International
-
December 12, 2024
2nd Circ. Won't Rethink Dual Citizen's FBAR Penalties
The Second Circuit will not review its September decision finding that a dual U.S.-French citizen is liable for tax penalties for failing to file reports of foreign bank and financial accounts, the court said Thursday.
-
December 12, 2024
Swiss To End Credit Offsetting India's Tax Treaty Snub
The Swiss government will no longer offer a credit to taxpayers designed to offset India's rejection of Swiss claims to benefits offered in other Indian tax treaties because India's top court decided to uphold its government's position, according to a notice.
-
December 12, 2024
German Fund Managers Charged In €45M Cum-Ex Scheme
Two fund managers have been charged in Germany for "particularly serious" tax evasion over their alleged role in a €45 million ($47 million) cum-ex dividend tax fraud, prosecutors confirmed Thursday.
-
December 12, 2024
IRS Hopes To Issue Amount B Pricing Guidance Within Weeks
Treasury is working to finish its guidance on the simplified transfer pricing approach to baseline marketing and distribution known as Amount B by the end of the year, a U.S. official said Thursday.
-
December 12, 2024
Treasury Seeks To Pause Anti-Laundering Law Injunction
The U.S. Treasury Department asked a Texas federal judge to pause his nationwide preliminary injunction of the Corporate Transparency Act pending an appeal of his recent decision that found Congress likely overstepped its constitutional authority when it wrote the anti-money laundering law.
-
December 12, 2024
Less Than Half Of Latin America Sees Taxes As Contributions
Only 47% of surveyed Latin American taxpayers consider their taxes as a contribution to the overall good of society as opposed to a cost they are forced to pay, the Organization for Economic Cooperation and Development said Thursday, saying the figure was below the global average.
-
December 12, 2024
Gibraltar Considering Global Minimum Tax Bill
Gibraltar's Parliament is considering the implementation of two parts of the Organization for Economic Cooperation and Development's 15% global corporate minimum income tax on large multinational entities making over €750 million ($786 million) annually.
-
December 12, 2024
Mexico To Join Int'l Pricing Program In 2025, Official Says
Mexico plans in 2025 to join the International Compliance Assurance Program, a multilateral effort to resolve transfer pricing issues, an official from that country's tax authority said Thursday.
-
December 12, 2024
Trader Sentenced To 12 Years For Cum-Ex Fraud In Denmark
A Danish court sentenced a British hedge fund trader to 12 years in prison on Thursday after finding him guilty of defrauding the country's tax authority by masterminding a nine billion kroner ($1.3 billion) cum-ex fraud scheme.
-
December 11, 2024
More Facts Needed In RJ Reynolds Tax Row, Mich. Court Says
More facts are needed on whether part of a $4.9 billion sale of trademarks by R.J. Reynolds to a Japanese company should be taxable in Michigan, a state court said Wednesday, declining to rule immediately.
-
December 11, 2024
Exxon Tax Ruling Doesn't Help Liberty Global, 10th Circ. Told
Liberty Global cannot use a recent ruling that allowed Exxon Mobil a tax deduction for interest payments to claim a deduction for dividends that arose from its intragroup shuffling of a Belgian affiliate, the U.S. government told the Tenth Circuit on Wednesday.
-
December 11, 2024
Irish Ruling Cuts Shareholder's Capital Gains Tax By €2.2M
A shareholder who gave all his shares in a company to several entities will save €2.2 million ($2.3 million), as Ireland's Tax Appeals Commission said Wednesday that the disposal happened in multiple transactions, qualifying for a discounted capital gains tax rate.
-
December 11, 2024
Estonia Passes 2% Tax To Fund Russia-Ukraine War Spending
Estonia's Parliament passed a temporary 2% tax Wednesday, earmarked to cover increased defense spending for the Russia-Ukraine war, choosing to go a different route to raise funds than neighboring Lithuania and Latvia.
-
December 11, 2024
Adidas Says European Offices Raided In EU Tax Investigation
Authorities are searching Adidas AG's offices in Germany and Austria for evidence of tax evasion following a five-year investigation by customs authorities in the European Union, the company told Law360 on Wednesday.
-
December 11, 2024
Netherlands Gov't Reports $5.3B Drop In Tax Avoidance
The Dutch government said Wednesday that it has seen tax avoidance drop by €5 billion ($5.3 billion) since the imposition of two European Union directives targeting low-tax corporate structures and practices.
-
December 10, 2024
FinCEN Says CTA Still Constitutional In Post-Injunction Alert
The Financial Crimes Enforcement Network has alerted companies that they do not currently need to file so-called beneficial ownership information with the agency after a federal judge's nationwide preliminary injunction blocking the Corporate Transparency Act, though the bureau maintained that the law calling for such information is constitutional.
-
December 10, 2024
Morgan Lewis Gets DLA Piper Tax Pro With DOJ Experience
Morgan Lewis & Bockius LLP announced that it has added to its Boston office a tax attorney from DLA Piper who served as an appellate attorney at the U.S. Department of Justice, Tax Division.
-
December 10, 2024
FBAR Default Against Widow Should Be Vacated, Judge Says
A New York federal magistrate judge recommended vacating a default judgment against a widow, which would give her a second chance to defend her dead husband's estate against U.S. government claims that it owes $275,000 for his failure to report his account at an Indian bank.
-
December 10, 2024
African Tax Revenue Ratio Up, Still Well Behind OECD Average
While the average ratio of total tax revenue to gross domestic product in 36 surveyed African countries rose in 2022, it still sits at just 16%, less than half of the 33.9% average for Organization for Economic Cooperation and Development countries, the OECD said Tuesday.
-
December 10, 2024
Exxon's Tax Win Sets Path For Liberty Global, 10th Circ. Told
A ruling allowing Exxon Mobil a U.S. tax deduction for interest expenses in its natural gas deal with Qatar confirms that Liberty Global is entitled to a deduction related to its sale of a Belgian affiliate, an attorney for the telecommunications company told the Tenth Circuit.
-
December 10, 2024
EU Reaches Deal On Digital VAT Exemption Certificate
The European Union reached an agreement Tuesday to replace the current paper version of certificates for value-added tax exemptions with a digital version, though the form itself will still need to be developed.
-
December 10, 2024
EU To Introduce Digital Certificate For Withholding Tax Relief
The Council of the European Union said Tuesday that it has agreed on new withholding rules that grant easy access to tax relief for cross-border investors through a common digital tax residence certificate.
-
December 10, 2024
HMRC Staff Vote To Strike Over Sacking Of 3 Colleagues
More than 200 staff members at an HM Revenue and Customs office have voted to strike for up to eight weeks in protest over the firing of three colleagues, allegedly for taking part in other industrial action.
-
December 10, 2024
Treasury Finalizes Simplified Foreign Currency Rules
The U.S. Treasury Department finalized regulations Tuesday that aim to simplify aspects of how corporations determine taxable income or loss with respect to certain affiliates that conduct business in a foreign currency.
-
December 10, 2024
Jockey Frankie Dettori Named In HMRC Tax Avoidance Battle
Italian jockey Frankie Dettori has been named as the individual who attempted to maintain his anonymity to keep private his legal battle with HM Revenue and Customs over a tax avoidance scheme, according to a London court judgment.
Expert Analysis
-
How Methods Are Evolving In Textualist Interpretations
Textualists at the U.S. Supreme Court are increasingly considering new methods such as corpus linguistics and surveys to evaluate what a statute's text communicates to an ordinary reader, while lower courts even mull large language models like ChatGPT as supplements, says Kevin Tobia at Georgetown Law.
-
Why Attorneys Should Consider Community Leadership Roles
Volunteering and nonprofit board service are complementary to, but distinct from, traditional pro bono work, and taking on these community leadership roles can produce dividends for lawyers, their firms and the nonprofit causes they support, says Katie Beacham at Kilpatrick.
-
Firms Must Offer A Trifecta Of Services In Post-Chevron World
After the U.S. Supreme Court’s Loper Bright Enterprises v. Raimondo decision overturning Chevron deference, law firms will need to integrate litigation, lobbying and communications functions to keep up with the ramifications of the ruling and provide adequate counsel quickly, says Neil Hare at Dentons.
-
5 Tips To Succeed In A Master Of Laws Program And Beyond
As lawyers and recent law school graduates begin their Master of Laws coursework across the country, they should keep a few pointers in mind to get the most out of their programs and kick-start successful careers in their practice areas, says Kelley Miller at Reed Smith.
-
How Law Firms Can Avoid 'Collaboration Drag'
Law firm decision making can be stifled by “collaboration drag” — characterized by too many pointless meetings, too much peer feedback and too little dissent — but a few strategies can help stakeholders improve decision-making processes and build consensus, says Steve Groom at Miles Mediation.
-
Litigation Funding Disclosure Key To Open, Impartial Process
Blanket investor and funding agreement disclosures should be required in all civil cases where the investor has a financial interest in the outcome in order to address issues ranging from potential conflicts of interest to national security concerns, says Bob Goodlatte, former U.S. House Representative for Virginia.
-
What NFL Draft Picks Have In Common With Lateral Law Hires
Nearly half of law firm lateral hires leave within a few years — a failure rate that is strikingly similar to the performance of NFL quarterbacks drafted in the first round — in part because evaluators focus too heavily on quantifiable metrics and not enough on a prospect's character traits, says Howard Rosenberg at Baretz+Brunelle.
-
Replacing The Stigma Of Menopause With Law Firm Support
A large proportion of the workforce is forced to pull the brakes on their career aspirations because of the taboo surrounding menopause and a lack of consistent support, but law firms can initiate the cultural shift needed by formulating thoughtful workplace policies, says Barbara Hamilton-Bruce at Simmons & Simmons.
-
Planning Law Firm Content Calendars: What, When, Where
During the slower month of August, law firms should begin working on their 2025 content calendars, planning out a content creation and distribution framework that aligns with the firm’s objectives and maintains audience engagement throughout the year, says Jessica Kaplan at Legally Penned.
-
Law Firms Should Move From Reactive To Proactive Marketing
Most law firm marketing and business development teams operate in silos, leading to an ad hoc, reactive approach, but shifting to a culture of proactive planning — beginning with comprehensive campaigns — can help firms effectively execute their broader business strategy, says Paul Manuele at PR Manuele Consulting.
-
The Big Issues A BigLaw Associates' Union Could Address
A BigLaw associates’ union could address a number of issues that have the potential to meaningfully improve working conditions, diversity and attorney well-being — from restructured billable hour requirements to origination credit allocation, return-to-office mandates and more, says Tara Rhoades at The Sanity Plea.
-
It's Time For A BigLaw Associates' Union
As BigLaw faces a steady stream of criticism about its employment policies and practices, an associates union could effect real change — and it could start with law students organizing around opposition to recent recruiting trends, says Tara Rhoades at The Sanity Plea.
-
How Justices Upended The Administrative Procedure Act
In its recent Loper Bright, Corner Post and Jarkesy decisions, the U.S. Supreme Court fundamentally changed the Administrative Procedure Act in ways that undermine Congress and the executive branch, shift power to the judiciary, curtail public and business input, and create great uncertainty, say Alene Taber and Beth Hummer at Hanson Bridgett.