International

  • May 21, 2024

    CohnReznick Adds PwC Partner To International Tax Practice

    CohnReznick has a new principal in its international tax practice who previously served as a partner at PwC, the firm announced.

  • May 21, 2024

    22 States Tell 11th Circ. Corp. Transparency Act Goes Too Far

    The federal Corporate Transparency Act unconstitutionally displaces state authority and its enforcement would economically harm states and their residents, attorneys general from 22 states told the Eleventh Circuit, urging it to uphold a ruling that struck down the law.

  • May 21, 2024

    Yellen Says US Can't Support Global Tax On Billionaires

    Treasury Secretary Janet Yellen said the U.S. can't support Brazil's proposal for the Group of 20 nations to endorse pursuing a multilateral agreement to tax billionaires' wealth at a minimum rate.

  • May 21, 2024

    Italy Needs To Adjust Tax Credits To Limit Debt, IMF Says

    While generous Italian tax regimes such as credits for home improvements have helped the country's economy rebound quickly from the pandemic, they also pose a risk to the country's debt burden and need to be adjusted, the International Monetary Fund said.

  • May 21, 2024

    Strategic Hiring Was The New Normal For BigLaw In 2023

    The 400 largest law firms by headcount in the U.S. grew more slowly in 2023 than in the previous two years, while Kirkland & Ellis LLP surpassed the 3,000-attorney threshold, according to the latest Law360 ranking.

  • May 21, 2024

    The Law360 400: Tracking The Largest US Law Firms

    The legal market expanded more tentatively in 2023 than in previous years amid a slowdown in demand for legal services, especially in transactions, an area that has been sluggish but is expected to quicken in the near future.

  • May 21, 2024

    Portuguese Cos. Appeal EU Court Ruling On Tax Breaks

    Three Portuguese companies have appealed a European Union court's judgment backing a European Commission decision that demanded repayment of tax breaks considered to have been illegal, documents published Tuesday showed.

  • May 21, 2024

    EU Adopts Decision To Send Russian Profits To Ukraine

    European Union countries adopted a formal decision Tuesday to transfer the net income from frozen and immobilized Russian state assets to EU funds for rebuilding Ukraine and buying arms for the war-torn country, a news release said.

  • May 21, 2024

    I Am An Honest Man, British Trader Tells £1.4B Fraud Trial

    Sanjay Shah, a former hedge fund owner who is accused of defrauding Denmark's tax authority out of £1.4 billion ($1.8 billion), told a London court on Tuesday that he is an "honest man" who traded using a legal "loophole."

  • May 21, 2024

    IMF Report Warns UK Against More Tax Cuts

    The United Kingdom should refrain from additional tax cuts unless they are credibly shown to boost economic growth and are offset by measures to cut the deficit, the International Monetary Fund said Tuesday.

  • May 20, 2024

    Transparency Act Violates Constitution, Groups Tell 11th Circ.

    The Corporate Transparency Act's reporting requirements violate the Fifth Amendment's protection against self-incrimination and other constitutional provisions, libertarian think tank Cato Institute and others said Monday in urging the Eleventh Circuit to uphold an Alabama district court's ruling against the law.

  • May 20, 2024

    India's Top Court Says Accounting Body Can Limit Tax Audits

    India's regulatory association for accountants has the authority to limit the amount of tax audits performed by an individual accountant to 60, the Supreme Court of India ruled — even as it canceled ongoing disciplinary proceedings over the restriction because of inconsistent enforcement.

  • May 20, 2024

    IRS Guidance Plan Should Cover Corp. AMT, AICPA Says

    The Internal Revenue Service should provide guidance on the definitions and applications of the 15% corporate alternative minimum tax, among other topics, the American Institute of Certified Public Accountants said in comments published by the agency Monday.

  • May 20, 2024

    Turkey Will Introduce 15% Global Minimum Tax, Minister Says

    The Turkish government will introduce the 15% global minimum corporate tax and will not provide any incentives that would allow companies to pay a lower rate, the country's finance minister told its public broadcaster Monday.

  • May 20, 2024

    Isle Of Man Commits To Portion Of Global Minimum Tax

    The Isle of Man plans to introduce legislation implementing the qualified domestic minimum top-up tax portion of the OECD's Pillar Two directive starting in 2025 but is less committed to adopting the income inclusion rule, the island's Treasury said Monday.

  • May 20, 2024

    HMRC Lays Out Registration Rules For Pillar 2

    Companies covered by the U.K.'s implementation of the Organization for Economic Cooperation and Development's Pillar Two global minimum tax directive must register with HM Revenue & Customs within six months of the accounting period that makes them eligible, the agency said Monday.

  • May 20, 2024

    US, Argentina To Carry Out 1st FATCA Info Exchange

    The Internal Revenue Service approved cybersecurity measures by Argentina in a step that clears the way for the first automatic information exchange under the Foreign Account Tax Compliance Act between the two countries in September, Argentina's revenue service said Monday.

  • May 17, 2024

    Med Device Co. Allowed $160M In Deductions, Tax Court Told

    A tax code provision in place before the 2017 federal tax overhaul changed it allows a medical device manufacturer to claim more than $160 million in deductions for dividends despite the government's attempt to apply the law retroactively, company counsel told the U.S. Tax Court on Friday.

  • May 17, 2024

    Michigan Doctor Seeks Release From Contempt In FBAR Fight

    A Michigan doctor incarcerated for civil contempt in a case in which he was ordered to repay more than $1 million in penalties for failure to report foreign accounts should be freed because he can no longer satisfy the terms of his release, he told a Michigan federal court.

  • May 17, 2024

    Koch-Tied Group Says Transparency Law Offends Federalism

    The Corporate Transparency Act is unconstitutional because it does not regulate interstate commerce yet mandates that state-registered entities disclose personal information, a conservative group affiliated with the billionaire Koch brothers told the Eleventh Circuit on Friday.

  • May 17, 2024

    Credit Suisse Can't Reverse $21.3M Biz Loss Denial

    Credit Suisse cannot carry forward $21.3 million in business losses from 2015-2017 to its 2018 Michigan tax return, a state appeals court said, letting stand a ruling that the bank miscalculated its business income from those years on its returns.

  • May 17, 2024

    New Domestic Content Guidance May Boost Energy Credits

    The U.S. Treasury Department's new guidance on bonus tax credits for clean energy projects that source domestic-made materials and components aims to simplify the process for determining eligibility and spur more development to get those extra incentives.

  • May 17, 2024

    Italian Financial Police Uncover €1B Tax Credit Scam

    The Italian Financial Police placed more than 300 people under investigation after uncovering a scheme to collect more than €1 billion ($1.09 billion) in tax credits designed to promote construction and energy matters, authorities said.

  • May 17, 2024

    Transfer Pricing Deal Needed For Pillar 1, OECD Official Says

    It's crucial for countries to agree on transfer pricing policies under an international profit reallocation agreement known as Pillar One as they work toward their end-of-June deadline to sign a related multilateral treaty, an OECD official said Friday.

  • May 17, 2024

    New Dutch Gov't Outlines Range Of Tax Measures

    The incoming Dutch government has outlined numerous tax measures affecting companies and individuals in its preliminary coalition agreement, a government document showed.

Expert Analysis

  • How FinCEN Proposal Expands RE Transaction Obligations

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    Against a regulatory backdrop foreshadowing anti-money laundering efforts in the real estate sector, the Financial Crimes Enforcement Network's proposed rule significantly expands reporting requirements for certain nonfinanced residential real estate transfers and necessitates careful review, say attorneys at Fried Frank.

  • Business Litigators Have A Source Of Untapped Fulfillment

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    As increasing numbers of attorneys struggle with stress and mental health issues, business litigators can find protection against burnout by remembering their important role in society — because fulfillment in one’s work isn’t just reserved for public interest lawyers, say Bennett Rawicki and Peter Bigelow at Hilgers Graben.

  • Unpacking FinCEN's Proposed Real Estate Transaction Rule

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    Phil Jelsma and Ulrick Matsunaga at Crosbie Gliner take a close look at the Financial Crimes Enforcement Network's recently proposed rulemaking — which mandates new disclosures for professionals involved in all-cash real estate deals — and discuss best next steps for the broad range of businesses that could be affected.

  • Think Like A Lawyer: Forget Everything You Know About IRAC

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    The mode of legal reasoning most students learn in law school, often called “Issue, Rule, Application, Conclusion,” or IRAC, erroneously frames analysis as a separate, discrete step, resulting in disorganized briefs and untold obfuscation — but the fix is pretty simple, says Luke Andrews at Poole Huffman.

  • 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.

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