International

  • June 05, 2024

    Win May Embolden IRS Use Of Economic Substance Doctrine

    The IRS' successful wielding of the economic substance doctrine to characterize multinational telecommunications corporation Liberty Global's sophisticated set of intercompany deals as an abusive tax shelter could encourage the agency to apply similar analysis to even the most basic tax transactions.

  • June 05, 2024

    Streamers To Be Hit With 5% Charge On Canadian Revenue

    Streaming services such as Netflix and Disney+ soon will be required to contribute 5% of their Canadian revenues to the country's broadcasting system, which could generate CA$200 million ($146 million) a year, Canada's government said, drawing the ire of the National Foreign Trade Council.

  • June 05, 2024

    Gov't UK ISA Savings Proposal Gets Cold Shoulder

    More financial firms on Wednesday warned that the U.K. government's plans to give consumers a new tax break for investing in U.K. companies was unworkable, adding it could conflict with the Financial Conduct Authority's consumer protection rules.

  • June 05, 2024

    EU Corp. Tax Proposal Delayed By Uncertainty On OECD Plan

    European Union countries' negotiations on a proposal to streamline corporate taxation have been delayed because of a lack of clarity on implementation of the OECD's global minimum tax and the design of the accompanying reallocation of taxing rights, a top European Commission tax official said Wednesday.

  • June 05, 2024

    OECD Official Hopes Pillar 2 Ends Some 'Wasteful' Incentives

    The introduction of the global minimum corporate tax known as Pillar Two should lead to the end of some "wasteful" incentives that narrow the tax base, an official from the Organization for Economic Cooperation and Development said Wednesday.

  • June 05, 2024

    Labour's Pension Tax Plans Backed By Fiscal Research Body

    An influential economics think tank has backed plans by the Labour Party to reintroduce the lifetime allowance, arguing that there should be a cap on the tax-free accumulation of pensions wealth.

  • June 04, 2024

    Full DC Circ. Asked To Weigh Foreign Info Disclosure Penalties

    A D.C. Circuit panel made questionable assumptions about congressional intent when it revived the IRS' authority to assess and administratively collect penalties related to undisclosed foreign corporations, a businessman said Tuesday in asking the full appellate court to hear his case.

  • June 04, 2024

    Australian Court Upholds Ex-Chinese Citizen's $7.7M Tax Bill

    An Australian court upheld an AU$11.5 million ($7.7 million) tax bill from the Australian Taxation Office to a former Chinese citizen after determining he failed to provide enough evidence to support his alternative tax liability calculation.

  • June 04, 2024

    Calif. OTA Rejects Couple's Claim Of Bolivia Residency

    A California couple owes additional state income tax on a retirement account distribution, the state Office of Tax Appeals said in an opinion released Tuesday, rejecting the pair's assertion that they were domiciled in Bolivia at the time.

  • June 04, 2024

    EU OKs Italian Renewable Energy Plan Funded By Levy

    The European Commission said Tuesday that it approved Italy's plan to introduce a levy on the electricity bills of final consumers to fund construction of renewable energy plants, finding the benefits far outweigh any potential damage to competition and trade.

  • June 04, 2024

    Spain Sends Pillar 2 Bill To Legislature After EU Pressure

    The Spanish government announced Tuesday it has sent a bill to its legislature that would transpose the European Union directive to implement the Organization for Economic Cooperation and Development's global minimum tax on large corporations following pressure from the bloc.

  • June 04, 2024

    New Dutch Gov't Seen Returning To Pro-Biz Positions

    The incoming conservative Dutch government is expected to adopt tax policies that align with the Netherlands' long-standing reputation as a tax-friendly jurisdiction for businesses, in part by reversing a recently enacted measure that taxed companies' purchases of their own shares.

  • June 04, 2024

    Luxembourg Candidate Calls To End EU Tax Unanimity Rule

    The leading Socialist candidate in the upcoming European parliamentary elections said the European Union should scrap the need for unanimity for all tax decisions, clashing with his home country of Luxembourg's longtime stand that's meant to protect its status as a financial center.

  • June 04, 2024

    Austrian Authorities Reveal Spike In Fake Companies

    The number of fake companies in Austria is increasing, according to data from the Finance Ministry, which said that it hoped a new law would aid in combating the trend.

  • June 03, 2024

    Danish Tax Agency Says $2.1B Tax Fraud Suits Not Filed Late

    Denmark's tax administrator urged a New York federal court to reject bids to toss its suits against U.S. pension plans and individuals it accuses of participating in a $2.1 billion fraud scheme, saying the suits were not filed too late.

  • June 03, 2024

    Treasury Aims To Salvage Corp. Transparency Act At 11th Circ.

    The Corporate Transparency Act is a valid exercise of congressional authority to curb money laundering under the commerce clause and the necessary and proper clause in the Constitution, the U.S. Treasury Department told the Eleventh Circuit on Monday in a bid to restore the law's reporting requirements.

  • June 03, 2024

    Tax Convictions Withstand Poor Counsel Claim, 4th Circ. Says

    A North Carolina man's claim of ineffective counsel is not sufficient reason to vacate his convictions for filing false tax returns and obstructing an official proceeding in a case involving $2.1 million in unreported income sent from Bermuda entities, the Fourth Circuit ruled.

  • June 03, 2024

    Texas Oil Co. Says IRS Hasn't Paid $36M Promised Refund

    The Internal Revenue Service has promised to pay a Texas oil company more than $36 million in tax refunds and credits for the 2009 tax year but has failed to do so, the company told a federal court.

  • June 03, 2024

    African Gov'ts Made Big Gains From Data Swaps In 2023

    African tax authorities made huge headway last year in using the international standard for exchange of information on request to find additional revenues of €2.2 billion ($2.4 billion), which is more than over the past 13 years combined, the OECD reported Monday.

  • June 03, 2024

    UK Liberal Democrats Call For Buyback Tax, Tripling DST

    The U.K. Liberal Democrat party called for a 4% share buyback tax on the 100 largest corporations on the stock market as well as for tripling the country's 2% digital services tax, with the additional revenue generated to be earmarked to benefit schoolchildren.

  • June 03, 2024

    South Korea Extending Tax Breaks For Growing Businesses

    Companies in South Korea that graduate from being considered small and medium enterprises to middle-market enterprises will see the grace period that allows them to continue to receive tax breaks granted to smaller entities extended, the country's finance ministry said Monday.

  • June 03, 2024

    7 Arrested In €18M Italian VAT Fraud Ring

    Financial police in Italy arrested seven suspects Monday in connection with a value-added tax fraud scheme involving beverages that resulted in losses of €18 million ($19.6 million), the European Public Prosecutor's Office said.

  • June 03, 2024

    EU Court Asked To Rule On Belgian Tax On Dividends

    A Belgian court asked the European Union's highest court to rule on whether the country can tax dividends transferred from a subsidiary to a parent company, despite an EU law apparently prohibiting this, a document published Monday showed.

  • June 01, 2024

    Blockbuster Summer: 10 Big Issues Justices Still Must Decide

    As the calendar flips over to June, the U.S. Supreme Court still has heaps of cases to decide on issues ranging from trademark registration rules to judicial deference and presidential immunity. Here, Law360 looks at 10 of the most important topics the court has yet to decide.

  • May 31, 2024

    3M Tells 8th Circ. IRS Used Invalid Regs For $24M Allocation

    Multinational conglomerate 3M reiterated Friday its bid for the Eighth Circuit to reverse a U.S. Tax Court decision allowing the IRS to allocate nearly $24 million from the company's Brazilian affiliate, arguing the agency's adjustment relied on substantively invalid regulations.

Expert Analysis

  • How New EU Tax And Transfer Pricing Rules May Affect M&A

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    Companies involved in mergers and acquisitions may need to adjust fiscal due diligence procedures to ensure they consider potential far-reaching effects of newly implemented transfer pricing measures, such as newly implemented global minimum tax and European Union anti-tax avoidance directives and proposals, says Patrick Tijhuis at BDO.

  • How Firms Can Ensure Associate Gender Parity Lasts

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    Among associates, women now outnumber men for the first time, but progress toward gender equality at the top of the legal profession remains glacially slow, and firms must implement time-tested solutions to ensure associates’ gender parity lasts throughout their careers, say Kelly Culhane and Nicole Joseph at Culhane Meadows.

  • 7 Common Myths About Lateral Partner Moves

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    As lateral recruiting remains a key factor for law firm growth, partners considering a lateral move should be aware of a few commonly held myths — some of which contain a kernel of truth, and some of which are flat out wrong, says Dave Maurer at Major Lindsey.

  • 6 Pointers For Attys To Build Trust, Credibility On Social Media

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    In an era of information overload, attorneys can use social media strategically — from making infographics to leveraging targeted advertising — to cut through the noise and establish a reputation among current and potential clients, says Marly Broudie at SocialEyes Communications.

  • US-Chile Tax Treaty May Encourage Cross-Border Investment

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    Provisions in the recently effective U.S.-Chile bilateral income tax treaty should encourage business between the two countries, as they reduce U.S. withholding tax on investment income for Chilean taxpayers, exempt certain U.S. taxpayers from Chilean capital gains tax, and clarify U.S. foreign tax credit rules, say attorneys at Kramer Levin.

  • A Post-Mortem Analysis Of Stroock's Demise

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    After the dissolution of 147-year-old firm Stroock late last year shook up the legal world, a post-mortem analysis of the data reveals a long list of warning signs preceding the firm’s collapse — and provides some insight into how other firms might avoid the same disastrous fate, says Craig Savitzky at Leopard Solutions.

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

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    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

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    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

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    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

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    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

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    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

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    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

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    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.

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