International

  • October 17, 2024

    Vestager Urges EU Politicians To Push Ahead With Pillar 1

    European Union competition chief Margrethe Vestager urged EU politicians Thursday to push ahead with work to finalize the Pillar One plan to redistribute taxing rights among countries.

  • October 17, 2024

    Polsinelli Hires McDermott Tax Counsel In DC

    Polsinelli PC has hired an attorney who joined the firm's tax group as a shareholder after 12 and a half years with McDermott Will & Emery LLP.

  • October 17, 2024

    EU Frequent Flyer Tax Could Raise €64B, Think Tank Says

    The European Union could raise an estimated €63.6 billion ($68.9 billion) in revenue by taxing frequent flyers, according to a think tank report published Thursday.

  • October 16, 2024

    Utah Groups Can't Scrap Corporate Transparency, US Says

    A Utah federal court hasn't seen sufficient evidence to block the Corporate Transparency Act's disclosure requirements in presentations by an off-the-grid community, an online meat market and a trade group for cattle producers that have sued over the statute, the federal government said.

  • October 16, 2024

    Japan Signs Double-Tax Treaty With Armenia

    Japan and Armenia have reached an agreement on a double-tax treaty to replace the convention Japan had with the Soviet Union, Japan's Ministry of Finance said Wednesday.

  • October 16, 2024

    Spain's High Court Annuls Rulings Denying R&D Deductions

    Spain's Supreme Court overturned a lower court's ruling that sided with a decision from revenue officials to ignore a report from the country's science ministry when denying corporate tax deductions for research and development.

  • October 16, 2024

    Swedish Parliament To Consider Global Min. Tax Amendments

    Sweden's government sent draft amendments regarding the country's implementation of the Organization for Economic Cooperation and Development's 15% global corporate minimum tax to its Parliament for consideration, the country's Ministry of Finance said.

  • October 16, 2024

    Switzerland Enshrines Ability To Tax Certain Telecommuters

    Switzerland has ensured it will be able to tax employees' earned income if they telework in their country of residence for an employer based in Switzerland — under certain circumstances — starting in 2025, the country's executive body said Wednesday.

  • October 16, 2024

    Romania Suspends Double-Tax Treaty With Russia

    Romania has completely suspended its double-tax treaty with Russia in response to Russia's cessation of parts of the treaty last year, the Romanian Ministry of Finance said Wednesday.

  • October 15, 2024

    Microsoft's Cost-Share Tax Arguments 'Deficient,' Mich. Says

    Microsoft failed to adequately flesh out its arguments that cost-sharing agreement receipts from affiliates should be included in its Michigan apportionment formula as licenses of intellectual property, the state's tax agency argued in asking the Michigan Tax Tribunal to toss the company's case.

  • October 15, 2024

    Irish Tax-To-GDP Ratio Expected To Drop In 2025

    Ireland's tax revenue as a share of its gross domestic product is projected to drop to 25.3% in 2025 as a result of tax measures included in the country's budget proposal, a drop of 3.1 percentage points compared with projections for this year, the country's Department of Finance said Tuesday.

  • October 15, 2024

    Israel-US Citizen Owes $1.1M In FBAR Penalties, US Says

    A dual Israeli-American citizen who owns a Chicago pub faces more than $1 million in penalties for failing to report bank accounts that he maintained in Israel, the U.S. government told an Illinois federal court.

  • October 15, 2024

    New ABA Tax Chair Wants To Revamp Practice's Dry Image

    The new chair of the American Bar Association Section of Taxation told Law360 she wants to boost the section's recent efforts to revamp the tax practice's image as a boring, numbers-intensive profession with limited opportunities to improve society and inspire more students to enter tax law. Here, she shares her background and goals for the tax section.

  • October 15, 2024

    Alvarez & Marsal Tax Brings On Restructuring Leader

    Alvarez & Marsal's tax affiliate added a restructuring professional from investment bank Houlihan Lokey to serve as its head of global restructuring tax services.

  • October 15, 2024

    Isle Of Man Could Generate £35M Annually From Min. Tax

    The Isle of Man's planned implementation of parts of the Organization for Economic Cooperation and Development's global corporate minimum tax on large multinational entities could generate as much as £35 million ($45 million) for the jurisdiction annually, its Treasury said Tuesday.

  • October 15, 2024

    V&E Adds Energy Tax Pro From Bracewell In Houston

    Vinson & Elkins LLP has bolstered its energy transition and tax practices with a partner in Houston who came aboard from Bracewell LLP and whose background includes substantial in-house experience advising on renewable projects.

  • October 15, 2024

    Starmer Hints At National Insurance Hike Over Capital Gains

    British Prime Minister Keir Starmer on Tuesday again refused to rule out raising employers' National Insurance, a payroll levy used to fund social programs, after downplaying claims that his government is planning to raise the capital gains tax.

  • October 15, 2024

    Law Firms Diverge As Anti-ESG Pushback Continues

    A continuing onslaught of legislation and litigation opposing corporate environmental, social and governance actions has created a fork in the road for law firms, with some choosing to scale back efforts and others pushing ahead with their internal ESG and diversity, equity and inclusion goals.

  • October 15, 2024

    The 2024 Law360 Pulse Social Impact Leaders

    Check out our Social Impact Leaders ranking, analysis and interactive graphics to see which firms stand out for their engagement with social responsibility and commitment to pro bono service.

  • October 11, 2024

    Danish Tax Agency Sniffs Out $367M In VAT Fraud

    The Danish Tax Agency said it has issued collections for roughly 2.5 billion Danish kroner ($367 million) since 2018 against companies it discovered were carrying out cross-border value-added tax fraud schemes known as VAT carousels.

  • October 11, 2024

    France Targets Largest Cos. With Tax In Austerity Budget

    The French government said it plans to implement a temporary tax targeting the country's biggest companies as part of a budget of €61.3 billion ($67 billion) of fiscal changes intended to help bring the deficit in line with European Union rules.

  • October 11, 2024

    Italian Police Freeze €12.3M In Textile VAT Fraud Investigation

    The Italian Financial Police carried out two freezing orders totaling €12.3 million ($13.5 million) against suspects in an ongoing investigation into a value-added tax fraud involving the illegal importation of textiles from China, the European Public Prosecutor's Office said.

  • October 11, 2024

    Bird & Bird Adds DLA Piper Legal Director To London Office

    Bird & Bird LLP has added a former DLA Piper legal director as a partner to its London tax team. 

  • October 11, 2024

    Disputes May Loom Over Dividend Deductions For CFCs

    U.S. multinational corporations are concerned that rulemakers' interpretation of a law allowing tax-free repatriation of certain overseas earnings could lead to controversy after the Internal Revenue Service published a memo indicating the break is unavailable for controlled foreign corporations.

  • October 11, 2024

    Fla. Businessman's Estate Faces $2.6M In FBAR Penalties

    A Florida businessman's estate owes the federal government $2.6 million in penalties plus interest for his failure to report his Swiss bank account from 2013 to 2017, the government told a federal court.

Expert Analysis

  • Corporate Reporting Considerations As Tax Meets ESG

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    With the U.S. Securities and Exchange Commission filing season upon us amid increasing pressure for greater transparency around effective tax rates and tax strategies, multinational companies must decide how they will approach voluntary tax reporting and prepare their responses if they want to control the narrative, say Michael Lebovitz and Jenny Austin at Mayer Brown.

  • The Highs And Lows Of Tax Controversy In 2021

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    Lawrence Hill at Steptoe & Johnson reviews the ups and downs of tax controversy practice in 2021, including the continued effects of the pandemic, troubling decisions on attorney-client privilege and an IRS comeback on transfer pricing.

  • Lessons From IRS For A New HMRC Whistleblowing Model

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    Andrew Park at Andersen considers whether the public interest would be better served in allowing the U.K.'s tax enforcers, HM Revenue & Customs, to offer larger and more certain cash incentives to people blowing the whistle on tax misdemeanors — similar to the IRS model for whistleblowers.

  • The Benefits Of Competent Authority In Int'l Tax Disputes

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    Multinational enterprises seeking relief from double taxation in a changing international tax landscape should consider utilizing the competent authority process, which provides both taxpayers and domestic tax regulators an efficient and effective means of dispute resolution, say David Farhat and Eman Cuyler at Skadden.

  • How OECD Transfer Tax Initiative Affects Smaller Businesses

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    Small and midsize enterprises with cross-border transactions need to consider redefining tax strategies and operational models in light of the Organization for Economic Cooperation and Development's base erosion and profit shifting initiative, even though the agency's new tax guidelines are aimed at large multinational enterprises, says Ganesh Ramaswamy at Kreston Rangamani.

  • What The New OECD Double-Tax Procedure Statistics Tell Us

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    Monique van Herksen and Clive Jie-A-Joen at Simmons & Simmons consider the Organization for Economic Cooperation and Development’s recent report on double taxation cases resolved in 2020 under the mutual agreement procedure process, and examine whether the process has improved dispute resolution mechanisms since its implementation five years ago.

  • Navigating FCPA Risks Of Minority-Owned Joint Ventures

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    The U.S. Department of Justice and U.S. Securities and Exchange Commission will likely continue to focus on third-party risks under the Foreign Corrupt Practices Act, so companies with minority-owned joint ventures should take several steps to mitigate related compliance challenges, say Ben Kimberley at The Clorox Company and Addison Thompson at Covington.

  • Questions To Ask If Doing Business In A Corruption Hot Spot

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    Businesses facing new scrutiny after the U.S. Department of Justice's recently announced task force for combating human trafficking in Central America, the release of the Pandora Papers and continuing fallout from 2019's Panama Papers, should address compliance risks by having employees ask three questions about every transaction, say attorneys at White & Case.

  • How The Global Tax Agreement Could Backfire For Biden

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    If the $3.5 trillion spending package fails, the federal tax code will not conform to the recent 15% global minimum tax agreement spearheaded by the U.S., which would embarrass the Biden administration and could lead to retaliatory tax measures by other nations, says Alex Parker at Capitol Counsel.

  • Pandora Papers Reveal Need For Greater Tax Enforcement

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    The recent Pandora Papers leak is a reminder of the importance of transparency laws and proper funding for enforcement efforts against tax evasion as bad actors increasingly operate in the shadows, says Daren Firestone and Kevin Crenny at Levy Firestone.

  • Parsing New Int'l Tax Reporting Rules For Pass-Throughs

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    Attorneys at Grant Thornton unpack the Internal Revenue Service’s new pass-through entity reporting requirements for international tax matters and the accompanying guidance for penalty relief, and suggest how companies should prepare for what may be the most significant change to the partnership compliance function in decades.

  • A Look At Global Tax Enforcement Developments: Part 2

    Excerpt from Practical Guidance
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    Sean Craig at LexisNexis examines recent investigations by the Joint Chiefs of Global Tax Enforcement and their impact on U.S. taxpayers, as well as the growing significance of transfer pricing disputes and policies for future enforcement.

  • A Look At Global Tax Enforcement Developments: Part 1

    Excerpt from Practical Guidance
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    Sean Craig at LexisNexis looks at how international initiatives, such as the Joint Chiefs of Global Tax Enforcement, are addressing cryptocurrency-related tax evasion, and how the COVID-19 pandemic and increasing demands for governmental welfare programs are driving global tax policy.

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