International

  • September 30, 2024

    IRS Seeks Input On Draft Partnership Basis-Shifting Form

    The Internal Revenue Service asked for comments Monday on a draft form and instructions for partners to disclose all the property they receive from partnerships, part of upcoming regulations meant to target abusive tax avoidance that uses sophisticated partnership basis-shifting transactions.

  • September 30, 2024

    German Lawyer Charged Over €428M Cum-Ex Fraud

    A lawyer has been charged in Germany with several counts of "serious tax evasion" over his alleged role in a €428 million ($477 million) so-called cum-ex dividend tax fraud, a German court confirmed Monday.

  • September 30, 2024

    Feds Seek Prison In Tax Case Linked To 'China Initiative'

    Prosecutors have asked a Texas federal judge for an 18- to 24-month prison sentence for a Chinese-born engineer who pled guilty to tax crimes after being charged with export violations and fraud in a case the defense claims began as an espionage investigation under the U.S. Department of Justice's now-disbanded "China Initiative."

  • September 30, 2024

    IRS Appeals Office Tests Group Mailbox For Large Cos.

    The Internal Revenue Service's Independent Office of Appeals announced Monday that it will test out a program intended to help enhance secure messaging for large businesses with multiple representatives by allowing them to request a group mailbox to communicate with their assigned Appeals employee.

  • September 30, 2024

    Aussie 2023-24 Budget Delivered Surplus Despite Tax Dip

    Australia ended the 2023-24 fiscal year with an AU$15.8 billion ($11 billion) surplus, larger than what the government had projected and primarily due to spending cuts, not higher taxes, according to the country's annual report, published Monday.

  • September 27, 2024

    Ex-Citizens' Renunciation Fee Suit Shipped To Claims Court

    A D.C. federal judge ruled that a lawsuit brought by former U.S. citizens seeking a refund on their $2,350 citizenship renunciation fee belongs in the Court of Federal Claims.

  • September 27, 2024

    Constitution Permits Blocked Anti-Laundering Law, Panel Told

    The U.S. government urged the Eleventh Circuit on Friday to reinstate the Corporate Transparency Act passed in 2021, arguing that the anti-money laundering law is within Congress' powers to regulate economic activity and necessary to have businesses report beneficial ownership to combat crimes like tax evasion and terrorist financing.

  • September 27, 2024

    IRS Plans Transition Rules In Basis-Shifting Regs, Atty Says

    The IRS plans to include transition rules in forthcoming proposed regulations that aim to clamp down on abusive tax avoidance practices through complex partnership transactions known as basis shifting, an agency attorney said Friday.

  • September 27, 2024

    Corp. AMT Rules Could Wrap In Smaller Partnerships

    Recently proposed rules on the U.S. corporate alternative minimum tax create new concerns for partnerships of various sizes that could be forced to comply with complex reporting requirements unless the government introduces carveouts, tax observers said.

  • September 27, 2024

    Ireland Seeks Input On Business Interest Tax Regime

    Ireland has asked for comments on its business interest taxation and deduction regime, as well as whether the country should introduce a commercial business purposes test for deductions, its government said Friday.

  • September 27, 2024

    Taxation With Representation: Kirkland, Skadden, Cleary

    In this week's Taxation With Representation, Blackstone and Vista Equity Partners acquire Smartsheet Inc., Macquarie Asset Management takes a stake in D.E. Shaw Renewables Investment Group, and Apogee Enterprises Inc. buys UW Interco LLC from Heartwood Partners.

  • September 27, 2024

    US Trade Group Pushes OECD On Compliance Burden

    The Organization for Economic Cooperation and Development needs to do more work on the safe harbor provisions of its Pillar Two 15% global corporate minimum tax plan — including potentially making it permanent — among other compliance burden concerns, the National Foreign Trade Council said Friday.

  • September 27, 2024

    Gov't Could Target Pension Contributions In Tax Raid

    The U.K. government could introduce a new levy on employer pension contributions as a means of plugging a £22 billion ($29.5 billion) black hole in public finances, experts said Friday.

  • September 26, 2024

    Belgian Co. Can't Keep Using Ad Space Rent-Free, ECJ Says

    The European Court of Justice on Thursday upheld a 2019 European Commission ruling that a street furniture company's owed rent for Brussels bus shelter advertising space, agreeing with the commission that allowing the company to continue using the ad displays without paying rent or taxes constituted unlawful state aid.

  • September 26, 2024

    Tribunal Halts $52.8M German Tax Collection Against Oil Cos.

    German tax authorities shouldn't collect a windfall profits tax totaling at least €47.2 million ($52.8 million) from two oil refineries before the dispute has been litigated, a tribunal of the International Centre for Settlement of Investment Disputes said.

  • September 26, 2024

    Montreal Exchange Is A Qualified Exchange, IRS Says

    The Montreal Exchange is a qualified board or exchange for purposes of mark-to-market contracts under Internal Revenue Code Section 1256(g)(7)(C), the Internal Revenue Service said Thursday. 

  • September 26, 2024

    Amazon Reports Paying £932M In UK Taxes In 2023

    Amazon said Thursday that it paid a total of £932 million ($1.25 billion) in U.K. taxes last year, which the company said puts it among the 10 largest taxpayers in the country.

  • September 26, 2024

    Tariff Tax Base Too Small To Replace Income Tax, Report Says

    Higher tariffs can't replace income tax revenue, as former President Donald Trump has suggested, since U.S. imports total $3 trillion annually while incomes top $20 trillion, but they would lower incomes by raising prices for U.S. consumers, a think tank reported Thursday.

  • September 26, 2024

    Irish Dividend Exemption Too Restrictive, Big 4 Say

    The Big Four accounting firms raised concerns about wording in Ireland's planned tax exemption for foreign-sourced dividends, claiming in comments released Thursday that it would be overly restrictive to require dividends to come solely out of an offshore affiliate's profits.

  • September 26, 2024

    Harris' And Trump's Tax Plans Each Add To Deficit, Study Says

    The U.S. federal deficit would grow by at least $2 trillion over the next decade from the tax policy plans of both major parties' candidates, former President Donald Trump and Vice President Kamala Harris, researchers said Thursday.

  • September 26, 2024

    UK Cos. Claimed Nearly £1.5B In Patent Box Relief In 2022-23

    While there was a slight dip in the number of U.K. companies that elected to use the country's patent box tax regime in the 2022-23 tax year compared with the prior year, the estimated value of relief claimed jumped to nearly £1.47 billion ($1.97 billion) compared with around £1.33 billion, HM Revenue & Customs said Thursday.

  • September 26, 2024

    UK R&D Tax Credit Claims Down, But Total Relief Up £100M

    While there was an over 20% dip in research and development tax credit claims in the U.K. in the 2022-23 tax year, the total relief claimed rose to £7.5 billion ($10.1 billion), a £100 million increase, HM Revenue & Customs said Thursday.

  • September 26, 2024

    UK Corp. Tax Receipts Up 10% To £93.3B, HMRC Says

    The U.K. generated £93.3 billion ($125 billion) in corporate tax receipts in the 2023-24 tax year, a 10% increase over the prior year, HM Revenue & Customs said Thursday, pointing mainly to the increase in the country's corporation tax rate to 25% as the reason behind the bump.

  • September 26, 2024

    ECJ Backs Strong Protection For Lawyer-Client Discussions

    Confidentiality of lawyer-client communications has enhanced protection under European Union law, including in cross-border tax disclosures, the European Court of Justice ruled Thursday.

  • 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.

Expert Analysis

  • 4 Ways To Refresh Your Law Firm's Marketing Strategy

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    With many BigLaw firms relying on an increasingly obsolete marketing approach that prioritizes stiff professionalism over authentic connection, adopting a few key communications strategies to better connect with today's clients and prospects can make all the difference, say Eric Pacifici and Kevin Henderson at SMB Law.

  • This Earth Day, Consider How Your Firm Can Go Greener

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    As Earth Day approaches, law firms and attorneys should consider adopting more sustainable practices to reduce their carbon footprint — from minimizing single-use plastics to purchasing carbon offsets for air travel — which ultimately can also reduce costs for clients, say M’Lynn Phillips and Lisa Walters at IMS Legal Strategies.

  • Cum-Ex Prosecutions Storm Shows No Sign Of Abating

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    The ongoing trial of Sanjay Shah in Denmark is a clear indicator that efforts remain focused on holding to account the alleged architects and beneficiaries of cum-ex trading, and with these prosecutions making their way across Europe, it is a more turbulent time now than ever, says Niall Hearty at Rahman Ravelli.

  • Practicing Law With Parkinson's Disease

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    This Parkinson’s Awareness Month, Adam Siegler at Greenberg Traurig discusses his experience working as a lawyer with Parkinson’s disease, sharing both lessons on how to cope with a diagnosis and advice for supporting colleagues who live with the disease.

  • Why Supreme Court Should Allow Repatriation Tax To Stand

    If the U.S. Supreme Court doesn't reject the taxpayers' misguided claims in Moore v. U.S. that the mandatory repatriation tax is unconstitutional, it could wreak havoc on our system of taxation and result in a catastrophic loss of revenue for the government, say Christina Mason and Theresa Balducci at Herrick Feinstein.

  • For Lawyers, Pessimism Should Be A Job Skill, Not A Life Skill

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    A pessimistic mindset allows attorneys to be effective advocates for their clients, but it can come with serious costs for their personal well-being, so it’s crucial to exercise strategies that produce flexible optimism and connect lawyers with their core values, says Krista Larson at Stinson.

  • Requiring Leave To File Amicus Briefs Is A Bad Idea

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    A proposal to amend the Federal Rules of Appellate Procedure that would require parties to get court permission before filing federal amicus briefs would eliminate the long-standing practice of consent filing and thereby make the process less open and democratic, says Lawrence Ebner at the Atlantic Legal Foundation and DRI Center.

  • 4 Ways To Motivate Junior Attorneys To Bring Their Best

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    As Gen Z and younger millennial attorneys increasingly express dissatisfaction with their work and head for the exits, the lawyers who manage them must understand and attend to their needs and priorities to boost engagement and increase retention, says Stacey Schwartz at Katten.

  • Former Minn. Chief Justice Instructs On Writing Better Briefs

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    Former Minnesota Supreme Court Chief Justice Lorie Gildea, now at Greenberg Traurig, offers strategies on writing more effective appellate briefs from her time on the bench.

  • Stay Interviews Are Key To Retaining Legal Talent

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    Even as the economy shifts and layoffs continue, law firms still want to retain their top attorneys, and so-called stay interviews — informal conversations with employees to identify potential issues before they lead to turnover — can be a crucial tool for improving retention and morale, say Tina Cohen Nicol and Kate Reder Sheikh at Major Lindsey.

  • Neb. Justices Should Weigh IRC Terms In Dividend Tax Case

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    Nebraska’s highest court, which will hear oral arguments in Precision CastParts v. Department of Revenue on April 1, should recognize that the Internal Revenue Code provides key clues to defining “dividends received or deemed to be received,” and therefore limits Nebraska’s tax on foreign-sourced corporate income, says Joseph Schmidt at Ryan.

  • Judicial Independence Is Imperative This Election Year

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    As the next election nears, the judges involved in the upcoming trials against former President Donald Trump increasingly face political pressures and threats of violence — revealing the urgent need to safeguard judicial independence and uphold the rule of law, says Benes Aldana at the National Judicial College.

  • Spartan Arbitration Tactics Against Well-Funded Opponents

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    Like the ancient Spartans who held off a numerically superior Persian army at the Battle of Thermopylae, trial attorneys and clients faced with arbitration against an opponent with a bigger war chest can take a strategic approach to create a pass to victory, say Kostas Katsiris and Benjamin Argyle at Venable.

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