International

  • June 11, 2024

    House Panel Chair Seeks To End Media Org's Tax Exemption

    The House's top tax writer wants the Internal Revenue Service to revoke the tax-exempt status of a nonprofit Mideast-focused news outlet, telling Commissioner Daniel Werfel that the organization is aiding Hamas.

  • June 11, 2024

    Lawmakers Urge Biden To Back Brazil's Int'l Wealth Tax Plan

    Sen. Bernie Sanders and Democratic lawmakers asked the Biden administration Tuesday to support the global minimum tax on billionaires being proposed by Brazil, which is encouraging the Group of 20 nations to endorse the initiative at its meetings next month.

  • June 11, 2024

    Kostelanetz Partners Talk Benefits Of Atlanta Tax Firm Tie-Up

    Kostelanetz LLP partners Bryan Skarlatos and Todd Welty discuss the firm’s recent combination with Atlanta boutique Welty PC.

  • June 11, 2024

    Democratic Republic Of Congo Joins African Tax Coalition

    The Democratic Republic of the Congo has officially joined the African Tax Administration Forum as its 44th member, the group announced.

  • June 11, 2024

    Tory Tax Cut Plans Raise Questions On Funding Gaps

    The prime minister unveiled plans for £17.2 billion ($21.8 billion) in tax cuts at the launch of the Conservative Party's election manifesto on Tuesday, but a headline cut of two percentage points in the payroll tax was put off for three years — and funding plans left some experts unconvinced.

  • June 11, 2024

    French Tax Law Challenged On Free Movement Grounds

    The European Court of Justice is examining a French law regarding undeclared assets held outside the country to determine whether it is in line with the European Union's law respecting free movement of capital, the EU's official journal said.

  • June 11, 2024

    Sunak Pledges Further Tax Cuts In Election Manifesto

    Rishi Sunak said on Tuesday that his Conservative Party would establish a tax system that "rewards work" by slashing a range of levies if it wins the general election, including another cut in the national payroll tax by 2027.

  • June 10, 2024

    Canadian Gov't Proposes Capital Gains Tax Hike

    A new tax rate on capital gains realized annually above CA$250,000 ($181,700) by individuals and on all capital gains realized by Canadian corporations would go into effect this month under a proposal introduced by Canada's finance minister Monday.

  • June 10, 2024

    Big Tech Urges US Reprisal Over Canada's Impending DST

    The Office of the U.S. Trade Representative should open formal dispute proceedings with the Canadian government in response to a 3% digital services tax that is expected to soon pass in the Canadian Senate, business groups with members in the U.S. tech industry said Monday.

  • June 10, 2024

    UN Aims To Finish Drafting Tax Convention By Fall 2026

    The United Nations should aim to finish a framework convention on international tax cooperation and early protocols that address taxation of the digital economy, cross-border services and high-net-worth individuals by September 2026, according to draft terms of reference open for comment through June 21.

  • June 10, 2024

    3rd Prime Suspect Arrested In €50M Italian VAT Fraud Ring

    The Italian Financial Police arrested a third person suspected of leading a value-added tax fraud scheme involving sales of over 3 million Apple AirPods that caused an estimated €50 million ($54 million) in losses, the European Public Prosecutor's Office said Monday.

  • June 10, 2024

    Authorities Arrest Danish Suspect In €85M VAT Fraud In Kenya

    A Dane suspected of leading an €85 million ($91 million) value-added tax fraud ring was apprehended in Kenya after having fled Denmark late last year, the European Public Prosecutor's Office said Monday.

  • June 10, 2024

    Latvia Parliament Passes Parts Of Minimum Tax Directive

    Under pressure from the European Union, Latvia's Parliament approved a bill transposing portions of the bloc's directive to implement the Organization for Economic Cooperation and Development's Pillar Two standards to prevent tax base erosion and profit shifting.

  • June 10, 2024

    Singapore Seeks Opinions On OECD's Minimum Tax Plan

    Singapore is seeking public feedback on a proposal that would introduce the Organization for Economic Cooperation and Development's corporate global minimum tax, the country's Ministry of Finance said Monday.

  • June 10, 2024

    EU Commission Invites Experts To Anti-Tax-Evasion Forum

    The European Union's executive arm issued a call Monday for nongovernmental organizations to apply to join a platform that discusses measures against tax evasion and avoidance outside the bloc.

  • June 10, 2024

    EU Countries To Aim Again For VAT Deal, Agenda Says

    European Union countries will again discuss proposed changes to the bloc's value-added tax laws at a meeting next week, aiming to find a deal after one country blocked agreement, according to a meeting agenda.

  • June 10, 2024

    Lib Dems Vow To Raise Capital Gains Tax For UK's Wealthiest

    The U.K.'s third-largest political party vowed on Monday to raise taxes on the country's wealthiest individuals if it wins the next election, in a bid to raise £5 billion ($6.4 billion) for the National Health Service.

  • June 10, 2024

    What Tax Experts Hope To See In Labour's Manifesto

    Labour's policy manifesto, expected to be unveiled on Thursday, will be studied by tax lawyers for more detail on the fiscal planning being carried out by the clear favorite to win the general election, including a final word on lifetime pension savings.

  • June 07, 2024

    IRS Updates EV Battery Reporting Guide For Tax Credits

    The Internal Revenue Service provided updated guidance Friday for automakers planning to provide a report on meeting the battery sourcing requirements that can qualify their new electric vehicle models for the consumer tax credit of up to $7,500.

  • June 07, 2024

    NZ Sets Foreign Investment Interest Deemed Rate Of Return

    New Zealand has set the deemed rate of return for attributing interest on foreign investment funds — one of the ways to calculate income from such sources for tax purposes — at 8.63% for the 2023-24 income year, the country's revenue agency said.

  • June 07, 2024

    Dentons Adds Pair Of Husch Blackwell Tax Attys

    Two South Carolina tax attorneys have joined Dentons' corporate, tax and private client practice as partners after moving from Husch Blackwell LLP, the firm announced on Thursday.

  • June 07, 2024

    Halliburton Wrongly Denied $11.3M Deduction, Court Told

    The Internal Revenue Service is arbitrarily and wrongfully refusing to refund Halliburton over $11.3 million in tax deductions taken for a payment to a foreign government to secure the safety of the company's employees, Halliburton told a federal court.

  • June 07, 2024

    Chile Says Filing Restriction Program Stopped $203M In Fraud

    Chile's tax agency said Friday that its strategy for blocking value-added tax fraud via fraudulent invoices prevented the disbursement of 186 billion Chilean pesos ($203 million) of incorrect value-added tax credits since the start of 2023 through April 2024.

  • June 07, 2024

    Taxation With Representation: Vinson, Latham, Ropes & Gray

    In this Week's Taxation with Representation, Waste Management buys Stericycle, Becton Dickinson pays $4.2 billion for Edwards Lifesciences' critical care products unit, Aquiline Capital Partners raises over $3.4 billion in fund capital, and Bain Capital buys PowerSchool Holdings.

  • June 07, 2024

    Swiss Launch Consultation On Data Exchange Law

    The Swiss government said Friday that it has begun a consultation on a law concerning the international exchange of salary data, which it says is needed to support laws pertaining to the taxation of cross-border workers.  

Expert Analysis

  • Private Equity Owners Can Remedy Law Firms' Agency Issues

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    Nonlawyer, private-equity ownership of law firms can benefit shareholders and others vulnerable to governance issues such as disparate interests, and can in turn help resolve agency problems, says Michael Di Gennaro at The Law Practice Exchange.

  • How Taxpayers Can Prep As Justices Weigh Repatriation Tax

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    The U.S. Supreme Court might strike down the 2017 federal tax overhaul's corporate repatriation tax in Moore v. U.S., so taxpayers should file protective tax refund claims before the case is decided and repatriate previously taxed earnings that could become entangled in dubious potential Section 965 refunds, say Jenny Austin and Gary Wilcox at Mayer Brown.

  • OFAC Designation Prosecutions Are Constitutionally Suspect

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    Criminal prosecutions based on the Office of Foreign Assets Control’s sanctions-related listing decisions — made with nearly unfettered discretion through an opaque process — present several constitutional issues, so it is imperative that courts recognize additional rights of review, say Solomon Shinerock and Annika Conrad at Lewis Baach.

  • How The OECD Global Tax Proposal Could Affect M&A

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    Following agreement on the Organization for Economic Cooperation and Development’s Pillar Two proposal to introduce a global minimum tax, domestic implementation is expected to have a significant impact on international M&A transactions, with financial modeling, deal structuring, risk allocation and joint venture arrangements likely to be affected, say lawyers at Freshfields.

  • UK Shares-Tax Proposals Offer Long-Awaited Modernization

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    The U.K. government's recent consultation on the introduction of a new tax on transactions in securities raises detailed legal and practical issues, but the prospect of a single digital stamp tax offering both streamlined legislation and administration will be welcomed, say Zoë Arnautov and Mark Sheiham at Simmons & Simmons.

  • IRS Foreign Tax Credit Pause Is Welcome Course Correction

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    A recent IRS notice temporarily suspending application of 2022 foreign tax credit regulations provides wanted relief for the many U.S. multinational companies and other taxpayers that otherwise face the risk of significant double taxation in their international operations, say attorneys at Mayer Brown.

  • IRS Criminal Probe Spells Uncertainty For Malta Pension Plans

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    The IRS’ recent scrutiny of Malta pension plan arrangements — and its unusual issuance of criminal administrative summonses — confirms that it views many of these plans as illegal tax evasion schemes, and the road ahead will not be smooth and steady for anyone involved, say attorneys at Kostelanetz.

  • IRS Announcement Will Aid Cos. In Buyback Tax Planning

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    Recent IRS transitional guidance regarding current requirements for reporting and payment of the stock repurchase excise tax will help corporate taxpayers make decisions about records retention and establishing reserves for future tax payments, say Xenia Garofalo and Kyle Colonna at Eversheds Sutherland.

  • Flawed Analysis Supports Common Law Tax Deficiency Ruling

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    The Colorado federal district court’s recent decision in Liberty Global, holding that the U.S. Department of Justice may assert a common law tax claim without the notice of tax deficiency required by the Internal Revenue Code, relies on a contorted reading of the statute and irrelevant case law, say Loren Opper and Christie Galinski at Miller Canfield.

  • 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.

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