International

  • May 16, 2024

    Australian Lawmakers OK Tougher Corporate Promoter Rules

    Australian lawmakers agreed Thursday to raise maximum penalties on corporations that promote tax avoidance schemes and to introduce a cap on deductions under its petroleum resource rent tax despite concerns from some members, according to documents published by Parliament.

  • May 16, 2024

    P&G Exec Says FDII Uncertainty May Sway Cos.' IP Decisions

    The 2017 tax overhaul's measure for foreign-derived intangible income, a regime that gives tax breaks for domestically held intellectual property, faces uncertainty that could be one factor in keeping some companies from repatriating IP, a tax executive for Procter & Gamble said Thursday.

  • May 16, 2024

    Eaton Must Give Up Personnel Docs In Transfer Pricing Probe

    Eaton must comply with an Internal Revenue Service summons for the personnel records of its foreign employees in the government's transfer pricing investigation of the multinational power management company, an Ohio federal judge ruled Thursday.

  • May 16, 2024

    African Tax Admins Promote Use Of Voluntary Disclosures

    Voluntary disclosure programs have been very effective when countries launch them in anticipation of complying with an international standard on automatic exchanges of financial account information, the African Tax Administration Forum said Thursday in guidance on the programs.

  • May 16, 2024

    Kenya Considering Global Minimum Tax, DST Replacement

    Kenya is considering legislation that would implement the Organization for Economic Cooperation and Development's corporate global minimum tax as well as repeal and replace the country's digital services tax.

  • May 16, 2024

    Germany's 2024 Tax Revenue Estimate Drops By €14B

    Germany's 2024 tax revenue estimate decreased by roughly €14 billion ($15.2 billion) to €950.3 billion from the estimate made last fall, which its finance ministry said Thursday was due to slower-than-expected economic recovery.

  • May 16, 2024

    Suspected Ringleader Of €2M Cosmetics VAT Fraud Arrested

    The suspected ringleader of a value-added tax fraud scheme at a cosmetics company that caused more than €2 million ($2.2 million) in estimated losses has been arrested by Italian police, the European Public Prosecutor's Office said Thursday.

  • May 16, 2024

    EU Tax On Excess Corp Profits Could Yield €107B, Study Says

    A European Union tax on excessive corporate profits could yield about €107 billion ($116 billion) to partly finance the common EU budget or other urgent investments, leftists in the European Parliament said Thursday.

  • May 16, 2024

    Treasury Provides Extra Relief For Bonus Energy Tax Credits

    The U.S. Treasury Department provided additional safe harbors Thursday that clean energy project developers can use to qualify for bonus tax credits for domestically sourcing their steel and aluminum parts in response to the Biden administration's new trade restrictions on solar products from China.

  • May 16, 2024

    Lithuania PM Wants Frozen Russian Assets To Help Ukraine

    Lithuania's prime minister said Thursday that Russia's frozen assets should be used to help Ukraine fight off aggression from its larger neighbor, saying that a recent European decision to use profits from frozen assets should be only a first step.

  • May 15, 2024

    Russian Gas Ex-CFO Can't Nix $44M FBAR Suit, Judge Rules

    The former chief financial officer of a Russian gas company who was sentenced to seven years in prison for hiding money in Swiss banks can't escape the government's civil suit seeking nearly $44 million in reporting penalties, a Florida federal judge ruled Wednesday.

  • May 15, 2024

    EU Court Upholds Ruling Against Spanish Ship Tax Scheme

    The European Union's General Court upheld Wednesday a European Commission ruling that a Spanish tax scheme for ships constructed in the nation's domestic shipyards was incompatible with the EU's internal market.

  • May 15, 2024

    Schulte Roth Adds Ex-Kleinberg Kaplan Partner To Tax Group

    Schulte Roth & Zabel LLP added a former Kleinberg Kaplan Wolff & Cohen PC partner with a focus on private investment funds to its tax group in New York.

  • May 15, 2024

    3 Key Takeaways From Floated Foreign Trust Reporting Rules

    Proposed rules for reporting transactions with foreign trusts recently issued by the U.S. Treasury Department provide breathing room on disclosure requirements for certain offshore retirement accounts, but leave open some questions about classification. Here, Law360 breaks down three sections of the proposed foreign trust reporting regulations.

  • May 15, 2024

    South African Tax Official Says Data Swaps Too Limited

    South Africa's requests to exchange information on taxpayers with authorities around the world are often denied for criminal investigations of tax crimes, while automatic exchanges sometimes lack the full identifying information of taxpayers, the commissioner of the country's tax agency said Wednesday.

  • May 15, 2024

    Taxpayers Let Down By HMRC Digital Service, Says Watchdog

    HM Revenue and Customs has let down taxpayers by failing to deliver better online services, according to a report published on Wednesday by the public spending watchdog.

  • May 15, 2024

    Swiss Seek Feedback On Crypto Information Exchange

    Switzerland's executive body, the Federal Council, is seeking feedback from the public on its plan to adopt two Organization for Economic Cooperation and Development standards that will update the country's automatic exchanges of information to account for crypto-assets, it said Wednesday.

  • May 15, 2024

    11 Arrested In €25M Italian VAT Fraud Case

    Italian police arrested 11 suspects in a value-added tax fraud ring involving electronic products that resulted in losses of over €25 million ($27.2 million), the European Public Prosecutor's Office said Wednesday.

  • May 15, 2024

    Gentiloni Warns EU States Not To Be Too Harsh With Budgets

    European Union tax commissioner Paolo Gentiloni warned EU countries Wednesday not to be too aggressive with budget cuts, even as some may have to take a more restrictive fiscal stance this year and next than had been planned. 

  • May 15, 2024

    German Finance Minister Wants Lower Tax Burden

    Germany's finance minister said he would like to see the tax burden lowered as part of a broader push to make life less burdensome for industry as the country tries to stimulate economic growth.

  • May 15, 2024

    EU Finance Ministers Plan Road To Tax Revamp

    European Union finance ministers agreed on a work program to implement about 40 measures to improve business financing, including a targeted makeover of tax systems in member countries covering corporate taxes, capital gains and tax breaks for interest payments.

  • May 14, 2024

    A Fifth Of Big Cos. Use Tax Transparency Standard, Org. Says

    About a fifth of the largest 1,000 public companies worldwide have voluntarily used a public country-by-country reporting standard created by an international independent standards organization, the nonprofit said Tuesday.

  • May 14, 2024

    Law Prof Comes To Treasury's Aid In 3M Transfer Pricing Fight

    The U.S. Department of the Treasury did not act arbitrarily when it wrote transfer pricing regulations that allowed the government to disregard foreign legal restrictions on royalty payments when allocating income to 3M from an affiliate, a law professor told the Eighth Circuit on Tuesday.

  • May 14, 2024

    Solarium Sunbaths Not Tax-Free Wellness, Sweden Says

    After receiving multiple questions about whether paying to sunbathe in a solarium is eligible for Sweden's tax-free wellness allowance, the country's tax agency said Tuesday that such activity is not eligible.

  • May 14, 2024

    Microsemi Calls IRS' Penalty Approval 'Woefully Inadequate'

    An Internal Revenue Service supervisor's sign-off on a transfer pricing penalty for Microsemi was "woefully inadequate" to meet statutory requirements for penalty approval, the semiconductor manufacturer told the U.S. Tax Court.

Expert Analysis

  • 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.

  • 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.

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