International Trade Tax Civil Remedies

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IRS Denies Treaty Benefits Despite Lack of Treaty Shopping

In Starr International Company, Inc., v. United States, the taxpayer (“Starr International Company, Inc.” or “SICO”) filed a complaint in the United States District Court for the District of Columbia seeking a tax refund from...more

DOJ Secures Verdict in Excess of $2 Million for Failure to File FBARs

On Wednesday, May 28, 2014, a jury in Miami issued a verdict against a taxpayer for $2.2 million in fees, interest, and civil penalties for willfully failing to file foreign bank account reports (FBARs) for his Swiss bank...more

Prince v ACE: Extra-Territorial Effect Of U.S. Tax Laws?

Should a Canadian court exercise its jurisdiction to hear a class action lawsuit against Air Canada for improperly collecting U.S. travel taxes on ticket purchases in Canada and on air travel in Canada?...more

£1 Billion At Stake - Taxpayer wins compound interest on overpaid VAT

The High Court (Henderson J) handed down its decision on 28 March 2014 awarding the mail order and retail company, Littlewoods Retail Limited, compound interest on sums of overpaid VAT that had originally been reimbursed to...more

Velcro Canada – Clarification on Cost Awards

n what circumstances can a party obtain a large lump-sum cost award after a favourable Tax Court decision? That was the question considered by the Tax Court in Velcro Canada Inc. v. The Queen (2012 TCC 273), in which the...more

Federal Court of Appeal: Canada Cannot Tax Treaty Income Twice

It is trite law that one of the main purposes of tax treaties is to prevent double taxation of the same income. In Canada this principle has often been treated with a grain of salt since Canadian domestic rules do not bar...more

Italian Revenue Agency Provides Guidance on Mutual Agreement Procedures

Italian tax authorities have become increasingly involved in mutual agreement procedures (MAPs) with foreign competent authorities in order to avoid double taxation, mostly as a result of an approach to transfer pricing...more

Financial Fraud Law Report: Financial Fraud Victims May Benefit from Swiss Bank's Disclosures

Originally published in the July-August 2012 issue of the Financial Fraud Law Report. Lawyer Michael Diaz, Jr., Says Financial Fraud Victims May Benefit from Swiss Bank’s Disclosures Swiss banking giant UBS’...more

Reuters: Corporations Face Long Odds in Tax Cases Heard by the United States Supreme Court – Situation Brighter in Canada

Reuters recently reported a study showing that corporations face very long odds in tax appeals heard by the United States Supreme Court. There were 919 income tax cases in the Supreme Court of the United States from 1909 to...more

A Month in UK Employment Law - March 2012

In This Issue: A monthly newsletter covering the latest developments in UK Employment Law. Case Update - 1 News Update - 4 Excerpt from Case Update: TEAM MOVES AND SPRINGBOARD INJUNCTIONS In the recent case...more

Lehman Bankruptcy - In re: Lehman Brothers Holdings, Inc., et al., No. 08-13555

Lehman Plan Becomes Effective; Distributions to Begin April 17 On March 6, 2012, Lehman Brothers Holdings Inc. and its affiliated debtors announced that their Modified Third Amended Joint Chapter 11 Plan, which had been...more

Swiss Banks Ready to Concede to IRS Demands

The IRS is investigating 11 Swiss banks (including Credit Suisse Group) suspected of helping wealthy American account holders hide taxable income in their offshore accounts. As a result, US and Swiss authorities are said to...more

Foreign Dividends in California: Apple Loses on Dividend Ordering. Now What?

Last week, the California Court of Appeal in Apple Inc. v. Franchise Tax Board rejected Apple's claim for preferential ordering for dividends paid by foreign subsidiaries. The court did, however, conclude that Apple was...more

Trade & Manufacturing Alert - May 2011

In This Issue: - 01 U.S.-Colombian Accord On Labor Issues And U.S.-Panamanian Accord On Tax Information Open Way For Congressional Action On Three FTAs; Timing And Legislative Process Still Uncertain - 02 Federal...more

Intensive Efforts Underway to Conclude WTO Doha Trade Negotiations

Implications for Companies with International Trade Interests Following calls by world leaders at the G20 and APEC meetings in November to conclude the Doha Round of multilateral trade negotiations by the end of 2011,...more

Sutherland Salt Shaker- Vol. 1 No. 8- August 2010

IN THIS ISSUE: Roam If You Want To: MTSA’s Application to Foreign Roaming; California Court of Appeal Addresses Proper Remedy for Taxpayers Claiming Dividends Received Deduction, Application of Post-Amnesty Penalties;...more

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