International

  • 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.

  • October 11, 2024

    Taxation With Representation: Davis Polk, Latham, Kirkland

    In this week's Taxation With Representation, Rio Tinto agrees to acquire Arcadium Lithium for roughly $6.7 billion, Ares Management Corp. and GCP International reach a $3.7 billion deal, and Butterfly Equity announces plans to buy The Duckhorn Portfolio for $2 billion.

  • October 10, 2024

    Ukraine's Parliament Hikes Taxes To Fund War With Russia

    Ukraine's Parliament announced that it approved several amendments to the country's tax code Thursday that will raise revenues for its war with Russia.

  • October 10, 2024

    Pillar 2 Carveout Should Cover Some Mobile Items, NFTC Says

    The exemption for tangible investments from the global minimum tax known as Pillar Two should include certain mobile assets, such as ships and aircraft, the National Foreign Trade Council recommended.

  • October 10, 2024

    Ryanair To Scale Back German Flights After Tax Hike

    Irish discount airline Ryanair announced plans Thursday to follow through on its threat to cut back service to Germany next summer over tax issues, saying it will cut 12% of its total capacity in the country — equal to 1.8 million seats — and close three bases of operation.

  • October 10, 2024

    Pfizer Lone Holdout In Senate Pharma Tax Probe, Wyden Says

    Pfizer Inc. is the only company to withhold a country-by-country breakdown of its tax planning in the Senate Finance Committee's probe into how Republicans' 2017 tax package reduced the pharmaceutical industry's U.S. liabilities, according to a letter Chairman Ron Wyden released Thursday.

  • October 10, 2024

    UK Exit Taxes OK When Paid Over Time, Upper Tribunal Says

    An exit tax on U.K. trusts leaving the country pre-Brexit interfered with their European Union right to free movement of capital, but is brought into compliance if trusts can pay the tax over at least a five-year period, the Upper Tribunal ruled.

  • October 10, 2024

    Switzerland Reports Info Exchanges With 108 Jurisdictions

    Switzerland's Federal Tax Administration has exchanged information on roughly 3.7 million financial accounts with 108 jurisdictions so far in 2024, the government said Thursday.

  • October 10, 2024

    Ireland's Finance Bill Sets Out Foreign Dividend Exemption

    The Irish government set out its plans for a new participation tax exemption for foreign dividends as part of a finance bill published Thursday.

  • October 10, 2024

    Algeria Joins OECD Tax Transparency Treaty

    Algeria formally joined the Organization for Economic Cooperation and Development's global tax transparency agreement on combating tax avoidance and evasion by multinational corporations, the OECD announced Thursday.

  • October 09, 2024

    Australia Floats Debt Reduction Creation Rules Guidance

    The Australian Taxation Office published draft guidance Wednesday for the country's new debt deduction creation rules, including the planned compliance approach and a framework for risk assessment.

  • October 09, 2024

    European Parliament Backs Brazil's G20 Wealth Tax Plan

    A majority of the European Parliament supports a 2% minimum tax on billionaires presented by Brazil at the Group of 20 nations meeting, asking the European Union to pursue the topic at the group's November summit, according to joint statements by members of Parliament on Wednesday.

  • October 09, 2024

    Swiss Council Rejects Funding Pensions With Transaction Tax

    Switzerland should not use the revenue generated by its two taxes on financial market transactions to fund the country's pension fund, nor should it create new ones for that purpose, the Swiss Federal Council said Wednesday.

  • October 09, 2024

    OECD Should Clarify Pillar 2 Safe Harbor Timing, CPAs Say

    The OECD should clarify when exactly multinational corporations need to determine whether they qualify for a transitional safe harbor under an international minimum tax agreement, the American Institute of Certified Public Accountants recommended in a letter.

  • October 09, 2024

    UK Gov't Greenlights Film Industry Tax Credit

    U.K. film companies will be able to gain over 50% tax relief for their films' costs from a tax credit approved Wednesday by the Labour government.

  • October 09, 2024

    3M Tax Ruling Must Fall Post-Chevron, Chamber Tells 8th Circ.

    The U.S. Supreme Court's ending of the Chevron doctrine calls for overturning a U.S. Tax Court ruling that let the IRS allocate $24 million of income to multinational conglomerate 3M from a Brazilian affiliate, the U.S. Chamber of Commerce told the Eighth Circuit on Wednesday.

  • October 09, 2024

    Starmer Refuses To Rule Out Payroll Tax Hike

    Prime Minister Keir Starmer didn't rule out raising employers' National Insurance contributions, a payroll tax used to fund healthcare and state pensions, during Wednesday's question time.

  • October 09, 2024

    Election Uncertainty Hampers Companies' Tax Planning

    With the November election approaching, businesses are bracing for the potential impact of two very different sets of tax policies, with the resulting uncertainty making long-term tax planning increasingly difficult.

  • October 09, 2024

    Australia Seeking Large Cos.'s Tax Execs For Advisory Board

    The Australian Taxation Office is looking for executives in charge of taxes for the country's largest businesses to join an advisory group focused on improving the Australian taxation systems, the ATO said Wednesday.

  • October 09, 2024

    Final Treasury Rules Shut Off Inclusion For Repatriated IP

    The U.S. Treasury Department adopted final rules Wednesday that shut off an annual income inclusion associated with intangibles for companies in certain situations that have transferred intellectual property back to the U.S. from overseas.

  • October 09, 2024

    Gov't Warned Over National Insurance Levy On Pensions

    About half of U.K. employers would scale back the amount they pay into staff pensions to regulatory minimums if a new tax was applied to contributions, according to a survey by a trade group published Wednesday.

  • October 08, 2024

    Germany May Offer Tax Break For 'E-Fuel' Cars, Ministry Says

    The German government will consider a motor vehicle tax exemption for cars running only on fuels manufactured with renewable energy, known as e-fuels-only vehicles, the German Ministry of Finance announced Tuesday.

  • October 08, 2024

    China Pushes Back On Turkish EV Tariffs, Targets EU Brandy

    China said Tuesday that it is appealing to the World Trade Organization to halt Turkish tariffs on electric and hybrid vehicles made in the country, and it announced a temporary anti-dumping measure on European Union brandy that follows the bloc's own EV tariffs.

Expert Analysis

  • 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.

  • EU Climate Plan Should Involve Taxing Pollution, Not Borders

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    In order to crack down on greenhouse gas emissions, the European Union proposes to levy carbon emissions at its borders and to overhaul its long-standing energy tax framework, but the latter would hold polluters directly accountable, giving it the better chance for success, says Rebecca Christie at Bruegel.

  • Prepare For Global Tax Regime's New Biz Dispute Risks

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    Companies should take steps to mitigate the business dispute risks of the new international tax framework, which over a hundred countries agreed to in July, as implementing the new regime will be expensive and require substantial organizational restructuring efforts, says Tim McCarthy at Dykema.

  • Prepare For More Audits Of Tax Info And Withholding Filings

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    Financial institutions and other corporate taxpayers should focus compliance efforts on tax information reporting and withholding, given recent indications from the Biden administration that the IRS will increase enforcement, and the administration's need to fund its infrastructure plan and other costly initiatives, say attorneys at Mayer Brown.

  • Anti-Boycott Compliance Still Key In UAE Business Dealings

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    Notwithstanding recent amendments to U.S. anti-boycott laws that reflect the United Arab Emirates' withdrawal from the Arab boycott of Israel, companies doing business in the UAE and elsewhere still need to maintain effective anti-boycott compliance programs to avoid reporting violations or penalties, says Howard Weissman at Miller Canfield.

  • 9th Circ. Adds Pressure To Reject Substance Over Form

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    The Ninth Circuit’s recent decision rejecting taxes on a family's Roth IRA payments that were made through a foreign sales corporation represents a refreshing trend among federal appeals courts to reject substance-over-form principles and instead look to congressional intent, say Lawrence Hill and Caitlin Tharp at Steptoe & Johnson.

  • Will The OECD Plan Fix International Taxation?

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    Lilian Faulhaber at Georgetown Law breaks down the Organization for Economic Cooperation and Development’s plan for international tax reform, recently joined by 130 countries, and whether it will solve the problems it was designed to address, including the need for multinational companies to pay their fair share of taxes in the digitized world economy.

  • What Biden's Tax Proposals May Mean For Int'l Private Clients

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    Jennifer Wioncek and Paul D’Alessandro at Bilzin Sumberg discuss the U.S. Department of the Treasury's recently released explanation of the Biden administration's tax proposals and how the changes would affect income and wealth transfer planning for international private clients.

  • What Crypto Holders Can Learn From Early-2000s Tax Scandal

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    The Internal Revenue Service’s recent push to gather information about cryptocurrency accounts is similar to its Swiss bank account investigations of the early 2000s, which should prompt taxpayers to consider voluntarily disclosing transactions before they are individually targeted for enforcement, say Timothy Wagner and Thomas Barnard at Baker Donelson.

  • International Tax Reform's Implications For Transfer Pricing

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    As the Organization for Economic Cooperation and Development overhauls the global tax rules on base erosion and profit shifting, and the Biden administration rolls out new U.S. tax proposals, multinational enterprises need to prepare for the effects of these tax changes on their transfer pricing structures, say Mandy Li and Shuang Feng at MGO.

  • Justices' Preemptive Tax Challenge Ruling Shows Divisions

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    The U.S. Supreme Court's recent decision in CIC Services v. Internal Revenue Service reveals divisions among the justices about when potentially burdensome tax regulations can be challenged, making the holding less clear and less valuable, say George Isaacson and David Swetnam-Burland at Brann & Isaacson.

  • Takeaways From 2 New FBAR Rulings

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    In light of two recent California federal court decisions, capping penalties for nonwillful violations of foreign bank account reporting but broadening the willfulness standard, U.S. taxpayers must be vigilant about understanding their reporting obligations, and prepare for the Internal Revenue Service to target willful conduct, which yields much higher penalties, say Friedemann Thomma and Marianna Felshtiner at Venable.

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