International

  • March 15, 2024

    Swiss Senate Votes Not To Consider Tonnage Tax

    The upper house of the Swiss legislature has decided not to consider a tonnage tax proposal, choosing instead to follow the recommendation of a committee that last month recommended not taking up the measure.

  • March 14, 2024

    Taiwanese Gov't Proposes Filing Of Electronic Invoicing

    The Taiwan government's executive branch approved a draft amendment to the island's Value-added and Non-value-added Business Tax Act that would require businesses to file electronic invoices on an open database, the Ministry of Finance announced Thursday.

  • March 14, 2024

    Economists Suggest UN Tackle CFC Rules, Other Tax Policies

    Governments should look at coordinating globally on controlled foreign corporation rules, economic substance requirements, financial transparency, excess profits taxes, inheritance taxes and wealth taxes in negotiations on the nascent United Nations tax convention, economists said Thursday at a conference in Paris.

  • March 14, 2024

    Wealth Tax, Stiff Biz Tax Could Fund Climate Fight, Study Says

    Governments could generate the $500 billion experts think developing countries would need annually to fund the fight against climate change with a 2% global minimum tax on billionaires and a 20% global minimum tax on corporations with no exclusions, the EU Tax Observatory said Thursday.

  • March 14, 2024

    New Zealand Proposes 12% Tax On Overseas Online Casinos

    The New Zealand tax agency proposed Thursday to target the profits of offshore online gambling companies with a 12% tax that would bring in an expected NZ$35 million ($21.5 million) a year.   

  • March 14, 2024

    Israel Tax Authority Claims Owner Of US Biz Underpaid Tax

    A Jerusalem man is suspected of failing to report 50 million Israeli new shekels ($13.7 million) of his income from companies in Israel and abroad, the Israel Tax Authority said Thursday.

  • March 14, 2024

    Brazil Turns To Central Region In Farm Tax Fraud Probe

    Brazil's tax authority is focusing on the country's central region in the next phase of an investigation into a tax avoidance scheme that led it to more than 550 million real ($110.2 million) in uncollected revenue from rural farmers.

  • March 14, 2024

    Nine In 10 Finnish Cos. Report Positive Attitude To Taxation

    Nine of 10 Finnish companies have a positive attitude toward taxation, according to a survey announced Thursday by Finland's Tax Administration.

  • March 14, 2024

    IRS' Signals On Economic Substance Doctrine Draw Scrutiny

    The Internal Revenue Service's recent legal success asserting a doctrine to invalidate transactions in tax law enforcement matters may embolden the government to broaden that argument's reach, and lawyers are concerned it doesn't properly apply to transfer pricing matters.

  • March 14, 2024

    EU Law No Hindrance To Interest Rule, Says ECJ Adviser

    European Union law does not preclude national legislation restricting the ability of taxpayers to deduct interest on a loan that is taken out for non-commercial reasons, an adviser to the bloc's Court of Justice found Thursday.

  • March 13, 2024

    Disney, IBM Seeking Tax Loophole, NY High Court Judge Says

    Disney and IBM's attempt to take New York tax deductions on royalties received from foreign affiliates is "the biggest loophole" that could be created under a former tax statute, a New York high court judge said Wednesday during oral arguments in disputes involving both companies.

  • March 13, 2024

    Siemens Asks Tax Court To Toss $1.2B IRS Bill

    A U.S. subsidiary of German technology company Siemens is pushing the U.S. Tax Court to throw out $1.16 billion in tax deficiencies and penalties the IRS has imposed, saying the agency relied on invalid rules in denying a deduction.

  • March 13, 2024

    JCT Indicates Pillar 1 Is Bad Deal For US, GOP Lawmakers Say

    An analysis of the Organization for Economic Cooperation and Development's Pillar One taxing rights overhaul by congressional scorekeepers makes clear the plan should not receive U.S. support because it would disadvantage U.S. multinationals and federal tax revenue, Republican leaders of Congress' taxwriting committees said Wednesday.

  • March 13, 2024

    Longtime Stradley Ronon Tax Partner Joins Grant Thornton

    Following more than a quarter-century practicing law with Stradley Ronon Stevens & Young LLP, longtime tax attorney Chris Scarpa decided to change career paths, joining accounting firm Grant Thornton LLP.

  • March 13, 2024

    EU Seeks Comments On Double-Tax Dispute Framework

    The European Commission is asking businesses and citizens to weigh in on the European Union's framework for resolving cross-border disputes within the bloc regarding double taxation, the commission said Wednesday.

  • March 13, 2024

    Australia Asking Stakeholders For Goals For New Tax Treaties

    Australia is working to expand its tax treaty network by crafting new agreements with Brazil and Ukraine, as well as updating three other treaties, and is seeking public feedback on what they should cover, its Treasury said Wednesday.

  • March 13, 2024

    EU Parliament Backs Overhaul Of Customs Laws

    A revamp of the European Union's customs code that aims to simplify handling of most imported goods while focusing checks on potentially illicit and tax-dodging shipments was approved by the European Parliament on Wednesday.

  • March 12, 2024

    Irish Co. Can Claim €28M In Foreign Royalty Tax Deductions

    Ireland's tax office wrongfully denied a company €27.8 million ($30.4 million) in tax deductions it had claimed for royalty withholding tax imposed on its income by foreign jurisdictions, the country's Tax Appeals Commission said in a determination released Tuesday.

  • March 12, 2024

    IRS Mulling Partnership Foreign Currency Rules, Official Says

    The Internal Revenue Service will likely propose rules that would provide additional guidance to partnerships for determining taxable income or loss with respect to certain affiliates that conduct business in a foreign currency, an agency official said Tuesday.

  • March 12, 2024

    Calif. Man Agrees To Pay Nearly $500K In FBAR Penalties

    A California man agreed to pay almost $500,000 in penalties, late fees and interest for failing to report his bank accounts in the Bahamas on his tax forms, according to a stipulated order entered by a California federal court.

  • March 12, 2024

    OECD Suggests Ways Romania Can Boost Tax Revenue

    Romania's tax revenue is too low to fund ongoing government spending, and its government should work on changes to its income and value-added tax systems to alter that, the Organization for Economic Cooperation and Development said Tuesday.

  • March 12, 2024

    Tax Officials Say Data Needed To Coax Politicians Into Pillar 2

    The biggest challenge developing countries face in implementing the 15% global minimum tax is persuading politicians, which would be easier if more of them had access to data showing which companies are in-scope, tax officials said Tuesday during an OECD conference.

  • March 12, 2024

    PwC Must Come Clean About Tax Scandal, Aussie Sens Say

    PwC must name the partners who shared confidential drafts of tax laws, release its internal report on the matter and go further than modest self-regulation, Australian senators told Law360 on Tuesday in response to the firm announcing reforms to its governance structure.

  • March 12, 2024

    Netherlands, Bangladesh Reach Deal To Update Tax Treaty

    The Netherlands said Tuesday that it signed an updated double-tax treaty with Bangladesh that broadens the taxing rights of the South Asian country.

  • March 12, 2024

    Businessman Hid $20M In Swiss Accounts, US Says

    A Brazilian-American businessman hid $20 million from the Internal Revenue Service over 35 years using accounts at Swiss banks including UBS and Credit Suisse, the U.S. government said in a criminal complaint that accuses him of conspiring to defraud the U.S. and lying to authorities.

Expert Analysis

  • Curtailing Offshore Tax-Advantaged Investment In China

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    The U.S. government's plans to establish a new outbound investment regime hold the potential to arrest Chinese companies' increasing use of offshore, tax-advantaged locations to raise capital, says David Plotinsky at Morgan Lewis.

  • Cos. May Want To Wait Out US-EU Green Incentives Fight

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    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.

  • India's Budget Proposals May Ease Entry For Certain Sectors

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    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.

  • High Court Ax Of Atty-Client Privilege Case Deepens Split

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    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.

  • US-India Advance Pricing Resolutions Should Reassure Cos.

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    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.

  • Stock Buyback Excise Tax Guidance A Mixed Bag For SPACs

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    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.

  • The IRS' APA Rulemaking Journey: There And Back Again

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    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.

  • ECJ Fiat Ruling Sets Clear Boundaries For EU State Aid Law

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    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.

  • Unpacking The Interim Guidance On New Stock Buyback Tax

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    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.

  • IRS Will Use New Resources To Increase Scrutiny In 2023

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    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.

  • How Japan's Implementation May Change The Pillar 2 Debate

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    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.

  • Foreign Tax Credit Proposal Is Some Help, But More Is Needed

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    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.

  • IRS' Tax Gap Statistics Don't Paint A Full Compliance Picture

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    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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