International

  • February 20, 2024

    HMRC's Civil Tax Avoidance Case Investigations Fall By Half

    HM Revenue & Customs investigated nearly half as many potential civil tax avoidance cases in the 2022-23 tax year as it did in 2018-19, including an even bigger drop in cases opened by its team investigating offshore, corporate and wealthy taxpayers, two local news agencies said.

  • February 20, 2024

    Czech Republic Launching R&D Credit Certainty Pilot Program

    The Czech Republic is launching a pilot collaboration between its finance administration and science agencies in hopes of making the value of research and development credits available to Czech companies more predictable, a pair of government bodies said Tuesday.

  • February 20, 2024

    Swiss Seen Turning To Credits, Subsidies As Pillar 2 Begins

    Switzerland is expected to turn to the use of subsidies and tax credits to try to keep business in the country as its ability to compete on tax rates is curtailed by the introduction of the global minimum tax.

  • February 19, 2024

    Barrister Disbarred For Pocketing £149K In VAT Payments

    A barrister was ordered to be disbarred on Monday after he admitted to receiving value-added tax on his professional fees despite not being registered for it, with a tribunal saying he acted dishonestly and that his behavior amounted to "serious misconduct."

  • February 19, 2024

    OECD Presents Simplified Amount B Transfer Pricing Rules

    The international negotiating body working on fundamental changes to corporate tax law presented a new approach to simplifying the application of transfer pricing rules on Monday, the Organization of Economic Cooperation and Development said.

  • February 16, 2024

    Manufacturers Back 3M In 8th Circ. Transfer Pricing Case

    The National Association of Manufacturers joined the chorus of business groups supporting 3M, asking the Eighth Circuit to throw out transfer pricing regulations that allow the Internal Revenue Service to reallocate income to U.S. group members even when foreign laws prohibit outbound payments.

  • February 16, 2024

    Medtronic Urges 8th Circ. To Undo Transfer Pricing Ruling

    Medical device company Medtronic asked the Eighth Circuit on Friday to overturn a decision rejecting its pricing method for licensing intellectual property to its Puerto Rican affiliate, saying in the long-running case that Medtronic hadn't used the intercompany arrangement to underreport its income.

  • February 16, 2024

    4 Arrested In Suspected €10M Italian VAT Fraud Scheme

    Italian authorities arrested four people as part of an investigation into what the European Public Prosecutor's Office said Friday was a €10 million ($10.7 million) value-added tax fraud scheme involving the sale of tires.

  • February 16, 2024

    Taxation With Representation: Paul Weiss, Kirkland

    In this week's Taxation With Representation, Diamondback buys Endeavor, KKR & Co. acquires a stake in Cotiviti, and Gilead Sciences Inc. purchases CymaBay Therapeutics Inc.

  • February 16, 2024

    New EU VAT Rules' Impact Will Be Seen In 2025, Official Says

    The impact of the European Union's new reporting obligations for payment processors that handle online cross-border transactions will become clearer starting next year, an EU official said Friday.

  • February 16, 2024

    Singapore Reaffirms Plan To Carry Out Minimum Tax Next Year

    Singapore remains on track to implement the Organization for Economic Cooperation and Development's corporate global minimum tax standards starting next year, the country's finance minister said Friday.

  • February 16, 2024

    Irish Parliament Panel Objects To EU's BEFIT Proposal

    A committee of Ireland's Parliament objected to a new draft framework for corporate taxation in the European Union, saying it oversteps the legal boundaries of EU legislation and undercuts the ability of individual countries to engage in tax competition. 

  • February 15, 2024

    Chamber, Others Back 3M In Transfer Pricing Appeal

    The Eighth Circuit should set aside transfer pricing regulations from the U.S. Treasury Department that reallocated $23 million of income from 3M's Brazilian affiliate to the parent company, three trade associations told the court in amicus briefs.

  • February 15, 2024

    Fla. Couple Get 57 Mos. For Evading $42M In Plywood Duties

    A Florida couple were sentenced to nearly five years in prison each after confessing to disguising the Chinese origin of millions of dollars' worth of plywood imports to avoid paying $42 million in import tariffs.

  • February 15, 2024

    HMRC Seeks Input On Tax Administration Capabilities

    HM Revenue & Customs is asking for feedback on its tax administration capabilities, particularly its inquiry and assessment powers, penalties and safeguards, it said Thursday.

  • February 15, 2024

    Mexico Granting Tax Credits For Hydrocarbon Activities

    Mexico has created what it calls a stimulus package for businesses conducting hydrocarbon exploration and extraction, granting tax credits for certain costs incurred over four months stretching back to 2023, according to a presidential decree.

  • February 15, 2024

    CPAs Call For Limiting Currency Recomputation Rules

    The IRS should exclude smaller taxpayers from requirements in proposed regulations for companies to recompute foreign currency gains or losses and income or losses into their parent entities' currencies annually, the American Institute of Certified Public Accountants said in a letter.

  • February 15, 2024

    EU Must Be Ready To Loosen Fiscal Policy, Gentiloni Says

    European Union countries should be ready to loosen their fiscal policy to stimulate the economy if growth slows further and inflation keeps falling, Paolo Gentiloni, the EU's tax commissioner, said Thursday.

  • February 15, 2024

    City Lobby Calls For Tax Cuts, Investment Reform In Budget

    The U.K. government should cut taxes on banking, make it easier for firms to list as public companies and create a new investment office to boost competitiveness, according to a leading financial lobby.

  • February 14, 2024

    Biden's OECD Pick Vows To Warren He'll Avoid Crypto Policy

    A former New York congressman who's been nominated to serve as the U.S. ambassador to a global economic development body has said he'll forgo working on crypto-oriented policy if he's confirmed to the job after Sen. Elizabeth Warren, D.-Mass, expressed concern over his work with cryptocurrency exchange Coinbase.

  • February 14, 2024

    Gov't Atty Says IRS Has Authority For Failure-To-File Penalty

    Internal Revenue Code Section 6021(a) gives the IRS broad authority to assess penalties for failing to file a form mandated by Section 6038(b) on which a company reports its foreign corporations, even though that authority isn't spelled out, a government attorney told the D.C. Circuit on Wednesday.

  • February 14, 2024

    OECD Chief Claims No Knowledge Of Aussie PwC Breaches

    The OECD's top official had no knowledge of PwC Australia's breaches of confidentiality when he took equity in its former CEO's consulting firm that he relinquished when the existence of the equity became public knowledge, his spokesperson told Law360.

  • February 14, 2024

    Jury Wipes Away Texaco Heiress' $21M FBAR Penalties

    A Florida federal jury found Wednesday that the U.S. government hadn't proved a Texaco heiress willfully failed to report foreign bank account information on time, eliminating the almost $21 million in penalties assessed against her estate, according to a court filing.

  • February 14, 2024

    Tech Group Backs 3M In 8th Circ. Transfer Pricing Appeal

    A tax group representing multinational tech companies urged the Eighth Circuit to overturn a U.S. Tax Court ruling that found 3M Co. owed taxes stemming from an additional $23 million in income reallocated from its Brazilian affiliate, saying the decision wrongly upheld transfer pricing regulations that were improperly enacted.

  • February 14, 2024

    UK Top Court Rejects Jersey Co.'s £15M VAT Case

    A company based on the island of Jersey had no grounds to seek £15 million ($18.8 million) in damages from HM Treasury after the U.K. ended a value-added tax relief arrangement in what the company said was a violation of EU law, the U.K.'s Supreme Court ruled Wednesday.

Featured Stories

  • Swiss Seen Turning To Credits, Subsidies As Pillar 2 Begins

    Todd Buell

    Switzerland is expected to turn to the use of subsidies and tax credits to try to keep business in the country as its ability to compete on tax rates is curtailed by the introduction of the global minimum tax.

  • Lawmakers Brace For Lobbying Blitz On Expiring Tax Breaks

    Stephen K. Cooper

    Some lawmakers foresee an increase in lobbying activity this year as Congress considers renewing parts of the GOP's 2017 tax law that are approaching expiration, while efforts to address the influence of dark money in politics remain on hold.

  • IRS Memo Highlights Tensions In Arm's-Length Loan Pricing

    Natalie Olivo

    A recent IRS advice memorandum disregards certain details about affiliated companies when treating them as unrelated businesses for the purpose of pricing an intercompany loan, raising questions about how the arm's-length standard should apply to corporate group financing arrangements.

Expert Analysis

  • SG's Office Is Case Study To Help Close Legal Gender Gap

    Author Photo

    As women continue to be underrepresented in the upper echelons of the legal profession, law firms could learn from the example set by the Office of the Solicitor General, where culture and workplace policies have helped foster greater gender equality, say attorneys at Ocean Tomo.

  • Reimagining Law Firm Culture To Break The Cycle Of Burnout

    Author Photo

    While attorney burnout remains a perennial issue in the legal profession, shifting post-pandemic expectations mean that law firms must adapt their office cultures to retain talent, say Kevin Henderson and Eric Pacifici at SMB Law Group.

  • Cayman Islands Off AML Risk Lists, Signaling Robust Controls

    Author Photo

    As a world-leading jurisdiction for securitization special purpose entities, the removal of the Cayman Islands from increased anti-money laundering monitoring lists is a significant milestone that will benefit new and existing financial services customers conducting business in the territory, say lawyers at Walkers Global.

  • The Legal Industry Needs A Cybersecurity Paradigm Shift

    Author Photo

    As law firms face ever-increasing risks of cyberattacks and ransomware incidents, the legal industry must implement robust cybersecurity measures and privacy-centric practices to preserve attorney-client privilege, safeguard client trust and uphold the profession’s integrity, says Ryan Paterson at Unplugged.

  • As Promised, IRS Is Coming For Crypto Tax Evaders

    Author Photo

    The IRS is fulfilling its promise to crack down on those who have neglected to pay taxes on cryptocurrency earnings, as demonstrated by recently imposed prison sentences, enforcement initiatives and meetings with international counterparts — suggesting a few key takeaways for taxpayer compliance, say attorneys at BakerHostetler.

  • 5 Reasons Associates Shouldn't Take A Job Just For Money

    Author Photo

    As a number of BigLaw firms increase salary scales for early-career attorneys, law students and lateral associates considering new job offers should weigh several key factors that may matter more than financial compensation, say Albert Tawil at Lateral Hub and Ruvin Levavi at Power Forward.

  • The Pop Culture Docket: Judge Djerassi On Super Bowl 52

    Author Photo

    Philadelphia Court of Common Pleas Judge Ramy Djerassi discusses how Super Bowl 52, in which the Philadelphia Eagles prevailed over the New England Patriots, provides an apt metaphor for alternative dispute resolution processes in commercial business cases.

  • Employee Experience Strategy Can Boost Law Firm Success

    Author Photo

    Amid continuing business uncertainty, law firms should consider adopting a holistic employee experience strategy — prioritizing consistency, targeting signature moments and leveraging measurement tools — to maximize productivity and profitability, says Haley Revel at Calibrate Consulting.

  • 6 Practice Pointers For Pro Bono Immigration Practice

    Author Photo

    An attorney taking on their first pro bono immigration matter may find the law and procedures beguiling, but understanding key deadlines, the significance of individual immigration judges' rules and specialized aspects of the practice can help avoid common missteps, says Steven Malm at Haynes Boone.

  • Lessons From Country Singer's Personal Service Saga

    Author Photo

    Recent reports that country singer Luke Combs won a judgment against a Florida woman who didn’t receive notice of the counterfeit suit against her should serve as a reminder for attorneys on best practices for effectuating service by electronic means, say attorneys at Jenner & Block.

  • 7 E-Discovery Predictions For 2024 And Beyond

    Author Photo

    The legal and technical issues of e-discovery now affect virtually every lawsuit, and in the year to come, practitioners can expect practices and policies to evolve in a number of ways, from the expanded use of relevancy redactions to mandated information security provisions in protective orders, say attorneys at Littler.

  • 5 Litigation Funding Trends To Note In 2024

    Author Photo

    Over the next year and beyond, litigation funding will continue to evolve in ways that affect attorneys and the larger litigation landscape, from the growth of a secondary market for funded claims, to rising interest rates restricting the availability of capital, says Jeffery Lula at GLS Capital.

  • 4 Legal Ethics Considerations For The New Year

    Author Photo

    As attorneys and clients reset for a new year, now is a good time to take a step back and review some core ethical issues that attorneys should keep front of mind in 2024, including approaching generative artificial intelligence with caution and care, and avoiding pitfalls in outside counsel guidelines, say attorneys at HWG.