International
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September 26, 2024
OECD Publishes Streamlined Amount B Model Agreement
The Organization for Economic Cooperation and Development published a model agreement Thursday for a simplified and streamlined approach to the Amount B portion of Pillar One, a transfer pricing plan for certain baseline marketing and distribution activities.
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September 25, 2024
IBM Urges Justices To Review NY Tax On Foreign Royalties
New York's system for taxing royalty payments would be unconstitutional if every other jurisdiction adopted it, violating an internal consistency test reaffirmed by a 2015 precedent, IBM told the U.S. Supreme Court in asking it to review and overturn New York's high court ruling that allowed the tax regime.
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September 25, 2024
Boosting Indirect Tax Revenues Can Tackle Debt, OECD Says
A number of countries should look to eliminate distortive tax expenses as well as increase their revenue from certain taxes to help manage debt sustainability and make their economies more supportive of growth, the Organization for Economic Cooperation and Development said Wednesday.
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September 25, 2024
Expect More R&D Guidance Before Regs, IRS Atty Says
The Internal Revenue Service plans to release more guidance governing the tax treatment of research and development expenses before it formally issues proposed regulations that implement the 2017 federal tax law's changes to the incentive, an agency attorney said Wednesday.
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September 25, 2024
EU States Must Unify Divergent Biz Rules, Majority Says
The European Union must double down on unifying its divergent rules for businesses in a policy proposal next year because the bloc's main competitive advantage is its single market, almost three-quarters of EU countries told the bloc's executive arm.
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September 25, 2024
Basis-Shifting Regs May Add Accounting Fixes, IRS Atty Says
The Internal Revenue Service may include in upcoming proposed regulations a solution for partnership basis-shifting for taxpayers that want to adjust accounting methods so prior transactions can be compliant with economic substance laws, an agency attorney said Wednesday.
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September 25, 2024
Wyden Calls On 2025 Tax Bill To Include Partnership Reform
Lawmakers should consider next year how to revise partnership tax laws to better collect on large businesses' income without harming smaller entities as Congress debates over how to address expiring tax provisions, Senate Finance Committee Chairman Ron Wyden said Wednesday.
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September 25, 2024
Australia Floats Updates To Amended Tax Pro Conduct Code
After repeated pushback against changes to Australia's tax agent code of conduct, the country's Treasury proposed two further amendments Wednesday that aim to address complaints regarding corrections of false or misleading statements and disclosures of information to clients.
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September 25, 2024
Hong Kong, Turkey Reach Double-Tax Agreement
Hong Kong and Turkey agreed to a treaty to prevent double taxation, which would take effect after approval by both jurisdictions' legislatures, Hong Kong's Inland Revenue Department said.
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September 25, 2024
French Finance Minister Signals Higher Taxes On Rich
The new French government is considering raising taxes on the wealthy and businesses to help reduce the country's budget deficit amid concerns over debt, according to remarks by the new finance minister.
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September 25, 2024
Puerto Rico Seeking Input On Implementing Global Min. Tax
Puerto Rico's Department of the Treasury is looking for public comments regarding possible implementation of the Organization for Economic Cooperation and Development's 15% global corporate minimum tax on large multinational entities.
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September 25, 2024
HMRC Arrests 11 Suspected Of R&D Tax Fraud
HM Revenue & Customs arrested 11 people, including tax agents, at several locations on suspicion of defrauding research and development tax relief programs, officers said.
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September 24, 2024
Halliburton Tardy In Contesting $35M Deduction, US Says
A Halliburton Co. lawsuit claiming a deduction for a $35 million payoff to a foreign country must be dismissed because the company waited too long to start its action, the U.S. told a Texas federal court.
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September 24, 2024
Microsoft Fights Mich. Tax Treatment Of Cost Share Payments
Microsoft urged the Michigan Tax Tribunal to find that cost sharing agreement receipts from affiliates constituted licenses of intellectual property that should be included in its apportionment formula, arguing that the state's tax agency incorrectly followed federal transfer pricing rules in excluding the payments from its tax calculations.
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September 24, 2024
Digital Asset Rules Coming By Year's End, Treasury Atty Says
The U.S. Treasury Department and the Internal Revenue Service intend to release rules "later this year" on additional reporting requirements for brokers of digital assets such as cryptocurrency and nonfungible tokens, a senior Treasury attorney said Tuesday.
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September 24, 2024
Abbott Seeks $24M Refund Over Transfer Pricing Adjustments
Healthcare products giant Abbott Laboratories is owed $24.3 million for overpaid taxes after the IRS incorrectly adjusted its intragroup income and payments this year, the company told the U.S. Tax Court in a petition.
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September 24, 2024
IRS Wary Of Adding Complexity In Min. Tax Regs, Official Says
The IRS opted to use existing tax rules in proposed guidance to address risks that the U.S. corporate alternative minimum tax could count offshore income twice, an agency official said Tuesday, noting a more precise method would increase complexity.
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September 24, 2024
Australia Floats Denying Late, Wrong Tax Interest Deductions
Australia's government opened a consultation Tuesday on a measure that would deny tax deduction claims for interest charged on late payments of tax liabilities as well as for interest charged when incorrect self-assessments result in a shortfall of tax paid.
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September 24, 2024
Treasury To Allow 3 AMT Transition Methods, Official Says
Final rules on the new corporate alternative minimum tax are expected to adopt the proposed regulations' three ways for companies to transition to the regime, and the U.S. Treasury Department is open to other ways as well, a department official said Tuesday.
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September 24, 2024
Exxon Claims It Beat Weak Defense In $1.8B Tax Trial
Exxon Mobil urged a Texas federal judge to find that it defeated what it called a scattered defense by the U.S. government during a five-day bench trial in April when the company argued for a $1.8 billion tax refund on its natural gas deal with Qatar, according to newly released filings.
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September 24, 2024
Azerbaijan Ratifies OECD Tax Treaty Standards
Azerbaijan ratified the Organization for Economic Cooperation and Developement's multilateral convention on base erosion and profit shifting Tuesday, which updates bilateral tax treaties of its signatories with agreed-upon standards, the OECD said.
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September 24, 2024
HMRC Set To Launch Consultation On VAT E-Invoicing
HM Revenue & Customs will hold a consultation on e-invoicing for value-added tax "soon," the British Treasury confirmed following a speech by the chancellor.
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September 24, 2024
Miller & Chevalier Adds Federal Tax Expert From White & Case
Miller & Chevalier Chtd. announced that it added a former partner at White & Case LLP to its tax controversy and litigation practice.
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September 23, 2024
Clean Energy Safe Harbor Applies To Direct Pay, Official Says
The safe harbor for the bonus clean energy tax credits' domestic content rules applies to all applicable project owners, including tax-exempt entities that are eligible to get a direct cash payment of the credits, a U.S. Treasury Department attorney said Monday.
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September 23, 2024
The Tax Angle: Corporate Inversions, SALT Cap
From a look at criticisms that the 2017 federal tax law failed to stop corporations from moving overseas to GOP efforts to navigate the SALT cap ahead of the November elections, here's a peek into a reporter's notebook on a few of the week's developing tax stories.
Expert Analysis
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What Recent Study Shows About AI's Promise For Legal Tasks
Amid both skepticism and excitement about the promise of generative artificial intelligence in legal contexts, the first randomized controlled trial studying its impact on basic lawyering tasks shows mixed but promising results, and underscores the need for attorneys to proactively engage with AI, says Daniel Schwarcz at University of Minnesota Law School.
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How FinCEN Proposal Expands RE Transaction Obligations
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.
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Litigation Inspiration: A Source Of Untapped Fulfillment
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.
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Unpacking FinCEN's Proposed Real Estate Transaction Rule
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.
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Think Like A Lawyer: Forget Everything You Know About IRAC
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.
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How New EU Tax And Transfer Pricing Rules May Affect M&A
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.
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How Firms Can Ensure Associate Gender Parity Lasts
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.
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7 Common Myths About Lateral Partner Moves
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.
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6 Pointers For Attys To Build Trust, Credibility On Social Media
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.
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US-Chile Tax Treaty May Encourage Cross-Border Investment
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.
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A Post-Mortem Analysis Of Stroock's Demise
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.
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SG's Office Is Case Study To Help Close Legal Gender Gap
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.
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Reimagining Law Firm Culture To Break The Cycle Of Burnout
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.