International
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October 29, 2024
Rimon Adds International Tax Expert In Philadelphia
Rimon PC has added an expert in international tax and trusts and estates who joined the firm's Philadelphia office after working for his own practice.
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October 29, 2024
Croatia, Australia Reach Double Tax Treaty Agreement
Croatia and Australia have agreed on a treaty to avoid double taxation that will take effect when passed by the respective legislatures, the Croatian Ministry of Finance said.
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October 29, 2024
Switzerland Amends Double Tax Treaty With Kuwait
Switzerland said Tuesday it has ratified changes to its double taxation treaty with Kuwait that are due to take effect early next year.
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October 29, 2024
US, Taiwan To Begin Talks On Double-Tax Agreement
The U.S. and Taiwan announced Tuesday that they will begin a first round of negotiations to craft a double-tax avoidance agreement that would provide certain treaty-like benefits.
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October 28, 2024
Russia Says High Court Case May Help Nix $5B Award Suit
Russia has told a D.C. federal court that a case recently accepted for review by the U.S. Supreme Court may provide it a path to argue that the court lacks jurisdiction to decide a case brought against the country by a Yukos Oil Co. unit.
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October 28, 2024
Latin America, Caribbean Must Up Tobacco Taxes, OECD Says
Latin American and Caribbean countries must increase their tobacco excise tax levels, among other changes, to reduce the overall affordability of tobacco products to drive people to quit using them, the Organization for Economic Cooperation and Development said Monday.
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October 28, 2024
UK Construction Co. Due £3.2M In R&D Credits, Refunds
A construction contractor is entitled to tax credits and refunds totaling over £3.2 million ($4.2 million) after the U.K.'s First-tier Tribunal ruled that its expenditures for research and development were not subsidized or contracted out by another party.
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October 28, 2024
European Commission Backs Simplified Minimum Tax Filing
Multinational corporations could file returns for the 15% global minimum tax with a single country in the European Union that they would share with the others only where necessary under a proposal approved Monday by the bloc's executive branch, according to officials.
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October 28, 2024
Chile Provides Guidance For Voluntary Disclosure Program
Chile's tax agency provided guidance Monday for taxpayers interested in voluntarily disclosing their previously undeclared foreign assets in order to take advantage of a temporarily available tax rate.
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October 28, 2024
IRS Extends Relief For FATCA Filings Without ID Numbers
Foreign financial institutions that report information on U.S. account holders to the Internal Revenue Service without including the taxpayer identification numbers associated with those accounts won't be flagged for noncompliance for the next three years, the agency said Monday.
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October 28, 2024
Wise Boss Hit With FCA Fine For Not Disclosing Tax Penalty
The finance regulator said on Monday that it has fined the chief executive of a money transfer company £350,000 ($454,500) for his failure to tell the watchdog he had been penalized by HM Revenues and Customs for not paying his taxes.
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October 28, 2024
US Expatriations Tick Up In 3rd Quarter, IRS Says
The number of people who expatriated from the U.S. rose during the third quarter of the year compared with the previous quarter, the Internal Revenue Service said Monday.
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October 25, 2024
Lebanon, Angola, Others Added To Financial Crime Watch List
An intergovernmental task force on financial crimes added Lebanon, Angola, Algeria and the Ivory Coast to a watch list of countries with weak protections against money laundering and financing for armed groups, the group said Friday.
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October 25, 2024
Argentina Formally Shutters, Replaces Tax Agency
Argentina's president formally dissolved the country's tax agency, the Federal Public Revenue Administration, and established a new agency, following through on an announcement two days earlier to end what he characterized as an oversize entity.
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October 25, 2024
Authorities Bust €113M VAT Fraud Ring Between Italy, China
A sting carried out Friday by the European Public Prosecutor's Office busted a crime ring involving the import of clothing and accessories from China to Italy that hid the goods' origins in order to evade €113 million ($122 million) in value-added taxes, the EPPO said.
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October 25, 2024
Taxation With Representation: Davis Polk, Skadden, Kirkland
In this week's Taxation With Representation, Atlantic Union Bankshares Corp. absorbs Sandy Spring Bancorp, Sophos and Secureworks merge, Wendel Group takes a stake in Monroe Capital LLC, and Acuity Brands Inc. buys QSC LLC.
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October 25, 2024
MVP: Wachtell's Tijana J. Dvornic
Wachtell Lipton Rosen & Katz's Tijana J. Dvornic led the firm's tax team in representing Lumen Technologies in the largest liability management transaction outside of bankruptcy protections, including addressing over $15 billion of existing debt, earning her a spot as one of the 2024 Law360 Tax MVPs.
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October 25, 2024
Germany's Expected Tax Take For 5 Years Drops €58B
Germany expects to raise €58.2 billion ($63 billion) less in revenue through 2028 than what was forecast in May, according to the country's finance minister, who said that the government allowing employers to pay tax-free bonuses caused uncertainties regarding income tax collections.
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October 24, 2024
IRS To End Automatic Foreign Gift Reporting Penalty
Internal Revenue Service Commissioner Danny Werfel told the UCLA Tax Controversy Conference audience on Thursday that the agency will no longer automatically assess penalties for the late reporting of large foreign gifts, with the announcement eliciting applause from the audience of several hundred tax attorneys and tax professionals.
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October 24, 2024
IRS Forming Transfer Pricing Team To Aid Real-Time Audits
The Internal Revenue Service is establishing a dedicated team to tackle transfer pricing issues that arise in real-time audits of companies participating in its compliance assurance process program, which should allow those issues to be handled more efficiently, an agency official said Thursday.
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October 24, 2024
Nigeria Frees Binance Exec Detained Over Money Laundering
Nigeria's government released a top executive at cryptocurrency exchange Binance whom the government had been holding liable for money laundering charges against the company, the U.S. government and the exchange's CEO said Thursday.
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October 24, 2024
Wyden's Pharma Probe Could Build Case For Int'l Tax Reforms
Senate Finance Committee Chairman Ron Wyden's investigation into the tax planning of major U.S. pharmaceutical companies could help fuel an effort to revamp U.S. international tax laws next year when Congress addresses expiring provisions of the Tax Cuts and Jobs Act.
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October 24, 2024
Politics Blocking Amount B Consensus, OECD Tells G20
Continued delays of the Organization for Economic Cooperation and Development's transfer pricing plan for certain baseline marketing and distribution activities known as Amount B of Pillar One are due to "primarily political" issues as opposed to technical problems, the organization told the Group of 20 on Thursday.
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October 24, 2024
Dutch Gov't Seeks Feedback On Crypto Reporting Rules
The Netherlands is looking for input on a proposal that would implement European Union rules requiring crypto-asset service providers to collect, check and share their users' data with the country's tax authority, the Dutch Ministry of Finance said Thursday.
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October 24, 2024
Aussie Board Seeks Input On Tax Pro Code Update Guidance
The Australian Tax Practitioners Board is looking for feedback on guidance related to six amendments to the country's tax professional code of conduct that were made in response to the PwC document leak scandal, the board said Thursday.
States Should Cede Profit-Shifting Fight To OECD, Atty Says
States should shy away from using mandatory worldwide combined reporting to address profit shifting and instead allow the Organization for Economic Cooperation and Development to police tax avoidance from multinational corporations, a business trade group attorney said Tuesday.
Labour Budget Expected To Target Taxes At Biz, Investors
The U.K. government is set to unveil its budget statement Wednesday after months of hinting at higher taxes, and experts say businesses and investors are bracing to bear the brunt of the possible tax changes, such as through increases to capital gains and payroll taxes.
German Drug Co. Due £21.5M VAT Refund, UK Tribunal Finds
A German pharmaceutical provider is entitled to a refund of almost £21.5 million ($27.9 million) for the value-added tax it paid on the rebated portion of products supplied to the U.K.'s National Health Service, the British First-tier Tribunal ruled.
Featured Stories
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Labour Budget Expected To Target Taxes At Biz, Investors
The U.K. government is set to unveil its budget statement Wednesday after months of hinting at higher taxes, and experts say businesses and investors are bracing to bear the brunt of the possible tax changes, such as through increases to capital gains and payroll taxes.
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Wyden's Pharma Probe Could Build Case For Int'l Tax Reforms
Senate Finance Committee Chairman Ron Wyden's investigation into the tax planning of major U.S. pharmaceutical companies could help fuel an effort to revamp U.S. international tax laws next year when Congress addresses expiring provisions of the Tax Cuts and Jobs Act.
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New ABA Tax Chair-Elect Aims To Expand Leadership Paths
The new chair-elect of the American Bar Association Section of Taxation told Law360 that she wants to broaden the pathways to leadership for members, including those early in their careers, as part of the section's diversity, equity and inclusion initiatives. Here, Megan Brackney shares more about her background and goals for the section.
Expert Analysis
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Lawyers With Disabilities Are Seeking Equity, Not Pity
Attorneys living with disabilities face extra challenges — including the need for special accommodations, the fear of stigmatization and the risk of being tokenized — but if given equitable opportunities, they can still rise to the top of their field, says Kate Reder Sheikh, a former attorney and legal recruiter at Major Lindsey & Africa.
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Judicial Committee Best Venue For Litigation Funding Rules
The Advisory Committee on Civil Rules' recent decision to consider developing a rule for litigation funding disclosure is a welcome development, ensuring that the result will be the product of a thorough, inclusive and deliberative process that appropriately balances all interests, says Stewart Ackerly at Statera Capital.
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The Strategic Advantages Of Appointing A Law Firm CEO
The impact on law firms of the recent CrowdStrike outage underscores that the business of law is no longer merely about providing supplemental support for legal practice — and helps explain why some law firms are appointing dedicated, full-time CEOs to navigate the challenges of the modern legal landscape, says Jennifer Johnson at Calibrate Strategies.
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How Cos. Can Build A Strong In-House Pro Bono Program
During this year’s pro bono celebration week, companies should consider some key pointers to grow and maintain a vibrant in-house program for attorneys to provide free legal services for the public good, says Mary Benton at Alston & Bird.
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Home Canning Makes Me A Better Lawyer
Making my own pickles and jams requires seeing a process through from start to finish, as does representing clients from the start of a dispute at the Patent Trial and Appeal Board through any appeals to the Federal Circuit, says attorney Kevin McNish.
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Use The Right Kind Of Feedback To Help Gen Z Attorneys
Generation Z associates bring unique perspectives and expectations to the workplace, so it’s imperative that supervising attorneys adapt their feedback approach in order to help young lawyers learn and grow — which is good for law firms, too, says Rachael Bosch at Fringe Professional Development.
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Congress Can And Must Enact A Supreme Court Ethics Code
As public confidence in the U.S. Supreme Court dips to historic lows following reports raising conflict of interest concerns, Congress must exercise its constitutional power to enact a mandatory and enforceable code of ethics for the high court, says Muhammad Faridi, president of the New York City Bar Association.
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What To Make Of Dueling Corporate Transparency Act Rulings
Although challenges to the Corporate Transparency Act abound — as highlighted by recent federal court decisions from Alabama and Oregon taking opposite positions on its constitutionality — the act is still law, so companies should comply with their filing requirements or face the potential consequences, say attorneys at Lowenstein Sandler.
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Pop Culture Docket: Justice Lebovits On Gilbert And Sullivan
Characters in the 19th century comic operas of Gilbert and Sullivan break the rules of good lawyering by shamelessly throwing responsible critical thought to the wind, providing hilarious lessons for lawyers and judges on how to avoid a surfeit of traps and tribulations, say acting New York Supreme Court Justice Gerald Lebovits and law student Tara Scown.
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State Of The States' AI Legal Ethics Landscape
Over the past year, several state bar associations, as well as the American Bar Association, have released guidance on the ethical use of artificial intelligence in legal practice, all of which share overarching themes and some nuanced differences, say Eric Pacifici and Kevin Henderson at SMB Law Group.
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8 Childhood Lessons That Can Help You Be A Better Attorney
A new school year is underway, marking a fitting time for attorneys to reflect on some fundamental life lessons from early childhood that offer a framework for problems that no legal textbook can solve, say Chris Gismondi and Chris Campbell at DLA Piper.
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This Election, We Need To Talk About Court Process
In recent decades, the U.S. Supreme Court has markedly transformed judicial processes — from summary judgment standards to notice pleadings — which has, in turn, affected individuals’ substantive rights, and we need to consider how the upcoming presidential election may continue this pattern, says Reuben Guttman at Guttman Buschner.
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Mental Health First Aid: A Brief Primer For Attorneys
Amid a growing body of research finding that attorneys face higher rates of mental illness than the general population, firms should consider setting up mental health first aid training programs to help lawyers assess mental health challenges in their colleagues and intervene with compassion, say psychologists Shawn Healy and Tracey Meyers.