Law360 Tax Authority: Tax Authority International /tax-authority/international?utm_source=rss&utm_medium=rss&utm_campaign=section Latest articles for: Tax Authority International Copyright 2026 sa¹ú¼Ê´«Ã½. en-US Fri, 09 Jan 2026 17:01:16 +0000 US Disputes Right To Trial Before IRS Assesses FBAR Fines /tax-authority/international/articles/2428445?utm_source=rss&utm_medium=rss&utm_campaign=section /tax-authority/international/articles/2428445 A California man wasn't entitled to a jury trial prior to the IRS assessing penalties for his failure to report foreign bank accounts because the U.S. Supreme Court decision he cited limiting administrative courts for securities fraud doesn't apply, the government told a California federal court. Fri, 09 Jan 2026 16:38:39 +0000 The Case For Emulating, Not Dividing, The Ninth Circuit /tax-authority/international/articles/2427109?utm_source=rss&utm_medium=rss&utm_campaign=section /tax-authority/international/articles/2427109 Champions for improved judicial administration should reject the unfounded criticisms driving recent Senate proposals to divide the Ninth Circuit and instead seek to replicate the court's unique strengths and successes, says Ninth Circuit Judge J. Clifford Wallace. Fri, 09 Jan 2026 15:34:46 +0000 EU Council Approves Trade Pact With 4 S. American Countries /tax-authority/international/articles/2428338?utm_source=rss&utm_medium=rss&utm_campaign=section /tax-authority/international/articles/2428338 A legislative arm of the European Union approved the bloc's free trade agreement with four South American countries Friday, taking steps to create the largest global free trade zone. Fri, 09 Jan 2026 14:57:23 +0000 Taxation With Representation: King & Spalding, Torys, Milbank /tax-authority/international/articles/2428534?utm_source=rss&utm_medium=rss&utm_campaign=section /tax-authority/international/articles/2428534 In this week's Taxation With Representation, power generation company Vistra Corp. acquires Cogentrix Energy from Quantum Capital Group, real estate firm Minto Group partners with Crestpoint Real Estate Investments to take Minto's apartment-focused real estate investment trust private, and engineering services provider Jacobs acquires a remaining stake in PA Consulting. Fri, 09 Jan 2026 14:05:36 +0000 China To Cut VAT Export Tax Rebates For Solar Panels /tax-authority/international/articles/2428426?utm_source=rss&utm_medium=rss&utm_campaign=section /tax-authority/international/articles/2428426 China will eliminate its value-added tax export rebates for photovoltaic and other related products starting April 1, the country's Ministry of Finance said Friday. Fri, 09 Jan 2026 12:41:47 +0000 UK Gov't Rules Out Farm Inheritance Tax Concessions /tax-authority/international/articles/2428314?utm_source=rss&utm_medium=rss&utm_campaign=section /tax-authority/international/articles/2428314 The U.K.'s Labour government will not make more concessions to farmers on its inheritance tax rule changes for agricultural land after a recent compromise on the tax threshold, a minister said in a speech at a conference. Thu, 08 Jan 2026 18:56:52 +0000 OECD, Gov't Officials Praise 'Side-By-Side' Tax Deal /tax-authority/international/articles/2426611?utm_source=rss&utm_medium=rss&utm_campaign=section /tax-authority/international/articles/2426611 Officials from Germany, the U.S. and the OECD on Thursday hailed a recently finalized agreement among roughly 150 countries as a balanced solution to the U.S.' desire for a global minimum tax regime that operates "side by side" with its own rules. Thu, 08 Jan 2026 18:36:37 +0000 Courts Back Agencies Despite Loper Bright Ruling, DOJ Says /tax-authority/international/articles/2427080?utm_source=rss&utm_medium=rss&utm_campaign=section /tax-authority/international/articles/2427080 Appellate courts have mostly upheld federal agencies' interpretation of ambiguous statutes, including tax disputes, even after the U.S. Supreme Court's 2024 landmark decision that limited agency deference, a U.S. Department of Justice attorney said Thursday. Thu, 08 Jan 2026 17:28:40 +0000 US Asks 6th Circ. To Revive Reg In $89M FedEx Tax Suit /tax-authority/international/articles/2428014?utm_source=rss&utm_medium=rss&utm_campaign=section /tax-authority/international/articles/2428014 The Sixth Circuit should vacate a judgment that allowed FedEx an $89 million refund by discarding a regulation preventing companies from claiming foreign tax credits on earnings offset by losses, which aren't taxed in the U.S., the government said in an opening brief. Thu, 08 Jan 2026 17:08:31 +0000 Irish R&D Tax Credit Linked To €7B In Spending, Gov't Says /tax-authority/international/articles/2427872?utm_source=rss&utm_medium=rss&utm_campaign=section /tax-authority/international/articles/2427872 Ireland's tax credit for research and development is linked to €7 billion ($8.2 billion) in related spending by companies on the island in 2023 while costing the government about €1.4 billion, the Irish Department of Finance said Thursday. Thu, 08 Jan 2026 14:13:02 +0000 Data Supervisor Warns Against Exceptional VAT Info Searches /tax-authority/international/articles/2427817?utm_source=rss&utm_medium=rss&utm_campaign=section /tax-authority/international/articles/2427817 The European Union's plans to crack down on value-added tax fraud may blur the line between data cooperation and law enforcement, potentially undermining data protection, the EU's data supervisor warned Thursday. Thu, 08 Jan 2026 13:48:11 +0000 Audits Get Final Word On Economic Substance, IRS Atty Says /tax-authority/international/articles/2427692?utm_source=rss&utm_medium=rss&utm_campaign=section /tax-authority/international/articles/2427692 IRS attorneys provide legal guidance during audits on whether a transaction lacks economic substance, but examiners make the ultimate determination, an agency associate chief counsel said Thursday while explaining how the agency applies a powerful anti-abuse tool in audits. Thu, 08 Jan 2026 12:47:57 +0000 HSBC To Pay €300M To Settle French Tax Fraud Probe /tax-authority/international/articles/2427808?utm_source=rss&utm_medium=rss&utm_campaign=section /tax-authority/international/articles/2427808 HSBC has agreed to pay French authorities more than €300 million ($350 million) in fines and unpaid taxes to settle a criminal probe into how the bank's Paris branch handled dividend arbitrage transactions between 2014 and 2019, public prosecutors revealed Thursday. Thu, 08 Jan 2026 11:49:09 +0000 OECD Project Seeks To Ease Access To Tax Dispute Process /tax-authority/international/articles/2426605?utm_source=rss&utm_medium=rss&utm_campaign=section /tax-authority/international/articles/2426605 A new project at the OECD will aim to ensure that double-tax cases are eligible to be resolved through bilateral government negotiations under treaties no matter how they're characterized by a country's tax authority, a U.S. Treasury Department official said Thursday. Wed, 07 Jan 2026 19:17:09 +0000 US Official Gives Rationale For OECD Global Mobility Changes /tax-authority/international/articles/2426597?utm_source=rss&utm_medium=rss&utm_campaign=section /tax-authority/international/articles/2426597 Recent changes to the commentary on when a home office gives rise to a permanent establishment in the OECD model tax treaty reflect delegates' unhappiness with previous language on the availability of an office, a U.S. Treasury Department official said Wednesday. Wed, 07 Jan 2026 18:24:53 +0000 Reckless Conduct Can Be Willful FBAR Failure, 2nd Circ. Says /tax-authority/international/articles/2427450?utm_source=rss&utm_medium=rss&utm_campaign=section /tax-authority/international/articles/2427450 The standard for willful failure to report foreign bank accounts includes reckless conduct, and a 6% late payment penalty is mandatory for a couple who neglected fines for stashing millions in an undisclosed Swiss account, the Second Circuit said Wednesday, upholding a lower court's judgment. Wed, 07 Jan 2026 16:53:39 +0000 Tax Funding Oil Spill Cleanups Has Expired, IRS Clarifies /tax-authority/international/articles/2427647?utm_source=rss&utm_medium=rss&utm_campaign=section /tax-authority/international/articles/2427647 The Internal Revenue Service clarified Wednesday that the part of an added tax on crude oil and petroleum products earmarked for an oil spill cleanup fund expired at the end of 2025. Wed, 07 Jan 2026 16:01:49 +0000 Gov't Slow-Rolling Lower Fee For Expatriation, Court Told /tax-authority/international/articles/2427461?utm_source=rss&utm_medium=rss&utm_campaign=section /tax-authority/international/articles/2427461 The U.S. State Department has impermissibly slow-walked the rollout of a reduced fee for renouncing U.S. citizenship, a Paris-based group that represents Americans permanently residing abroad told a D.C. federal court. Wed, 07 Jan 2026 15:05:15 +0000 Australia Increasingly Blocking Tax Debtors From Leaving /tax-authority/international/articles/2427391?utm_source=rss&utm_medium=rss&utm_campaign=section /tax-authority/international/articles/2427391 The Australian Taxation Office is increasingly barring international travel for people with tax debts who it suspects of trying to flee their obligations, it said Wednesday. Wed, 07 Jan 2026 14:50:13 +0000 IRS Mulling Budget Bill's Changes To CFC Rules, Official Says /tax-authority/international/articles/2427451?utm_source=rss&utm_medium=rss&utm_campaign=section /tax-authority/international/articles/2427451 The Internal Revenue Service is weighing a balance between precision and administrability as it works on guidance for U.S. shareholders of foreign companies after the federal budget bill changed how to allocate overseas income, an agency official said Wednesday.