International

  • May 01, 2024

    No Relief For Fla. Adviser Convicted In $80M Trading Scam

    The Eleventh Circuit on Wednesday affirmed the conviction of a Florida investment adviser who bilked more than $80 million from the hundreds of people he persuaded to invest in a fraudulent company, after concluding he was not in custody when he made statements to the police.

  • May 01, 2024

    Middle East, North African Gov'ts Back UN For Corp. Tax Talks

    Governments should make a high-level commitment to address corporate tax reform within the United Nations' framework convention on international tax cooperation, an intergovernmental group of Middle Eastern and North African countries said Wednesday.

  • May 01, 2024

    Think Tank Says 'Distortive' DSTs Not The Right Way Forward

    As jurisdictions around the world continue to struggle with how to adequately tax the increasingly digital economy, they should look to expand their consumption taxes, not enact digital services taxes, the Tax Foundation said.

  • May 01, 2024

    Liberty Global Defends $109M Tax Refund Bid In 10th Circ.

    Telecommunications giant Liberty Global urged the Tenth Circuit to revive the company's $109 million tax refund bid, arguing a lower court rejected the claim by wrongly disregarding intercompany transactions that are permitted under legislation involving the repatriation of foreign profits.

  • May 01, 2024

    UN Must Improve Corp. Tax Rules, Platforms, Some Gov'ts Say

    Governments must commit to improving existing corporate tax rules and platforms created at the OECD within the terms of reference for a United Nations framework convention on global tax cooperation, two tax officials who participated in drafting those rules said Wednesday.

  • May 01, 2024

    HMRC Simplifies Late Filing Penalties For Digital Filers

    U.K. taxpayers voluntarily filing their personal income tax returns using a program intended to modernize the country's tax system will receive more leniency and access to a simpler penalty structure in cases of late filing, HM Revenue & Customs said.

  • May 01, 2024

    Hong Kong Proposes Amended Automatic Info Exchange List

    Hong Kong is considering adjusting the list of countries it automatically exchanges financial information with by subtracting nine jurisdictions and adding 11, which the country's tax authority said is in line with recommendations from the Organization for Economic Cooperation and Development.

  • May 01, 2024

    Swiss Sends Amendment To Serbian Tax Treaty To Parliament

    Switzerland's executive body, the Federal Council, sent to the country's parliament Wednesday an amendment for the country's double-taxation treaty with Serbia that would bring it in line with the OECD's base erosion and profit shifting standards, the council said.

  • April 30, 2024

    India, Belgium, Others Support UN Taking On Wealth Taxation

    Governments should make a high-level commitment to reach agreement on the taxation of wealthy individuals within the United Nations framework convention on international tax cooperation, representatives of India, Belgium, Austria, Nigeria and Kenya said Tuesday.

  • April 30, 2024

    Yellen Says US Pushing To Protect R&D Credit Under Pillar 2

    U.S. Treasury Department negotiators are continuing to advocate for more favorable treatment of the country's research and development tax credit under the Pillar Two global minimum tax rules, Treasury Secretary Janet Yellen told the House Ways and Means Committee on Tuesday.

  • April 30, 2024

    German Banker Gets 3 Years For €93M Cum-Ex Tax Evasion

    A German court on Tuesday sentenced a former bank board member to three years and two months in prison for his part in a €93.4 million ($100 million) so-called cum-ex dividend tax fraud.

  • April 30, 2024

    HMRC Proposes Special Economic Zone Tax Relief Extensions

    HM Revenue & Customs proposed Tuesday to extend the time to claim tax relief measures available in special economic zones in the U.K. to 2031 in England and to 2034 in other parts of the country.

  • April 30, 2024

    The Tax Angle: TCJA Teams, Dear Colleague Letters

    From a look at House GOP efforts to prepare for next year's expiration of their 2017 tax overhaul to ongoing attempts by lawmakers to draw attention and support for their own tax legislation, here's a peek into a reporter's notebook on a few of the week's developing tax stories.

  • April 30, 2024

    Global Climate Tax Could Fund Disaster Aid, Report Says

    If OECD countries adopted a tax on the extraction of fossil fuels proposed by over 100 climate organizations, $900 billion could be generated cumulatively by 2030, a majority of which would be earmarked for those hit by climate disasters, some of those groups reported.

  • April 30, 2024

    EU Tax System Needs To Aid Climate Policy, Accountants Say

    European Union lawmakers should design a tax system in their next five-year legislative term that supports the green transition and long-term employment, a European lobby for accountants said in a document posted Tuesday.

  • April 29, 2024

    Court Can Make Widow Pull $2.5M From Swiss Bank, US Says

    A Colorado federal court can force a widow to send $2.5 million from a Swiss bank to the U.S. to repay her late husband's penalties and interest for failing to report his foreign accounts, the U.S. told the court.

  • April 29, 2024

    OECD Nations Steer UN Tax Talks Toward Decision-Making

    The terms of reference for a United Nations global tax convention should guide the decision-making of a committee that will negotiate substantive provisions later even though some governments prefer to defer debate on the decision-making procedures to the General Assembly, several OECD government representatives said Monday.

  • April 29, 2024

    Canada Opens Second R&D Tax Credit Consultation

    With an additional CA$600 million ($439 million) earmarked for its scientific research and experimental development tax incentive program, Canada is looking for more specific feedback on expanding and otherwise adjusting the regime.

  • April 29, 2024

    Poland Pushes Back Mandatory E-Filing After Finding Flaws

    Polish businesses with sales totaling more than 200 million zloty ($50 million) won't have to use the country's electronic invoice system until 2025, with the full rollout delayed until 2026, due to multiple problems uncovered in the system, the country's tax authority said.

  • April 29, 2024

    OECD-UN Initiative Lands Developing Countries $2.3B In Tax

    A joint initiative between the Organization for Economic Cooperation and Development and the United Nations to help developing countries boost tax revenues said Monday that it has generated $2.3 billion in additional revenues and $6.05 billion in additional tax assessments since its 2015 formation.

  • April 29, 2024

    Ex-Man City Player Benjamin Mendy Pays £710K Tax Debt

    Former Manchester City footballer Benjamin Mendy avoided bankruptcy on Monday after paying a £710,000 ($892,000) tax bill minutes before a court hearing to determine whether an order should be made.

  • April 29, 2024

    US Expatriations Plummet In 1st Quarter, IRS Says

    The number of people who expatriated from the U.S. fell nearly 70% during the first quarter of 2024 compared with the previous quarter, the Internal Revenue Service said in a notice published Monday.

  • April 29, 2024

    EU Official Wants Progress On New Revenue Streams

    The budget commissioner of the European Union said Monday that the bloc must make progress toward agreeing on new revenue streams that would give it more diversified sources of income.

  • April 26, 2024

    4 Goals For Gov'ts To Pursue In The UN Tax Convention

    The United Nations' framework convention on international tax cooperation should resolve digital taxation, incorporate tax transparency conventions, seek consensus on tax allocation issues but adopt best practices by simple majority, and help fund development goals, officials and experts told Law360 as governments began negotiations Friday.

  • April 26, 2024

    FedEx Calls Gov't Arguments On Tax Credits Contradictory

    The federal government advanced contradictory arguments in FedEx's $84.6 million foreign tax credits dispute with the Internal Revenue Service, the package delivery giant said in a filing in Tennessee federal court.

Expert Analysis

  • IRS Notice Clarifies R&E Amortization, But Questions Remain

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    The IRS and Treasury Department’s recent notice clarifying the treatment of specified research and experimental expenditures under Section 174 provides taxpayers and practitioners with substantive guidance, but it misses the mark in delineating which expenditures are amortizable, say attorneys at Eversheds Sutherland.

  • Preparing Your Legal Department For Pillar 2 Compliance

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    Multinational entities should familiarize themselves with Pillar Two of the Organization for Economic Cooperation and Development’s BEPs 2.0 project and prepare their internal legal tracking systems for related reporting requirements that may go into effect as early as January, says Daniel Robyn at Ernst & Young.

  • What Large Language Models Mean For Document Review

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    Courts often subject parties using technology assisted review to greater scrutiny than parties conducting linear, manual document review, so parties using large language models for document review should expect even more attention, along with a corresponding need for quality control and validation, say attorneys at Sidley.

  • Participating In Living History Makes Me A Better Lawyer

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    My role as a baron in a living history group, and my work as volunteer corporate counsel for a book series fan association, has provided me several opportunities to practice in unexpected areas of law — opening doors to experiences that have nurtured invaluable personal and professional skills, says Matthew Parker at the Nebraska Department of Health and Human Services.

  • Private Equity Owners Can Remedy Law Firms' Agency Issues

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    Nonlawyer, private-equity ownership of law firms can benefit shareholders and others vulnerable to governance issues such as disparate interests, and can in turn help resolve agency problems, says Michael Di Gennaro at The Law Practice Exchange.

  • How Taxpayers Can Prep As Justices Weigh Repatriation Tax

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    The U.S. Supreme Court might strike down the 2017 federal tax overhaul's corporate repatriation tax in Moore v. U.S., so taxpayers should file protective tax refund claims before the case is decided and repatriate previously taxed earnings that could become entangled in dubious potential Section 965 refunds, say Jenny Austin and Gary Wilcox at Mayer Brown.

  • OFAC Designation Prosecutions Are Constitutionally Suspect

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    Criminal prosecutions based on the Office of Foreign Assets Control’s sanctions-related listing decisions — made with nearly unfettered discretion through an opaque process — present several constitutional issues, so it is imperative that courts recognize additional rights of review, say Solomon Shinerock and Annika Conrad at Lewis Baach.

  • How The OECD Global Tax Proposal Could Affect M&A

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    Following agreement on the Organization for Economic Cooperation and Development’s Pillar Two proposal to introduce a global minimum tax, domestic implementation is expected to have a significant impact on international M&A transactions, with financial modeling, deal structuring, risk allocation and joint venture arrangements likely to be affected, say lawyers at Freshfields.

  • UK Shares-Tax Proposals Offer Long-Awaited Modernization

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    The U.K. government's recent consultation on the introduction of a new tax on transactions in securities raises detailed legal and practical issues, but the prospect of a single digital stamp tax offering both streamlined legislation and administration will be welcomed, say Zoë Arnautov and Mark Sheiham at Simmons & Simmons.

  • IRS Foreign Tax Credit Pause Is Welcome Course Correction

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    A recent IRS notice temporarily suspending application of 2022 foreign tax credit regulations provides wanted relief for the many U.S. multinational companies and other taxpayers that otherwise face the risk of significant double taxation in their international operations, say attorneys at Mayer Brown.

  • IRS Criminal Probe Spells Uncertainty For Malta Pension Plans

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    The IRS’ recent scrutiny of Malta pension plan arrangements — and its unusual issuance of criminal administrative summonses — confirms that it views many of these plans as illegal tax evasion schemes, and the road ahead will not be smooth and steady for anyone involved, say attorneys at Kostelanetz.

  • IRS Announcement Will Aid Cos. In Buyback Tax Planning

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    Recent IRS transitional guidance regarding current requirements for reporting and payment of the stock repurchase excise tax will help corporate taxpayers make decisions about records retention and establishing reserves for future tax payments, say Xenia Garofalo and Kyle Colonna at Eversheds Sutherland.

  • Flawed Analysis Supports Common Law Tax Deficiency Ruling

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    The Colorado federal district court’s recent decision in Liberty Global, holding that the U.S. Department of Justice may assert a common law tax claim without the notice of tax deficiency required by the Internal Revenue Code, relies on a contorted reading of the statute and irrelevant case law, say Loren Opper and Christie Galinski at Miller Canfield.

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