International

  • August 06, 2024

    Treasury Floats Rules To Address Losses Under Pillar 2

    The U.S. Treasury Department proposed regulations Tuesday that outline when foreign taxes under the Pillar Two international minimum tax agreement could trigger long-standing U.S. rules that aim to prevent companies from what is known as double-dipping the same economic loss.

  • August 06, 2024

    Ex-UBS Exec Calls $4.7M In FBAR Penalties Unconstitutional

    A former executive for Swiss bank UBS' North American group told a Connecticut federal court the $4.7 million in penalties he faces for willful failure to report his foreign bank accounts are unconstitutionally excessive.

  • August 06, 2024

    Australia Provides Thin Capitalization Rules Guidance

    The Australian Taxation Office published guidance for compliance with the country's new thin capitalization rules, including the new earnings-based tests and other provisions.

  • August 06, 2024

    OECD Tax Center Shuffling Leadership Team

    The Organization for Economic Cooperation and Development made multiple senior appointments within its Center for Tax Policy and Administration, Director Manal Corwin announced, including replacing its recently departed deputy director.

  • August 06, 2024

    Arnold & Porter Adds Abramson Cancer Center Chief Counsel

    Throughout her career and while working in progressive leadership roles for the Abramson Cancer Center at the University of Pennsylvania, Mir Masud-Elias, Arnold & Porter Kaye Scholer LLP's newest counsel, has asked herself the same question: Is this role the best use of her time on Earth?

  • August 06, 2024

    Paul Hastings Gains Tax Pro In Dallas From McDermott

    Paul Hastings announced Tuesday that its meteoric growth in Texas is continuing with the addition of a partner in Dallas who strengthens its global tax practice and came aboard from McDermott Will & Emery LLP.

  • August 06, 2024

    Austria Records 'Problematic' Rise In Fake Companies

    Fake companies are on the rise in Austria, the country's Finance Ministry said Tuesday, adding that it hoped that a newly agreed-to law against tax evasion and fraud could reverse the trend.

  • August 05, 2024

    FedEx Asserts Chevron Ruling Supports $84.6M Refund

    The U.S. Supreme Court's recent rejection of the Chevron doctrine entitles FedEx to an $84.6 million tax refund by taking credits for foreign taxes it paid on offset earnings when repatriating overseas income, the package delivery giant told a Tennessee federal court.

  • August 05, 2024

    Pension Plan Testimony Barred In $2B Danish Tax Fraud Case

    U.S. pension plans have proposed irrelevant expert testimony in response to allegations of their participation in a $2.1 billion Danish tax fraud scheme, a New York federal judge ruled in excluding the testimony but leaving room to try again.

  • August 05, 2024

    Latest Draft Widens Scope Of UN Tax Convention

    Diplomats would gain flexibility on the scope, commitments and source material of a United Nations convention on international tax cooperation under a revised guidance for negotiators released ahead of a debate Monday as preliminary talks inch closer to finishing.

  • August 05, 2024

    Turkey Enacts Global Corporate Minimum Tax

    Turkey enacted the Organization for Economic Cooperation and Development's 15% corporate minimum tax on large multinational entities making more than €750 million ($821 million) annually.

  • August 05, 2024

    EU Court To Hear Czech Value-Added Tax Case

    The Court of Justice of the European Union will consider a case from the Czech Republic concerning whether the bloc's value-added tax system and proportionality principle precludes a Czech law regarding the transfers of VAT payment liabilities, the EU said Monday.

  • August 05, 2024

    Free Market Group Challenges EU Pillar 2 Directive In Court

    A free market trade group is taking aim in court at the European Union's implementation of the OECD's Pillar Two anti-tax base erosion and profit shifting measures, which it claims are unfairly impacting the U.S. and subverting Congress' right to tax U.S. companies.

  • August 05, 2024

    Peru To Subject Foreign Platforms To Sales Tax

    Foreign digital service providers doing business in Peru will be subject to the country's sales tax starting in October, in line with Organization for Economic Cooperation and Development standards, according to a legislative decree.

  • August 05, 2024

    Russia Increasing Corporate Tax Rates In 2025

    Corporations in Russia will be assessed a 25% income tax rate starting in 2025, an increase from the current 20%, the country's tax agency said Monday.

  • August 02, 2024

    Ex-Loeb Tax Atty Latest Addition To Kilpatrick's NY Team

    A former Loeb & Loeb LLP attorney is bringing his experience in U.S. federal tax matters and real estate transactions to Kilpatrick Townsend & Stockton LLP, the firm announced Thursday.

  • August 02, 2024

    Aussie Panel Opposes Aligning Public Tax Reporting With EU

    The benefits of Australia's public country-by-country reporting bill would diminish if it were limited to jurisdictions covered by the European Union's regime, as businesses have requested, the Australian Senate's economics committee reported Friday.

  • August 02, 2024

    PwC Australia Names Independent Governance Board Chair

    PwC Australia has chosen the first independent nonexecutive chair of its governance board, along with an independent nonexecutive board member, as it takes steps to rebound in the wake of its scandal involving the leak of government tax documents.

  • August 02, 2024

    Treasury Faces Complicated Path For Amount B Pricing Rules

    The U.S. Treasury Department signaled it is considering how to enact the OECD's routine pricing plan known as Amount B, but U.S. tax attorneys expect a complicated compliance exercise if rulemakers establish the new transfer pricing approach.

  • August 02, 2024

    Coca-Cola Poised To Appeal $2.7B Tax Bill With 11th Circ.

    The U.S. Tax Court signed off Friday on Coca-Cola's $2.7 billion tax bill, setting the stage for the beverage giant to appeal the liabilities and related rulings in its long-running dispute over the IRS' reallocation of the company's foreign income.

  • August 02, 2024

    IRS Tells Tax Court AbbVie's $1.6B Break Fee Is A Capital Loss

    The Internal Revenue Service correctly reclassified AbbVie's $1.6 billion break fee to an Irish biotechnology company as a capital loss, the agency told the U.S. Tax Court, arguing that the failed merger is tantamount to disposing of property.

  • August 02, 2024

    Taxation With Representation: Sullivan, Dechert, Kirkland

    In this week's Taxation With Representation, BNP Parabis SA acquires an investment management subsidiary for €5.1 billion, Cleveland accounting firm CBIZ merges with competitor Marcum for $2.3 billion, and Arcosa Inc. inks a deal with a family-owned construction materials business for $1.2 billion.

  • August 02, 2024

    Liberty Global's $110M Tax Refund Kosher, 10th Circ. Told

    The IRS is trying to block Liberty Global's bid for a $110 million tax refund by improperly using a legal doctrine requiring transactions to have economic substance, the telecommunications giant told the Tenth Circuit, arguing it was allowed to make tax-driven choices in the transactions at issue.

  • August 02, 2024

    Top UK Court To Hear HMRC Car Park Tax Dispute With NHS

    HM Revenue and Customs has been granted permission by Britain's highest court to challenge a ruling that a National Health Service trust qualified for value-added tax exemption for hospital car parking, a decision that could affect appeals brought by NHS entities.

  • August 01, 2024

    Divided Tax Court Says Treaty Bars Collections Hearing

    A divided U.S. Tax Court ruled Thursday that it lacked authority to review an Internal Revenue Service decision preventing a woman from challenging a federal tax lien the agency issued on behalf of the Canadian government to secure her tax debt to that country.

Expert Analysis

  • Prepare For Global Collaboration In Crypto Tax Enforcement

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    Recent Internal Revenue Service victories involving John Doe summonses served on cryptocurrency exchanges — and statements by the Joint Chiefs of Global Tax Enforcement about global collaboration in cryptocurrency-related tax investigations — should prompt assessment of prior virtual currency transactions and remediation before an enforcement agency shows up at the door, say attorneys at McDermott.

  • 10 Things to Know About US Competent Authority Assistance

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    Taxpayers should consider seeking U.S. competent authority assistance to help eliminate double taxation from a transfer pricing adjustment, especially now that the competent authorities are resolving cases virtually and more quickly, say attorneys at Thompson & Knight.

  • US Advance Pricing Agreements, Amid COVID And Before

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    Steptoe & Johnson's Matthew Frank, former director of the U.S. Advance Pricing Agreement Program, shares insights from an Internal Revenue Service report revealing an uptick in APA completions amid the pandemic, discusses trends over the program's 30-year history, and suggests ways taxpayers and the IRS could bolster program participation.

  • Choosing A Branch Or Subsidiary For Overseas Expansion

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    Samuel Pollack and Naoko Watanabe at Baker McKenzie examine the corporate and U.S. tax law considerations involved in deciding whether a branch or subsidiary is the most efficient way to expand operations overseas, now that recent Treasury regulations clarified the complicated international tax regime created by the Tax Cuts and Jobs Act.

  • Key Tax Concerns For Foreign Investors In US Private Equity

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    Paul D'Alessandro at Bilzin Sumberg examines important tax questions foreigners interested in U.S. private equity investments should ask in advance, including whether the investment will produce active or passive income, be subject to gains tax, and have U.S. estate tax consequences.

  • Surveying Global Tax Updates For Sovereign Wealth Investors

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    As the market transitions to a post-pandemic phase, sovereign wealth fund and other foreign institutional investors must evaluate how recent U.S., EU and U.K. tax changes may affect their private fund investments, say attorneys at Morgan Lewis.

  • Coke, 3M Tax Cases May Not Settle Blocked Income Debate

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    Even if the challenged U.S. Department of the Treasury regulation on blocked income is struck down by the U.S. Tax Court in the pending Coca-Cola and 3M cases, the obligations of a taxpayer that had, but failed to avail itself of, alternative means to secure payment will remain an open question, say Matthew Frank and Amanda Varma at Steptoe & Johnson.

  • IRS Should Level The Field For R&D Tax Credits

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    A recent increase in denials of research and development tax credits to small businesses in the architectural, engineering and construction community shows the Internal Revenue Service should issue new guidance to ensure a fair playing field and an opportunity to continue innovating in the U.S., says Julio Gonzalez at Engineered Tax Services.

  • Applying OECD Guidance On COVID-19 Transfer Pricing

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    In light of the recently released Organization for Economic Cooperation and Development's guidance on the transfer pricing implications of the pandemic, taxpayers should be prepared to explain and defend their transfer pricing decisions for fiscal year 2020 for contemporaneous documentation and in future tax audits, say Susan Fickling and TJ Michaelson at Duff & Phelps.

  • Mitigate Key FCPA Risks With Tailor-Made Compliance

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    Multinational companies should take a pragmatic approach to Foreign Corrupt Practices Act compliance by being aware of key risk areas — such as inappropriate gift-giving, liability for third-party actions, and countries with recurring corruption issues — and implementing custom-designed procedures that evolve with their operations, says Howard Weissman at Miller Canfield.

  • Tax Takeaways From India's Proposed Budget

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    Consultants at Deloitte discuss the tax implications of India's latest budget proposals, including the potential benefits for foreign portfolio investors and offshore funds migrating to India's new international financial services center, and the possible rise of M&A costs.

  • A Tough Road Ahead for Democrats' Ambitious Policy Agenda

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    While Democrats in Congress are well on their way to enacting an initial COVID-19 relief bill, they will face challenges when pivoting to President Joe Biden's Build Back Better goals for job creation and economic revitalization, say Russell Sullivan and Radha Mohan at Brownstein Hyatt.

  • Coca-Cola Tax Ruling Offers 5 Lessons For Multinationals

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    The U.S. Tax Court's decision that Coca-Cola owes more than $3.3 billion in taxes is instructive on important transfer pricing concepts, including those regarding intercompany agreements, the arm's-length standard and tax certainty, says ​​​​​​​Justin Radziewicz at Duff & Phelps.

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