International

  • May 07, 2024

    India High Court Says Biz's Tax Refunds Can't Be Held Back

    Indian tax authorities must refund value-added taxes of 225 million rupees ($2.7 million) to a business instead of withholding them to offset future tax liabilities, the country's top court ruled.

  • May 07, 2024

    Latin American, Caribbean 2022 Tax Revenue Up, OECD Says

    Tax revenue in Latin American and Caribbean countries rose in 2022, thanks in large part to gains in the gas and oil sector, but the average tax-to-gross domestic product ratio in the region still lags behind the OECD average, the organization said Tuesday.

  • May 07, 2024

    14 Arrested In €15M VAT Fraud Ring Tied To Lubricating Oil

    Authorities arrested 14 people as part of an investigation into a crime ring that evaded more than €15 million ($16.1 million) in value-added taxes and other levies tied to lubricating oil, the European Public Prosecutor's Office said Tuesday.

  • May 07, 2024

    EU Pauses Drive For Deal On Energy Tax

    The chair of European Union finance ministers gave up attempts to reach an agreement on a landmark energy taxation law because of sharply diverging views among EU countries, a source from Belgium's EU presidency confirmed Tuesday.

  • May 07, 2024

    Austrian Finance Chief Backs Tax Breaks For Full-Time Work

    Austria's finance minister said he backed proposals to use the tax system to encourage individuals to work full time, including freeing overtime work from taxation.

  • May 07, 2024

    Treasury Floats Foreign Trust Reporting Rules

    The U.S. Treasury Department proposed regulations Tuesday that provide guidance on the requirements for individuals to report their transactions with foreign trusts to the Internal Revenue Service, including the receipt of large gifts.

  • May 06, 2024

    10th Circ. Urged To Alter Substance Finding In Liberty Global

    To preserve the stability of federal tax law, the Tenth Circuit should reverse a lower court's finding that it needn't determine the economic substance doctrine is relevant before disallowing a transaction's tax benefits, the National Foreign Trade Council said Monday, supporting telecommunications firm Liberty Global.

  • May 06, 2024

    Man's FBAR Filing Makes Challenge Moot, 7th Circ. Says

    The Seventh Circuit upheld Monday the dismissal of a man's challenge to the constitutionality of filing reports of foreign accounts because after filing the suit, the man reported his bank account, making the case moot.

  • May 06, 2024

    Japan Floats Top Seat For Small Islands At UN Tax Convention

    The United Nations committee responsible for negotiating a framework convention on tax should have a co-chair for small island states in a subgroup that leads drafting of proposals, Japan's government said Monday.

  • May 06, 2024

    Marcum Expands Into Mich. By Adding Croskey Lanni

    Accounting and advisory firm Marcum LLP acquired Detroit-based Croskey Lanni PC, adding six partners and more than 50 associates, Marcum announced Monday.

  • May 06, 2024

    Austrian Tax Investigations Collected €49M In 2023

    Austrian tax investigators carried out 210 investigations in 2023, securing a total of €48.86 million ($52.6 million) in back taxes, with perpetrators possibly owing as much as €100 million in fines, the country's finance ministry said Monday.

  • May 06, 2024

    EU Court Asked To Rule On Italian Nix Of Biz Tax Deductions

    The European Union's highest court was asked to rule on Italy's policy denying Italian parent companies certain tax deductions of corporate taxes paid by their subsidiaries in other EU countries, a question arising from an Italian bank's court challenge, a document published Monday showed.

  • May 06, 2024

    Macron-Backed Group Backs G20 Wealth Tax In Election Pitch

    A group campaigning in the European Parliament elections that is backed by French President Emmanuel Macron supports a wealth tax in the world's largest economies, according to a campaign platform published Monday.

  • May 04, 2024

    IRS Seeks More Info On Purpose Test In Buyback Tax Regs

    The IRS is seeking more information on fine-tuning a test in proposed rules on the stock buyback tax meant to assess whether the principal purpose of a U.S. subsidiary's funding purchase of its foreign parent's stock is to avoid the tax, an agency attorney said Saturday.  

  • May 03, 2024

    US Resisting More Scoping On Amount B, Economist Says

    In negotiations over the streamlined transfer pricing approach for baseline marketing and distribution functions known as Amount B, the U.S. has resisted calls for additional scoping criteria that would exclude more companies from the safe harbor, a former U.S. Treasury economist said Friday.

  • May 03, 2024

    Foreign Trust Reporting Rules Coming Soon, IRS Official Says

    The Internal Revenue Service is about to issue proposed regulations that will provide guidance on the reporting obligations for individuals who have transactions with foreign trusts, an agency official said Friday.

  • May 03, 2024

    HMRC Director Rejoins KPMG To Boost Tax Dispute Offering

    A former deputy director at HM Revenue & Customs has returned to KPMG as director of KPMG Law's tax disputes teams, the firm has announced.

  • May 03, 2024

    Africa Seeks Early UN Reform On Transfer Pricing, Exchanges

    Legally binding protocols that reform transfer pricing and exchange of information to the benefit of all countries where multinational corporations operate should be developed simultaneously with the U.N. framework convention on global tax, the U.N.'s African bloc, India and others said Friday.

  • May 03, 2024

    Estonia Implements 2 EU Tax Laws After Delays

    Estonia officially enacted two European Union-wide tax measures that it was late putting into national law, both relating to the OECD's standards for global minimum taxation of large companies.

  • May 03, 2024

    Aussie Treasury Seeks Input On Powers After PwC Scandal

    With investigations into PwC Australia's leak of classified tax plan documents ongoing, the Australian government is asking the public whether it thinks its regulatory powers over tax and accounting firms are sufficient, its Treasury announced Friday.

  • May 03, 2024

    New Fiscal Rules Force EU Countries To Limit Deficits

    New European Union fiscal rules that recently kicked in will force EU countries to restrict public budget deficits by better balancing tax revenues with government spending, the European Commission said Thursday.

  • May 03, 2024

    US Trade Position Seen Contradicting Stance In Pillar 1 Talks

    The U.S. trade representative's withdrawal of support for digital trade proposals has caused tax policy observers to worry that the U.S. position on trade is undermining that of U.S. Treasury Department officials negotiating a taxing rights overhaul at the OECD known as Pillar One.

  • May 03, 2024

    Finland's Stance On Swiss Treaty Recalls Ended Portugal Deal

    Finland's plan to renegotiate its tax treaty with Switzerland in response to concerns about pension tax avoidance has some observers worried that the country will cancel that accord as it did a treaty with Portugal in recent years.

  • May 03, 2024

    Taxation With Representation: Skadden, Wachtell, Davis Polk

    In this week's Taxation With Representation, L'Occitane International said its executive director and chair is leading an offer to buy the company's shares he doesn't already own, UMB Financial agreed to purchase Heartland Financial USA, Medline said it agreed to acquire Ecolab's global surgical solutions business and The Mosaic Co. said it agreed to sell its stake in a phosphate production joint venture.

  • May 03, 2024

    IRS Can Assess Foreign Info Disclosure Penalty, DC Circ. Says

    The D.C. Circuit on Friday overturned a major U.S. Tax Court ruling that had struck down the Internal Revenue Service's authority to assess and administratively collect penalties from taxpayers for failing to file an information return on their interests in a foreign corporation.

Expert Analysis

  • The Highs And Lows Of Tax Controversy In 2021

    Author Photo

    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

    Author Photo

    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

    Author Photo

    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

    Author Photo

    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

    Author Photo

    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

    Author Photo

    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

    Author Photo

    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

    Author Photo

    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

    Author Photo

    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

    Author Photo

    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
    Author Photo

    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
    Author Photo

    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

    Author Photo

    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.

Can't find the article you're looking for? Click here to search the Tax Authority International archive.