder Michael Ashley argued in a London court Monday that the U.K.'s tax agency improperly handled his data request related to its probe into his 2012 sale of real estate assets, calling its alleged failings "significant, wide-spread and persistent."

  • December 02, 2024

    Australia Seeks Input On Tax Treaty With Portugal

    Australia's Treasury is looking for feedback on plans to implement a treaty with Portugal that would address concerns of double taxation and alleviate cross-border costs by establishing lower withholding rates, the agency said Monday.

  • December 02, 2024

    5 Convicted In €14M COVID Test VAT Fraud Scheme

    A German court convicted five people for their roles in a value-added tax fraud scheme involving the sale of COVID-19 tests that caused about €14 million ($14.7 million) in VAT losses, the European Public Prosecutor's Office said.

  • November 29, 2024

    Audit Watchdog Urges EU To Curb Harmful Tax Practices

    The European Union is still not doing enough to stop harmful corporate tax practices that are costing governments more than €100 billion ($105 billion) a year in revenue, the bloc's independent audit watchdog has warned.

  • November 28, 2024

    Police Detain 32 People In Raids On €297M VAT Fraud Network

    Police have detained more than 30 people in raids on a €297 million ($313 million) value-added tax fraud network that spanned 16 EU countries, the European Public Prosecutor's Office said Thursday.

  • November 28, 2024

    EU Closes Tax Investigations Into Amazon, Fiat, Starbucks

    The European Commission said Thursday that it is closing tax investigations into three multinational companies — Amazon, Fiat and Starbucks — following a series of high-profile court decisions.

  • November 28, 2024

    Ex-HMRC Compliance Officer Helped Husband Launder £3M

    A former compliance officer with HM Revenue and Customs has been handed a suspended sentence for her role in a £3 million ($3.8 million) money laundering operation carried out by her husband, the Crown Prosecution Service has said.

  • November 28, 2024

    AXA Loses Time Limits Appeal In HMRC Foreign Tax Claim

    Insurer AXA has lost its fight over time limits for bringing claims for restitution against the British tax authority over taxes collected in violation of European Union law, as a London appeals court ruled that the limits could not be extended.

  • November 27, 2024

    UN Approves Start Of Formal Talks On Global Tax Convention

    The United Nations General Assembly voted Wednesday in favor of beginning formal negotiations on a global tax convention next year with the goal of finishing in 2027, a proposal that was led by the body's African bloc and won support from 125 countries.

  • November 27, 2024

    US Says Prof's 8th Amendment Argument Fails In FBAR Case

    An 86-year-old former professor cannot claim that his $545,000 penalty for failing to report foreign bank accounts violates the Eighth Amendment, the U.S. told a federal court, saying the penalty is neither excessive nor a fine, and that he never raised the argument before.

  • November 27, 2024

    BlueCrest Disputes 'Disguised Salary' Claim In HMRC Case

    British-American hedge fund BlueCrest Capital Management LLP pushed back Wednesday against arguments from the U.K. tax authority that its portfolio managers are employees receiving a disguised salary.

  • November 27, 2024

    US Seeks FBAR Penalties Over $1.7M In Foreign Accounts

    A Texas woman should face penalties for willfully failing to disclose foreign bank accounts from 2011 through 2013, which held balances exceeding $1.7 million, the U.S. government told a federal court Wednesday.

  • November 27, 2024

    UK Gambling Levy Would Generate £100M, Gov't Says

    A new levy on U.K. gambling operations would generate £100 million ($127 million), which would be earmarked for funding various ways to combat problem gambling, a government agency said Wednesday.

  • November 27, 2024

    Info On €12T In Assets Swapped Last Year, OECD Says

    Tax jurisdictions using the Organization for Economic Cooperation and Development's automatic exchange of information frameworks swapped information on 134 million financial accounts last year, representing nearly €12 trillion ($12.7 trillion) in assets, according to an OECD forum report.

Expert Analysis

  • How Attys Can Avoid Pitfalls When Withdrawing From A Case

    Author Photo

    The Trump campaign's recent scuffle over its bid to replace its counsel in a pregnancy retaliation suit offers a chance to remind attorneys that many troubles inherent in withdrawing from a case can be mitigated or entirely avoided by communicating with clients openly and frequently, says Christopher Konneker at Orsinger Nelson.

  • Using A Children's Book Approach In Firm Marketing Content

    Author Photo

    From “The Giving Tree” to “Where the Wild Things Are,” most children’s books are easy to remember because they use simple words and numbers to tell stories with a human impact — a formula law firms should emulate in their marketing content to stay front of mind for potential clients, says Seema Desai Maglio at The Found Word.

  • New Crypto Reporting Will Require Rigorous Recordkeeping

    Author Photo

    The release of a form for reporting digital asset transactions is a pivotal moment in the Internal Revenue Service's efforts to track cryptocurrency activities that increases oversight by requiring brokers to report investor sales and exchanges, say Shaina Kamen and Max Angel at Holland & Knight.

  • Exploring An Alternative Model Of Litigation Finance

    Author Photo

    A new model of litigation finance, most aptly described as insurance-backed litigation funding, differs from traditional funding in two key ways, and the process of securing it involves three primary steps, say Bob Koneck, Christopher Le Neve Foster and Richard Butters at Atlantic Global Risk LLC.

  • A Vision For Economic Clerkships In The Legal System

    Author Photo

    As courts handle increasingly complex damages analyses involving vast amounts of data, an economic clerkship program — integrating early-career economists into the judicial system — could improve legal outcomes and provide essential training to clerks, say Mona Birjandi at Data for Decisions and Matt Farber at Secretariat.

  • A Look At New IRS Rules For Domestically Controlled REITs

    Author Photo

    The Internal Revenue Services' finalized Treasury Regulations addressing whether real estate investment trusts qualify as domestically controlled adopt the basic structure of previous proposals, but certain new and modified rules may mitigate the regulations' impact, say attorneys at Simpson Thacher.

  • E-Discovery Quarterly: Recent Rulings On Text Message Data

    Author Photo

    Electronically stored information on cellphones, and in particular text messages, can present unique litigation challenges, and recent court decisions demonstrate that counsel must carefully balance what data should be preserved, collected, reviewed and produced, say attorneys at Sidley.

  • Don't Use The Same Template For Every Client Alert

    Author Photo

    As the old marketing adage goes, consistency is key, but law firm style guides need consistency that contemplates variety when it comes to client alert formats, allowing attorneys to tailor alerts to best fit the audience and subject matter, says Jessica Kaplan at Legally Penned.

  • Think Like A Lawyer: Follow The Iron Rule Of Trial Logic

    Author Photo

    Many diligent and eager attorneys include every good fact, point and rule in their trial narratives — spurred by the gnawing fear they’ll be second-guessed for leaving something out — but this approach ignores a fundamental principle of successful trial lawyering, says Luke Andrews at Poole Huffman.

  • The Art Of Asking: Leveraging Your Contacts For Referrals

    Author Photo

    Though attorneys may hesitate to ask for referral recommendations to generate new business, research shows that people want to help others they know, like and trust, so consider who in your network you should approach and how to make the ask, says Rebecca Hnatowski at Edwards Advisory.

  • Unpacking The Bill To Extend TCJA's Biz-Friendly Tax Breaks

    Author Photo

    Attorneys at Skadden examine how a bipartisan bill currently being considered by the U.S. Senate to save the Tax Cuts and Jobs Act's tax breaks for research and development costs, and other expiring business-friendly provisions, would affect taxpayers.

  • Deciding What Comes At The End Of WTO's Digital Tariff Ban

    Author Photo

    Companies that feel empowered by the World Trade Organization’s recent two-year extension of the ban on e-commerce tariffs should pay attention to current negotiations over what comes after the moratorium expires, as these agreements will define standards in international e-commerce for years to come, say Jan Walter, Hannes Sigurgeirsson and Kulsum Gulamhusein at Akin Gump.

  • 4 Ways To Refresh Your Law Firm's Marketing Strategy

    Author Photo

    With many BigLaw firms relying on an increasingly obsolete marketing approach that prioritizes stiff professionalism over authentic connection, adopting a few key communications strategies to better connect with today's clients and prospects can make all the difference, say Eric Pacifici and Kevin Henderson at SMB Law.

Can't find the article you're looking for? Click here to search the Tax Authority International archive.