International

  • September 23, 2024

    Pension Experts Urge Tax Breaks For UK Investment Plan

    The government could best encourage investment in the economy from pension schemes by adopting tax incentives, a trade body said.

  • September 20, 2024

    8th Circ. To Hear Args In 3M's $24M Tax Case Next Month

    The Eighth Circuit said Friday that it will hear oral arguments next month in 3M's transfer pricing appeal, in which the multinational conglomerate is challenging the Internal Revenue Service's authority to reallocate to the company $24 million from a Brazilian affiliate.

  • September 20, 2024

    IRS Special Trial Attorney Joins Hochman Salkin In California

    When Hochman Salkin Toscher Perez PC's newest principal, Sebastian Voth, was studying at Emory University School of Law, a former chief counsel for the Internal Revenue Service told students that the IRS was a great place to start their careers. After 15 years as an IRS attorney, Voth found that the agency was also a great place to work, he told Law360 Pulse in an interview Friday.

  • September 20, 2024

    Australia Seeks Comments On Luxury Car Tax Green Changes

    Australia is looking for comments on plans to adjust the country's luxury car tax to update the definition of a fuel-efficient car and to make changes to the way the tax threshold is indexed, the country's Treasury Department said Friday.

  • September 20, 2024

    Hong Kong's Tax Revenue Drops For 2nd Straight Year

    Hong Kong's tax revenue dipped by HK$14 billion ($1.8 billion) to HK$342 billion in the 2023-24 tax year — the second straight year with a drop — largely because of decreases in stamp duty and profit tax collections, its tax authority said Friday.

  • September 20, 2024

    Taxation With Representation: Gibson Dunn, Holland & Knight

    In this week's Taxation With Representation, CACI International buys Azure Summit Technology, Hotel Engine lands a valuation led by Permira, and Knowles Corp. sells its microphone business to Syntiant Corp.

  • September 20, 2024

    UK Budget May Seek Gains From Inheritance Tax, Firms Say

    The U.K. government may try to squeeze more revenue out of the wealthy via inheritance tax, wealth management firms said Friday following the release of data showing the levy is generating higher returns for HM Treasury.

  • September 19, 2024

    Pillar 1's Safe Harbor Limits Split Of Taxing Rights, Study Says

    The redistribution of corporate taxing rights among countries that agreed to new profit reallocation rules known as Pillar One would be "seriously affected" by a proposed safe harbor, according to report from a think tank funded by the European Union.

  • September 19, 2024

    Death Doesn't Preclude FBAR Penalties, Judge Says

    The death of a U.S. citizen who failed to file reports of foreign bank and financial accounts doesn't stop the U.S. government from enforcing penalties against his estate, a New York federal judge ruled.

  • September 19, 2024

    Spain Tax Inspections Generated €16.7B In Revenue In 2023

    Spain's tax agency said Thursday that it increased the number of control actions it took against large companies and other groups by nearly 14% in 2023 as part of the agency's €16.7 billion ($18.6 billion) in revenue generated from control work last year.

  • September 19, 2024

    Sweden Aiming For Broad Tax Cuts In 2025 Budget

    Swedish taxpayers would see lower tax rates in many areas, such as on their labor and pensions, as part of a proposed 2025 budget that the government sent to the country's legislature for consideration Thursday.

  • September 19, 2024

    EU, China Fail To End EV Dispute But Talks Continue

    Negotiators from the European Union and China failed to resolve a dispute over EU antisubsidy tariffs on imported electric vehicles from China but promised Thursday to intensify efforts to find a mutually agreeable solution.

  • September 19, 2024

    Nine Countries Sign Treaty For OECD Min. Tax On Payments

    Indonesia, Turkey, Congo and six other countries signed a multilateral treaty aimed at implementing a 9% minimum tax on income sent from their jurisdictions to low-taxed entities within a corporate group, the OECD said Thursday.

  • September 19, 2024

    EU Top Court Rules UK's CFC Tax Breaks Not State Aid

    The European Court of Justice ruled Thursday that tax breaks the U.K. gave to certain companies under controlled foreign company regulations did not breach European Union state aid law.

  • September 19, 2024

    Apple Ruling Prompts EU Lawmakers To Call For Tax Justice

    Citing the recent European court judgment requiring Apple to pay €13 billion ($14.5 billion) in taxes to Ireland, European Union lawmakers demanded Thursday that the fight against tax evasion and for corporate tax harmonization be stepped up.

  • September 19, 2024

    EU Wrong To Block Berlusconi's Bank Stake, Top Court Rules

    Europe's highest court ruled Thursday that the European Central Bank was wrong to decide that a prior conviction for tax fraud prevented former Italian Prime Minister Silvio Berlusconi from holding a stake in a bank in the country.

  • September 18, 2024

    Tax Chiefs Eye Crypto Payment Cos., OTC Traders, IRS Says

    Tax investigators in the U.S., U.K., Canada, Australia and the Netherlands are preparing guidance on red flags for cryptocurrency payment providers and over-the-counter trading desks following a joint operation this week, a special agent with the Internal Revenue Service said Wednesday.

  • September 18, 2024

    Tax Court Wrongly Denied Premium Deduction, 5th Circ. Told

    A Texas couple asked the Fifth Circuit on Wednesday to reverse a U.S. Tax Court decision denying their bid to deduct more than $1 million in premiums paid to insurance companies they owned, arguing the Tax Court misclassified underlying insurance arrangements.

  • September 18, 2024

    Most Large Aussie Companies Paying Correct Tax Amounts

    The Australian Taxation Office has a high or medium level of assurance that 86% of the country's largest taxpayers paid the correct amount of income taxes in 2024, based on recent reviews.

  • September 18, 2024

    House GOP Vows Blowback Over OECD's Min. Tax Backstop

    House Republicans again warned the OECD that Congress will retaliate against countries that implement a backstop measure to the 15% global minimum tax, saying China will cheat the system and it will cost U.S. taxpayers about $120 billion.

  • September 18, 2024

    Estonia Implementing 2% Profit Tax To Fund Security

    Companies in Estonia will need to pay a 2% tax on their accounting profits starting in 2026 in order to boost investment in the country's defense measures, its Ministry of Finance said.

  • September 18, 2024

    Country-By-Country Reports In Place In Over 115 Jurisdictions

    More than 115 tax jurisdictions require large multinational entities to submit country-by country reports in line with the Organization for Economic Cooperation and Development standards as part of the group's fight against tax base erosion and profit shifting, the OECD reported.

  • September 18, 2024

    Colombia Should Lower 35% Corporate Tax Rate, OECD Says

    Colombia can reignite the since-slowed growth it experienced following the COVID-19 pandemic through a series of tax changes, in particular lowering its 35% corporate income tax as part of an overall rebalancing of the tax burden from corporate to personal income, according to the OECD.

  • September 18, 2024

    Latham Adds A&O Shearman Energy Group Co-Lead In DC

    Latham & Watkins LLP has hired the former co-head of Allen Overy Shearman Sterling's U.S. energy, natural resources and infrastructure group to its team of transactional tax partners based in Washington, D.C., the firm announced Monday.

  • September 18, 2024

    8th Circ. Considers Chevron's End In 3M's $24M Tax Case

    The Eighth Circuit signaled it would consider an argument by 3M that the U.S. Supreme Court's overturning of Chevron deference warranted a reversal in a transfer pricing case in which 3M is challenging the IRS' reallocation of $24 million from a Brazilian affiliate.

Expert Analysis

  • 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.

  • Employee Experience Strategy Can Boost Law Firm Success

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    Amid continuing business uncertainty, law firms should consider adopting a holistic employee experience strategy — prioritizing consistency, targeting signature moments and leveraging measurement tools — to maximize productivity and profitability, says Haley Revel at Calibrate Consulting.

  • 6 Practice Pointers For Pro Bono Immigration Practice

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    An attorney taking on their first pro bono immigration matter may find the law and procedures beguiling, but understanding key deadlines, the significance of individual immigration judges' rules and specialized aspects of the practice can help avoid common missteps, says Steven Malm at Haynes Boone.

  • Lessons From Country Singer's Personal Service Saga

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    Recent reports that country singer Luke Combs won a judgment against a Florida woman who didn’t receive notice of the counterfeit suit against her should serve as a reminder for attorneys on best practices for effectuating service by electronic means, say attorneys at Jenner & Block.

  • 7 E-Discovery Predictions For 2024 And Beyond

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    The legal and technical issues of e-discovery now affect virtually every lawsuit, and in the year to come, practitioners can expect practices and policies to evolve in a number of ways, from the expanded use of relevancy redactions to mandated information security provisions in protective orders, say attorneys at Littler.

  • 5 Litigation Funding Trends To Note In 2024

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    Over the next year and beyond, litigation funding will continue to evolve in ways that affect attorneys and the larger litigation landscape, from the growth of a secondary market for funded claims, to rising interest rates restricting the availability of capital, says Jeffery Lula at GLS Capital.

  • 4 Legal Ethics Considerations For The New Year

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    As attorneys and clients reset for a new year, now is a good time to take a step back and review some core ethical issues that attorneys should keep front of mind in 2024, including approaching generative artificial intelligence with caution and care, and avoiding pitfalls in outside counsel guidelines, say attorneys at HWG.

  • What The Law Firm Of The Future Will Look Like

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    As the legal landscape shifts, it’s become increasingly clear that the BigLaw business model must adapt in four key ways to remain viable, from fostering workplace flexibility to embracing technology, say Kevin Henderson and Eric Pacifici at SMB Law Group.

  • 4 PR Pointers When Your Case Is In The News

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    Media coverage of new lawsuits exploded last year, demonstrating why defense attorneys should devise a public relations plan that complements their legal strategy, incorporating several objectives to balance ethical obligations and advocacy, say Nathan Burchfiel at Pinkston and Ryan June at Castañeda + Heidelman.

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