International

  • 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.

  • April 26, 2024

    Ireland Received Nearly €24B In Corp. Taxes In 2023

    Corporations paid Ireland €23.8 billion ($25.5 billion) in taxes in 2023, a 5.3% increase over 2022, making corporate tax receipts the second-largest tax revenue generator in the country, according to the Irish revenue department.

  • April 26, 2024

    PwC Australia Appoints 6 Partners To Guide Scandal Rebound

    PwC Australia announced that it has elected six partners to its governance board as the firm continues to attempt to rebound in the wake of its scandal involving the leak of Australian government documents.

  • April 26, 2024

    HMRC Says Tax Digitalization Plan Will Generate £6.4B

    HM Revenue & Customs said its program to modernize U.K. tax filing is expected to generate £6.38 billion ($7.97 billion) in additional revenue through 2034 after projections last year put it at £3.9 billion.

  • April 26, 2024

    Poland Seeks Input On Bill To Enact Minimum Tax

    Poland, one of a handful of European Union countries that have delayed implementing the Organization for Economic Cooperation and Development's Pillar Two global minimum tax plan, introduced a proposal for public comment that would enact the regime.

  • April 26, 2024

    Abbott Labs' $417M IRS Bill Isn't Wrong, Tax Court Told

    The Internal Revenue Service denied allegations by Abbott Laboratories that it incorrectly increased the global healthcare giant's income, resulting in a $417 million tax bill, in answering Abbott's lawsuit filed with the U.S. Tax Court.

  • April 26, 2024

    Top EU Judge Sees Lower Court Becoming Like Tax Court

    The lower court of the European Union, the General Court, will over time become a venue that specializes in some tax matters after a reform is put into place, the EU's top judge has said.

  • April 26, 2024

    HSBC Beats Investors' £1.3B Disney Film Scheme Fraud Case

    HSBC fended off on Friday a £1.3 billion ($1.6 billion) fraud claim brought by hundreds of investors who alleged the bank misled them into financing a Disney movie tax relief scheme it developed which turned out to be worthless.

  • April 25, 2024

    Romanian Sanctions On Fuel Violate EU Law, Court Says

    A Romanian law imposing sanctions of €77,000 ($83,000) — 21 times the usual rate of taxation — on fuel placed back into storage is so extreme it violates European Union law, the EU's top court said Thursday.

  • April 25, 2024

    Dutch Tax Authority Aiming To Beef Up Data Security

    The Netherlands' tax authority is introducing more data protection measures based on suggestions from a KPMG report commissioned after signs of possible security threats within the tax administration, it said Thursday.

  • April 25, 2024

    Workers' Effective Tax Rates In OECD Countries Rise Again

    The effective tax rates on labor income in the majority of Organization for Economic Cooperation and Development member countries rose for the second year in a row in 2023, thanks in part to continued inflation, the OECD said Thursday.

  • April 25, 2024

    OECD Says Latvia Must Shift Tax Burden, Limit Fuel Subsidies

    Latvia needs to shift its tax burden off labor and onto other forms of income such as property, and to eliminate harmful subsidies and tax practices around fossil fuels, the Organization for Economic Cooperation and Development said Thursday.

  • April 25, 2024

    OECD Consolidates Past Pillar 2 Guidance Into Single Doc

    The Organization for Economic Cooperation and Development published administrative guidance Thursday that consolidates past publications on the interpretation and application of the international minimum tax agreement known as Pillar Two, which countries began implementing this year.

  • April 25, 2024

    EU Parliament Gives Final Approval To AML Package

    The European Parliament has given the final go-ahead to a package of laws to fight money laundering and terrorist financing, creating a single rule book and establishing a dedicated agency for the bloc.

Expert Analysis

  • 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.

  • Review Of Repatriation Tax Sets Justices On Slippery Slope

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    The U.S. Supreme Court’s recent decision to review the constitutionality of the repatriation tax in Moore v. U.S. has implications for many tax rules involving unrealized amounts and could leave the court on the brink of invalidating large swaths of the Internal Revenue Code, say attorneys at Eversheds Sutherland.

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