International
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July 25, 2024
Belgium Taken To EU Court Over Deposit Exemption Rules
The European Union's executive branch said Thursday that it is taking Belgium to court alleging that the country's system of exempting remuneration of savings deposits from tax violates EU law.
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July 24, 2024
Int'l Firm Garrigues Merges With Full-Service Mexican Firm
International legal and tax services firm Garrigues will create one of the largest law firms in Mexico by integrating a full-service Mexican firm into the group by the end of 2024, both firms announced.
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July 24, 2024
Nigerian Parliament Passes 70% Bank Windfall Levy
The upper house of Nigeria's Parliament passed an amendment to its finance bill that included a 70% one-time levy on banks' foreign exchange gains, an increase over the 50% rate originally proposed by the country's president.
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July 24, 2024
IRS' $15M Jeopardy Assessment OK'd In Offshore Tax Fight
A Florida federal court has upheld a $15 million immediate tax assessment against a man who transferred his father's estate into trusts for himself and his mother and refused to pay what the IRS claimed was tax debt on his father's undisclosed offshore accounts.
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July 24, 2024
Affordable Housing Pro Moves Practice To Nelson Mullins
An attorney who specializes in advising clients on completing affordable housing development projects has recently moved her practice to Nelson Mullins Riley & Scarborough's Pittsburgh office.
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July 24, 2024
HMRC Wins Battle Over Candy Maker's Holiday Fund Scheme
HM Revenue & Customs has convinced an appeals tribunal that a Scottish sweet maker must compensate its employees for salary deductions it put aside in "holiday funds," with the judge finding the scheme ran afoul of national minimum wage regulations.
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July 24, 2024
Germany Failing To Address Nonprofits' Tax Status, EU Says
Germany has failed to make any progress addressing uncertainty surrounding the tax-exempt status of nonprofit organizations a year after the European Commission recommended it do so, the commission said Wednesday.
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July 24, 2024
Dentons Brings On Former Big 4 Exec As New Global CEO
Global law firm Dentons, which has made a name for itself by aggressive growth through combinations, has tapped a new global chief executive officer with leadership experience at accounting giant EY, the firm's first change at the top in over a decade.
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July 24, 2024
Phillips Lytle Private Wealth Pro Joins Gunster In Florida
Gunster has announced that the firm picked up an of counsel for its private wealth services team in West Palm Beach, Florida, from Phillips Lytle LLP, as well as three associate attorneys.
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July 24, 2024
Can New Pensions Minister 'Serve Two Masters'?
A new British pensions minister with a foot in two competing government departments could help create a more coherent pensions reforms, although some analysts warn of a potential Treasury takeover of pensions policy to prioritize economic stimulus.
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July 23, 2024
Newell Says IRS Misapplied Pricing Law In $124M Dispute
Newell Brands told the U.S. Tax Court the Internal Revenue Service misapplied transfer pricing law to levy almost $124 million in additional taxes and penalties.
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July 23, 2024
IRS Notice Signals Direction On Corp. AMT Regs, Official Says
An Internal Revenue Service notice regarding the U.S. corporate alternative minimum tax can be read as a signal about how the agency will more broadly address the measure's potential for counting offshore income twice, an IRS official said Tuesday.
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July 23, 2024
Winston & Strawn Adds MoFo Tax Pro As Partner In NY
Winston & Strawn LLP has added a transactional tax specialist from Morrison Foerster LLP as a partner with the firm's transactions department and tax practice in New York.
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July 23, 2024
India Eyes End Of Digital Tax For E-Commerce, But Not Ads
Foreign e-commerce companies would be exempted from India's equalization levy, a 2% digital tax, but online advertisers would continue to pay a 6% rate on gross revenues sourced to Indian customers under a budget bill presented Tuesday by the government.
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July 23, 2024
Australia Mulling Higher Foreign Resident Capital Gains Tax
The Australian Treasury said Tuesday it is seeking feedback on a plan to increase the country's capital gains withholding tax rate for foreign residents, among other plans it said will strengthen the country's foreign resident capital gains tax regime.
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July 23, 2024
EU Seeking Comments On Digital VAT Exemption Certificate
The European Commission is seeking public comments on a proposal to replace the current paper version of certificates for value-added tax exemptions with a digital version, the European Union's executive branch said Tuesday.
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July 23, 2024
Former Doctor To Be Released From Jail In FBAR Fight
A former doctor will be released from U.S. custody after a Michigan federal court lifted Tuesday an order of civil contempt against him for failure to pay about $1 million in foreign account reporting penalties.
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July 23, 2024
Orrick Hires Ex-Winston & Strawn Tax Partner In Chicago
Orrick Herrington & Sutcliffe LLP announced the hiring of a former partner at Winston & Strawn LLP for its renewables tax equity and tax credit team.
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July 23, 2024
5-Hour Energy Partner Owes No Tax On Sale, DC Circ. Says
The D.C. Circuit found Tuesday that a Canadian citizen's $6.5 million in gains from her sale of a U.S. partnership interest in a company that sold 5-hour Energy drinks was not federally taxable as inventory income, reversing a U.S. Tax Court ruling.
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July 23, 2024
Hungary's EU Leadership Could Slow Tax Progress
Hungary's six-month term leading meetings of European Union ministers could hinder progress toward agreement on tax legislation, as the country's position on the war in Ukraine alienates other bloc members.
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July 23, 2024
EU Parliament's New Tax Group Head Has Eye On Evasion
The newly elected chair of the European Parliament's subcommittee on tax affairs said Tuesday that a major committee goal would be to examine the issue of tax fraud and evasion at a multinational level.
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July 22, 2024
3 Policies Tax Pros Want Congress To Pass This Year
As momentum around the House-passed tax break bill has fizzled and election season ramps up, tax experts hope lawmakers use what little time they have left to extend expired research tax breaks, approve the Taiwanese tax agreement and pass disaster relief before the end of the year. Here are three policy changes tax professionals think Congress should make before the end of the year.
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July 22, 2024
HMRC Wins Appeal Over Taxation Of Partnership Rewards
Financial rewards from a partnership were taxable as income even though they were made at the partnership's total discretion and the partners had no legally enforceable right to receive them, a London court ruled, siding with HM Revenue & Customs.
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July 22, 2024
US Treasury Working To Extend Pillar 1 DST Compromise
As OECD-led negotiations continue on a taxing rights overhaul known as Pillar One after a missed June deadline, the U.S. Treasury Department is working to extend the political agreement between it and several countries to nullify their digital services taxes once the rights overhaul is implemented.
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July 22, 2024
Pension Plans Slam Biz Docs In $2B Danish Tax Fraud Case
Denmark's tax agency has produced experts who are relying on unauthenticated documents in litigation accusing U.S. pension plans of participating in a $2.1 billion fraud scheme, the pension plans claimed in urging a New York federal court to exclude the testimony.
Expert Analysis
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Cos. May Want To Wait Out US-EU Green Incentives Fight
As the European Union considers measures to compete with the Inflation Reduction Act's incentives for U.S. production of clean tech, and EU and U.S. officials discuss a possible compromise, companies in the green sector should consider taking a wait-and-see approach to investment decisions, says Todd Thacker at Goldberg Segalla.
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India's Budget Proposals May Ease Entry For Certain Sectors
India’s recently released budget includes proposals to facilitate doing business in Gujarat International Finance Tec-City and moderate thousands of compliance requirements, opening up new opportunities for foreign businesses in the digital infrastructure, manufacturing and renewable energy sectors, say Mukesh Butani and Seema Kejriwal at BMR Legal.
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High Court Ax Of Atty-Client Privilege Case Deepens Split
The U.S. Supreme Court's recent dismissal of In re: Grand Jury as improvidently granted maintains a three-way circuit split on the application of attorney-client privilege to multipurpose communications, although the justices have at least shown a desire to address it, say Trey Bourn and Thomas DiStanislao at Butler Snow.
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US-India Advance Pricing Resolutions Should Reassure Cos.
The United States' and India's tax authorities' recent resolution of a significant number of pending advance pricing agreements should reduce taxpayer uncertainty, reassure companies of the nations' good working relationship and improve India's investment environment, say Miller Williams and Caroline Setliffe at Eversheds Sutherland.
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Stock Buyback Excise Tax Guidance A Mixed Bag For SPACs
Recent IRS guidance on the new stock repurchase excise tax includes a welcome exception for publicly traded special-purpose acquisition companies but does not exclude redemptions in connection with a de-SPAC transaction, and further guidance is needed to clarify ambiguities around the exception's application, say Olga Bogush and Evgeny Magidenko at ArentFox Schiff.
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The IRS' APA Rulemaking Journey: There And Back Again
Attorneys at Dentons examine recent challenges in which taxpayers successfully argued Internal Revenue Service rulemaking was invalid under the Administrative Procedure Act, how tax exceptionalism and U.S. Supreme Court regulatory deference prompted such challenges, and similar challenges the agency will likely face following this line of cases.
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ECJ Fiat Ruling Sets Clear Boundaries For EU State Aid Law
The European Court of Justice's recent landmark decision in Fiat v. Commission limiting the commission’s attempts to circumvent the lack of EU powers in the area of tax law has important implications in EU state aid law and beyond, say Andreas Reindl and Pietro Stella at Van Bael.
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Unpacking The Interim Guidance On New Stock Buyback Tax
The U.S. Department of the Treasury and Internal Revenue Service's recent notice on applying the newly effective excise tax on stock repurchases provides much-needed clarity on the tax's scope, which is much broader than anticipated given its underlying policy rationale, say attorneys at Eversheds Sutherland.
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IRS Will Use New Resources To Increase Scrutiny In 2023
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.
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How Japan's Implementation May Change The Pillar 2 Debate
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.
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Foreign Tax Credit Proposal Is Some Help, But More Is Needed
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.
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IRS' Tax Gap Statistics Don't Paint A Full Compliance Picture
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.
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How High Court Could Change FBAR Penalty Landscape
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.