Tax News Daily
The latest tax news from around the world, summarised and tagged for tax professionals. Updated twice daily.
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4 Questions As Gov't Appeals Illegal Tariff Refund Suit
The U.S. government is appealing a court ruling in a lawsuit concerning illegal tariff refunds, raising four key legal questions that will shape the outcome of the case. The appeal centers on whether the government must refund tariffs that were deemed unlawfully imposed, touching on issues of jurisdiction, sovereign immunity, and the scope of judicial review over executive trade actions. Tax and trade professionals are monitoring the case closely as it could have significant implications for importers seeking refunds on tariffs previously collected under disputed legal authority, potentially affecting billions of dollars in customs duties paid by U.S. businesses.
IRS Must Revisit Whistleblower Award Denial, DC Circ. Rules
The U.S. Court of Appeals for the D.C. Circuit has ruled that the IRS must reconsider its denial of a whistleblower award, finding the agency's reasoning insufficient. The case involves a whistleblower who provided information leading to tax enforcement action, but was denied an award by the IRS Whistleblower Office. The D.C. Circuit found procedural or substantive flaws in the IRS's denial decision, remanding the matter for further review. This ruling has implications for IRS whistleblower program administration under IRC Section 7623, which entitles informants to awards when their tips contribute to collected tax proceeds exceeding $2 million.
Taxation With Representation: Gibson Dunn, Davis Polk, S&C
This Law360 'Taxation With Representation' column highlights recent significant M&A and corporate transactions where major law firms Gibson Dunn, Davis Polk, and Sullivan & Cromwell provided tax counsel. These deal-focused roundups typically cover the tax structuring aspects of mergers, acquisitions, and capital markets transactions, detailing the roles of leading law firms in advising clients on tax-efficient deal structures. The transactions likely involve cross-border elements, corporate reorganizations, and related tax considerations. Without full article access, the piece reflects ongoing high-value corporate activity requiring sophisticated tax advisory work from elite law firm practices.
Debt Management and Banking Manual
HMRC's Debt Management and Banking Manual is an internal guidance resource published on GOV.UK that outlines procedures and policies for collecting and managing tax debts owed to HMRC. It covers enforcement powers, collection methods, banking arrangements, and operational guidance for HMRC staff handling debt recovery across various tax regimes. The manual addresses topics such as time-to-pay arrangements, enforcement action, insolvency proceedings, and internal banking processes. It serves as a reference tool for HMRC officers managing taxpayer liabilities and ensuring compliance with debt collection obligations under UK tax law.
Ride App Bolt Can't Cut £190M VAT Bill After All, Court Rules
A UK court has ruled that ride-hailing app Bolt cannot reduce its £190 million VAT liability, rejecting the company's attempt to restructure its tax position. The case centres on whether Bolt's drivers are providing services to passengers directly or whether Bolt acts as the principal supplier, which determines the VAT treatment of fares. The court upheld HMRC's position that Bolt is liable for VAT on the full value of rides rather than just its commission. This ruling has significant implications for the gig economy platform sector, following similar disputes involving Uber, and clarifies how VAT applies to ride-hailing intermediaries operating in the UK.
International Manual
HMRC's International Manual is a comprehensive guidance resource covering the UK's international tax rules for tax professionals and HMRC officers. It addresses cross-border taxation matters including transfer pricing, permanent establishments, controlled foreign companies (CFCs), double taxation relief, and diverted profits. The manual provides detailed technical guidance on how UK legislation applies to multinational enterprises and cross-border transactions, incorporating OECD principles and UK-specific statutory provisions. It serves as an authoritative reference for practitioners navigating the interaction between UK domestic law and international tax treaties, covering both inbound and outbound investment scenarios affecting businesses operating across multiple jurisdictions.
Tax Minister to owners of dodgy shops: “We are coming for you”
The UK Tax Minister has issued a direct warning to owners of non-compliant retail businesses engaged in tax evasion, signalling intensified HMRC enforcement action against 'dodgy shops.' The campaign targets businesses suspected of suppressing sales, operating off-the-books transactions, and failing to properly account for VAT and income taxes. HMRC is deploying compliance teams and data-driven intelligence to identify and investigate suspect retailers. The minister's public statement serves as both a deterrent and an announcement of increased audit activity in the retail sector, emphasising that tax cheats face significant penalties, back-tax demands, and potential criminal prosecution.
Using Form 8821 to Deliver Higher-Value Service Through Proactive Transcript Monitoring
Form 8821 (Tax Information Authorization) allows CPAs and tax professionals to access IRS transcripts on behalf of clients without full power of attorney. This article explores how proactive transcript monitoring via Form 8821 enables practitioners to deliver higher-value advisory services by identifying IRS notices, unfiled returns, balance dues, and account changes before clients are aware. By regularly reviewing client transcripts through the IRS's Tax Pro Account or e-Services, practitioners can anticipate compliance issues, strengthen client relationships, and position themselves as proactive advisors rather than reactive problem-solvers. The approach transforms routine compliance work into strategic client management and early intervention in potential tax controversies.
Comments on T-444/25 (Cavert) – General Court Rules VAT Groups Are Not Single Legal Entities
The EU General Court ruled in case T-444/25 (Cavert) that VAT groups do not constitute single legal entities for VAT purposes. The judgment clarifies the legal character of VAT grouping arrangements under EU VAT law, confirming that member companies within a VAT group retain their individual legal identities despite being treated as a single taxable person for VAT compliance purposes. This distinction has significant practical implications for contractual liability, litigation standing, and regulatory obligations of VAT group members. Tax professionals advising businesses operating within VAT groups should reassess structural arrangements and internal agreements in light of this clarification of the boundaries of VAT group consolidation.
Ex-Bank Chief Admits Role In Odebrecht Tax Evasion Plot
A former bank chief has admitted involvement in a tax evasion scheme connected to Odebrecht, the Brazilian construction conglomerate at the center of one of Latin America's largest corruption scandals. The admission relates to facilitating financial structures used to conceal income and evade tax obligations as part of the broader Odebrecht bribery and corruption network. Odebrecht, now rebranded as Novonor, previously faced multi-jurisdictional investigations involving bribery of government officials across numerous countries. This latest development highlights the ongoing legal proceedings stemming from the scandal, with financial institution executives facing accountability for enabling tax evasion through sophisticated banking arrangements.
IRS Restructures Security Summit to Better Tackle Tax-Related ID Theft and Fraud
The IRS has restructured its Security Summit, a public-private partnership established in 2015 between the IRS, state tax agencies, and the tax industry, to more effectively combat tax-related identity theft and fraud. The reorganization aims to modernize the coalition's approach by streamlining operations and enhancing collaboration among stakeholders. The restructured Summit will focus on improving authentication measures, data sharing, and fraud detection capabilities across federal and state tax systems. This initiative reflects ongoing efforts to protect taxpayers and the tax administration system from increasingly sophisticated identity theft schemes that cost billions annually in fraudulent refund claims.
Revised Microcaptive Rules Still Violate APA, 6th Circ. Told
The Sixth Circuit is being urged to find that revised IRS microcaptive insurance transaction rules still violate the Administrative Procedure Act (APA). Challengers argue the updated regulations, which target captive insurance arrangements the IRS considers abusive tax shelters, were not properly promulgated and lack adequate notice-and-comment rulemaking. Microcaptive transactions involve small captive insurance companies making 831(b) tax elections to exclude premium income from taxation. The IRS has long scrutinized these arrangements as listed transactions. The appeal follows lower court proceedings and is part of ongoing litigation challenging the procedural validity of IRS guidance targeting these structures under U.S. tax law.
IRS Provides Year in Review in 2025 Data Book
The IRS has released its 2025 Data Book, providing a comprehensive statistical overview of IRS activities during fiscal year 2025. The annual publication covers key metrics including tax return filings, examination and audit rates, collection activities, taxpayer service statistics, and enforcement outcomes. For tax professionals, the Data Book serves as an essential reference for understanding IRS operational trends, audit selection patterns, and compliance enforcement priorities. The data helps practitioners benchmark client risk profiles against national audit rates across various taxpayer categories, including individuals, corporations, and pass-through entities, while also tracking IRS resource allocation and strategic enforcement focus areas.
Treasury, IRS Provide Section 892 Tax Relief for Sovereign Investors
The U.S. Treasury and IRS have issued guidance providing tax relief under Section 892 of the Internal Revenue Code for sovereign investors, including foreign governments and their controlled entities. Section 892 generally exempts foreign governments from U.S. tax on certain investment income, including interest, dividends, and gains from U.S. securities. The new relief addresses specific compliance or structural concerns affecting sovereign wealth funds and similar entities investing in U.S. markets. This guidance is significant for international sovereign investors navigating U.S. withholding tax obligations and eligibility requirements, potentially broadening or clarifying the scope of exemptions available to qualifying foreign governmental entities investing in the United States.
Tax Practice Weekly Update – Issue 22 (11/06/2026)
This is a weekly tax practice update from the South African Institute of Tax Professionals (SAIT), Issue 22 dated 11 June 2026. The update covers recent developments in South African tax practice relevant to tax professionals. SAIT's weekly updates typically consolidate legislative changes, SARS communications, case law, and regulatory developments affecting practitioners in South Africa. Without access to the full article content, the summary is based on the publication's known format and the South African tax context. Tax professionals should consult the SAIT website directly for the specific legislative, administrative, and compliance developments covered in this particular issue.
IRS holds hiring events in 6 cities after staff cuts
The IRS is conducting hiring events across six U.S. cities in an effort to rebuild its workforce following significant staff reductions. These recruitment drives signal a partial reversal of earlier workforce cuts that had raised concerns among tax professionals about the agency's capacity to process returns, handle audits, and provide taxpayer services. The hiring push reflects ongoing tension between agency resource constraints and operational demands. For tax practitioners, reconstituting IRS staffing could affect audit rates, response times for correspondence, and overall enforcement activity. The specific cities and roles targeted suggest the IRS is prioritizing frontline compliance and taxpayer assistance functions to restore diminished operational capacity.
AICPA recommends improvements to CP53E notice process
The AICPA has submitted recommendations to the IRS seeking improvements to the CP53E notice process. CP53E notices are issued when the IRS is unable to direct deposit a tax refund, typically due to account issues or bank rejections. The AICPA's recommendations focus on enhancing clarity and efficiency in how these notices are communicated to taxpayers, reducing confusion and administrative burden for both practitioners and their clients. The proposals aim to streamline the refund reissuance process and improve taxpayer guidance within the notice itself, reflecting ongoing efforts to modernize IRS correspondence and reduce unnecessary friction in refund delivery procedures.
IRS to merge tax practitioner offices despite AICPA opposition
The IRS plans to merge its tax practitioner-facing offices despite formal opposition from the American Institute of CPAs (AICPA). The consolidation affects offices that serve as key liaison points between the IRS and tax professionals, including CPAs, enrolled agents, and attorneys. The AICPA has raised concerns that merging these units could reduce practitioner access to IRS resources, impair taxpayer representation, and diminish the quality of service for complex compliance issues. The restructuring is part of broader IRS operational changes under the current administration. Tax practitioners fear the move will create communication bottlenecks and reduce specialised support available to professionals navigating audits and compliance matters.
SARS Targets R300 Billion Tax Gap Through Illicit Trade Crackdown
The South African Revenue Service (SARS) is intensifying efforts to close a R300 billion tax gap attributable to illicit trade activities. The crackdown targets smuggling, counterfeiting, and other forms of illicit commerce that deprive the fiscus of significant revenue. SARS is deploying enhanced enforcement mechanisms, intelligence-driven operations, and inter-agency collaboration to detect and prosecute illicit trade networks. This initiative forms part of SARS's broader compliance and revenue recovery strategy, addressing sectors particularly vulnerable to illicit activity such as tobacco, alcohol, and fuel. Tax professionals should note the increased scrutiny and potential implications for supply chain compliance and customs documentation requirements.
Italy: Court rules DST not applicable to direct online sales
An Italian court has ruled that Italy's Digital Services Tax (DST) does not apply to direct online sales transactions. The decision clarifies the scope of Italy's DST, which targets revenues from digital intermediation services and advertising rather than straightforward e-commerce sales where a company directly sells goods or services to consumers online. This ruling has significant implications for multinational businesses operating direct-to-consumer digital sales models in Italy, potentially excluding a broad category of online revenue from DST liability. Tax professionals advising clients with Italian digital operations should review their DST exposure in light of this judicial interpretation of the tax's applicability.
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