French taxpayers are urging the country’s tax authorities to adopt some of HM Revenue & Customs’ (HMRC) audit practices after the French government announced a new pilot designed to improve taxpayer-tax authority relationships.
Online retailers Amazon and Overstock are battling the New York State Department of Taxation and Finance in court over a requirement for remote sellers to collect state sales tax. The ruling will have an impact on companies operating throughout the US.
Bank of New York Mellon (BNY Mellon) had its case thrown out by the US Tax Court this week as the court described a structured trust advantaged repackaged securities (STARS) scheme it was sold by Barclays in 2001 as an elaborate subterfuge for creating foreign tax credits.
The Canada Revenue Agency (CRA) must disclose to taxpayers how specific provisions of the Income Tax Act (Act) were abused whenever it applies the general anti-avoidance rule (GAAR) in a dispute, the Tax Court of Canada has ruled. And advisers say taxpayers could benefit from this information in future GAAR cases.
A challenge by the Portuguese tax authorities of a multinational’s cash pooling arrangement – because the authorities felt it inappropriately used the comparable uncontrolled price (CUP) – has been denied by an arbitration court. The case should alert Portuguese taxpayers to review the arm’s-length nature of their cash pooling arrangements.
US taxpayers who seek to exploit the differences in the tax treatment of debt and equity will need to prepare for more aggressive enforcement by the Internal Revenue Service (IRS). The decisions in three recent court cases, all featured in this International Tax Review special focus, suggest how companies could deal with this approach from the tax authorities.
