International

  • March 19, 2024

    OECD Deputy Tax Director To Leave Post In June

    A deputy tax director for the Organization for Economic Cooperation and Development announced he is stepping down from his position at the end of June after nearly a decade there working on international tax policy.

  • March 19, 2024

    Exxon Wants Closed Court In $1.8B Tax Trial

    Exxon Mobil plans to seek courtroom closures for parts of an upcoming trial in its $1.8 billion suit challenging denied tax deductions for payments it made to Qatar, telling a Texas federal court that certain testimony, if made public, would damage its relationship with the foreign partner.

  • March 19, 2024

    HMRC Under Fire For Sharply Cutting Back Helpline Service

    The U.K. tax authority has moved too quickly to phase out helpline services for taxpayers filing self-assessment returns this year, members of Parliament said Tuesday.

  • March 19, 2024

    EU Parliament Committees Approve AML Laws

    Two European Parliament committees approved new anti-money laundering legislation Tuesday for the European Union to create a single rule book for all 27 EU countries and to establish a common enforcement authority.

  • March 19, 2024

    Compliance Costs Call For Border Fee, France's Le Maire Says

    The cost of compliance with European environmental rules justifies the European Union's recently launched carbon border tax, which is designed to raise the price of imports with lower environmental standards, French Finance Minister Bruno Le Maire said Tuesday.

  • March 19, 2024

    UK Energy Co. Fights To Deduct £2.5M Deal Advice Fees

    An investment holding company told the Supreme Court on Tuesday that £2.5 million ($3.2 million) it paid to Deutsche Bank and others for deals advice is tax-deductible because they were the "type of services procured all the time."

  • March 18, 2024

    HMRC Defends Response To Tax Avoidance Ploy

    The U.K. tax authority has rejected claims that it has been "heavy-handed" by applying the loan charge to users of disguised remuneration schemes, according to a letter released on Tuesday by the Treasury Committee.

  • March 18, 2024

    Australia Seeks Input On Revised Energy Tax Regulations

    Australia's Department of the Treasury is seeking responses from the public to a draft of updated regulations for determining petroleum resource rent tax, the department announced Monday.

  • March 18, 2024

    Justices Won't Review Dead Film Exec's IRS Summons

    The U.S. Supreme Court on Monday denied a request from the daughter of a dead film executive to consider invalidating an IRS summons for her father's financial records, letting stand a Ninth Circuit decision that found the agency sought the records in good faith.

  • March 18, 2024

    Treasury Mulling Whether To Keep Foreign Tax Credit Regime

    The U.S. Treasury Department is considering whether the best way to provide administrable foreign tax credit rules and address related policy concerns is to retain the framework from paused final regulations or develop a new one, a Treasury official said Monday.

  • March 18, 2024

    Gov'ts Widely Back Building Capacity Of Tax Authorities

    Building the skills and capacities of tax authorities to implement international tax standards should be a central focus of global tax cooperation at the United Nations for governments to gain revenue, officials from the U.S., the African Group and many others said Monday.

  • March 18, 2024

    Axed HMRC Staffer Wins £16K Disability Discrimination Case

    HM Revenue and Customs must pay a disabled former employee £15,900 ($20,200) after it unfairly sacked him for gross misconduct and wrote off his claim that his sleep apnea was to blame, a Scottish tribunal has ruled.

  • March 18, 2024

    Wyden, Whitehouse Scrutinize DOJ's Caterpillar Investigation

    Two top Democratic senators asked the U.S. Justice Department about its handling of a criminal inquiry into Caterpillar for potential financial crimes and corporate tax fraud after receiving evidence corroborating a report that former DOJ officials may have suppressed the investigation, according to a letter released Monday.

  • March 18, 2024

    FCA Levies £5.95M Fine In Fake Dividend Tax Reclaim Case

    The Financial Conduct Authority said Monday it had decided to fine the former chief executive of Indigo Global Partners Ltd. £5.95 million ($7.57 million) and ban him from the industry for participating in a Danish tax scam that falsely reclaimed dividend taxes on shares.

  • March 18, 2024

    Serving Claims To HMRC By Email Made Permanent

    Claimants pursuing legal action against the U.K. tax authority in England and Wales will continue to be able to serve documents by email, HM Revenue and Customs said Monday, making the process it introduced during the COVID-19 pandemic permanent.

  • March 18, 2024

    Polish Senate Committee Objects To EU BEFIT Proposal

    A Polish Senate committee has objected to a new legislative proposal for corporate taxation in the European Union because it said it may lead to a loss of tax income and weaken the country's investment support programs.

  • March 15, 2024

    UAE Seeks Public Input On Global Minimum Tax

    The United Arab Emirates is seeking public comments on implementing the global minimum tax under the OECD's tax reform plan, along with other tax issues, the country's Ministry of Finance announced Friday.

  • March 15, 2024

    France's Green Energy Investment Tax Credit Now In Effect

    Companies operating in France's wind power sector and other clean energy industries will now be able to use the country's new green investment tax credit, the French finance ministry said Friday.

  • March 15, 2024

    Bechtel's Appeal Tossed In $8.5M Australian Tax Case

    Bechtel Corp. must pay taxes of AU$13 million ($8.5 million) on costs of transporting employees to a worksite because the travel did not occur in the course of producing income, a Federal Court of Australia panel said Friday.

  • March 15, 2024

    The Tax Angle: House GOP Plots TCJA Renewal Strategy

    House Republicans left Washington this week for their annual two-day legislative issues conference, hoping to expand their control of the chamber in the upcoming November elections and planning their strategy for renewal of their historic 2017 tax overhaul law.

  • March 15, 2024

    Tax Foundation Says UN Should Avoid Duplicating Tax Efforts

    The United Nations should only create global tax rules in areas where it can effectively reduce uncertainty and should avoid duplicating negotiations underway elsewhere, the Tax Foundation said Friday in a response to the organization.

  • March 15, 2024

    Netherlands Enters Tax Treaty Talks With 3 More Countries

    The Netherlands government announced plans to negotiate 13 tax treaties this year, including work on agreements with three new countries.

  • March 15, 2024

    Direct Hit On Tax Regs Unlikely If Justices Ditch Chevron

    A decision from the U.S. Supreme Court later this year on two cases challenging the so-called Chevron doctrine, which gives federal agencies wide latitude to interpret ambiguous laws, isn't likely to immediately affect tax regulations.

  • March 15, 2024

    Colombia, Norway Aim To Harmonize UN And OECD Tax Work

    Colombia and Norway are aiming to bring the best aspects of the OECD's tax work into negotiations at the United Nations while drafting a framework convention on global tax cooperation, officials said Friday during a conference in Paris.

  • March 15, 2024

    Taxation With Representation: Freshfields, Kirkland

    In this week's Taxation with Representation, AstraZeneca acquires Amolyt Pharma, XCF Global Capital goes public and EQT Corp. merges with Equitrans Midstream Corp.

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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