International
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October 09, 2024
UK Gov't Greenlights Film Industry Tax Credit
U.K. film companies will be able to gain over 50% tax relief for their films' costs from a tax credit approved Wednesday by the Labour government.
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October 09, 2024
3M Tax Ruling Must Fall Post-Chevron, Chamber Tells 8th Circ.
The U.S. Supreme Court's ending of the Chevron doctrine calls for overturning a U.S. Tax Court ruling that let the IRS allocate $24 million of income to multinational conglomerate 3M from a Brazilian affiliate, the U.S. Chamber of Commerce told the Eighth Circuit on Wednesday.
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October 09, 2024
Starmer Refuses To Rule Out Payroll Tax Hike
Prime Minister Keir Starmer didn't rule out raising employers' National Insurance contributions, a payroll tax used to fund healthcare and state pensions, during Wednesday's question time.
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October 09, 2024
Election Uncertainty Hampers Companies' Tax Planning
With the November election approaching, businesses are bracing for the potential impact of two very different sets of tax policies, with the resulting uncertainty making long-term tax planning increasingly difficult.
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October 09, 2024
Australia Seeking Large Cos.'s Tax Execs For Advisory Board
The Australian Taxation Office is looking for executives in charge of taxes for the country's largest businesses to join an advisory group focused on improving the Australian taxation systems, the ATO said Wednesday.
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October 09, 2024
Final Treasury Rules Shut Off Inclusion For Repatriated IP
The U.S. Treasury Department adopted final rules Wednesday that shut off an annual income inclusion associated with intangibles for companies in certain situations that have transferred intellectual property back to the U.S. from overseas.
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October 09, 2024
Gov't Warned Over National Insurance Levy On Pensions
About half of U.K. employers would scale back the amount they pay into staff pensions to regulatory minimums if a new tax was applied to contributions, according to a survey by a trade group published Wednesday.
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October 08, 2024
Germany May Offer Tax Break For 'E-Fuel' Cars, Ministry Says
The German government will consider a motor vehicle tax exemption for cars running only on fuels manufactured with renewable energy, known as e-fuels-only vehicles, the German Ministry of Finance announced Tuesday.
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October 08, 2024
China Pushes Back On Turkish EV Tariffs, Targets EU Brandy
China said Tuesday that it is appealing to the World Trade Organization to halt Turkish tariffs on electric and hybrid vehicles made in the country, and it announced a temporary anti-dumping measure on European Union brandy that follows the bloc's own EV tariffs.
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October 08, 2024
Tire Seller Counts As Importer, Owes $2M Tax, 5th Circ. Says
A Houston truck sales company owes nearly $2 million in excise taxes because it qualifies as the importer of tires that it bought from a Chinese manufacturer, the Fifth Circuit ruled Tuesday in overturning the decision of a Texas federal judge.
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October 08, 2024
Loss Rule Carveouts Raise Challenges In Pillar 2, Official Says
An IRS official flagged administrability concerns Tuesday with potential safe harbors that would, in some cases, carve out an international minimum tax agreement from interacting with long-standing domestic rules aimed at preventing companies from using the same economic loss twice.
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October 08, 2024
Australia Makes Additional Changes To Tax Pro Conduct Code
After industry pushback, delays and further tweaks, Australia's minister for financial services signed into law Tuesday further amendments to the nation's tax professional code of conduct as part of the country's reaction to the PwC document leak scandal.
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October 08, 2024
Eversheds Recruits Tax Disputes Partner From RPC
Eversheds Sutherland announced it has added a regulatory and tax disputes partner to its London office from Reynolds Porter Chamberlain LLP.
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October 08, 2024
UK Gov't Should Impose Exit Tax, Economists Say
The U.K. should follow the example of Australia and Canada and enact a tax on business owners leaving the country, according to a report published Tuesday by a research group.
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October 08, 2024
EU Removes Antigua And Barbuda From Tax Blacklist
The Council of the European Union removed Antigua and Barbuda from its blacklist of noncooperation jurisdictions on global tax standards, the EU's Economic and Financial Affairs Council announced Tuesday.
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October 08, 2024
Gov't Urged To Commit To Pension Tax 'Lock' In Budget
The government must commit to a long-term pact on pension tax policy, experts said, warning that prolonged uncertainty is damaging consumer confidence.
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October 07, 2024
Justices Won't Hear Man's FBAR Constitutionality Challenge
The U.S. Supreme Court let stand Monday a Seventh Circuit decision dismissing a man's challenge to the constitutionality of the Bank Secrecy Act's requirement to report his foreign bank accounts, effectively ending the man's claim that the filings were an invasion of privacy.
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October 07, 2024
Jury Finds Professor Hid Foreign Bank Accounts
An 86-year-old former college professor faces more than $500,000 plus interest in penalties after a jury found that he had deliberately failed to report his foreign bank accounts in Switzerland and Turkey, according to documents filed in a California federal court.
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October 07, 2024
Man Who Faced Espionage Case Gets Probation Over Taxes
A Chinese engineer initially accused of illegally exporting documents on military aircraft to China was given probation and fined for failing to report about $1.4 million in business income by a Texas federal court after the government dropped its export charges.
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October 07, 2024
Singapore Seeks Comments On Min. Tax Safe Harbor Rules
Singapore is looking for feedback on proposed safe harbor and transition rules that would complement its coming implementation of the OECD's Pillar Two global minimum tax on large multinational corporations, its revenue authority said.
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October 07, 2024
Norway's Gov't Looking To Close Exit Tax Loophole
Norway's government said Monday that it is looking to close a loophole by adjusting its exit tax rules, though the tightening on when the tax must be paid would be paired with a 500% increase of the threshold for when the tax becomes applicable.
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October 07, 2024
Corp. Tactics May Call For Rethinking Tax Breaks, Paper Says
Countries may want to look at scaling back corporate tax breaks to address tax planning opportunities taken advantage of by businesses over the past 20 years while those tax breaks have proliferated, according to a working paper published Monday by the Organization for Economic Cooperation and Development.
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October 07, 2024
India Seeking Feedback On Income Tax Regime
India's government said Monday it is undergoing what it called a comprehensive review of its income tax regime in hopes of reducing litigation and increasing taxpayer certainty.
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October 07, 2024
TCJA Extension, Biz Tax Cut To Reward Top 5%, Report Says
Former President Donald Trump's planned extension of the 2017 tax cuts and lowering of corporate rates contribute most among his platform to lowering taxes for the wealthiest 5% and hiking them for everyone else, the left-leaning Institute on Taxation and Economic Policy said Monday in a report.
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October 05, 2024
Biz Owners Saved £1.3B On Inheritance Tax, Report Says
Business owners have saved their families an estimated £1.3 billion ($1.7 billion) last year by claiming business property relief on inheritance tax, according to law firm TWM Solicitors.
Expert Analysis
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Rock Climbing Makes Me A Better Lawyer
Rock climbing requires problem-solving, focus, risk management and resilience, skills that are also invaluable assets in my role as a finance lawyer, says Mei Zhang at Haynes and Boone.
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Contract Disputes Recap: Preserving Payment Rights
Stephanie Magnell and Zachary Jacobson at Seyfarth examine three recent decisions that together illustrate the importance of keeping accurate records and adhering to contractual procedures to avoid inadvertently waiving contractual rights to cost reimbursements or nonroutine payments.
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Think Like A Lawyer: Dance The Legal Standard Two-Step
From rookie brief writers to Chief Justice John Roberts, lawyers should master the legal standard two-step — framing the governing standard at the outset, and clarifying why they meet that standard — which has benefits for both the drafter and reader, says Luke Andrews at Poole Huffman.
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Lead Like 'Ted Lasso' By Embracing Cognitive Diversity
The Apple TV+ series “Ted Lasso” aptly illustrates how embracing cognitive diversity can be a winning strategy for teams, providing a useful lesson for law firms, which can benefit significantly from fresh, diverse perspectives and collaborative problem-solving, says Paul Manuele at PR Manuele Consulting.
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Now More Than Ever, Lawyers Must Exhibit Professionalism
As society becomes increasingly fractured and workplace incivility is on the rise, attorneys must champion professionalism and lead by example, demonstrating how lawyers can respectfully disagree without being disagreeable, says Edward Casmere at Norton Rose.
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Reading Between The Lines Of Justices' Moore Ruling
The U.S. Supreme Court's recent Moore v. U.S. decision, that the Internal Revenue Code Section 965 did not violate the 16th Amendment, was narrowly tailored to minimally disrupt existing tax regimes, but the justices' various opinions leave the door open to future tax challenges and provide clues for what the battles may look like, say Caroline Ngo and Le Chen at McDermott.
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A Midyear Forecast: Tailwinds Expected For Atty Hourly Rates
Hourly rates for partners, associates and support staff continued to rise in the first half of this year, and this growth shows no signs of slowing for the rest of 2024 and into next year, driven in part by the return of mergers and acquisitions and the widespread adoption of artificial intelligence, says Chuck Chandler at Valeo Partners.
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States Should Loosen Law Firm Ownership Restrictions
Despite growing buzz, normalized nonlawyer ownership of law firms is a distant prospect, so the legal community should focus first on liberalizing state restrictions on attorney and firm purchases of practices, which would bolster succession planning and improve access to justice, says Michael Di Gennaro at The Law Practice Exchange.
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After Chevron: Uniform Tax Law Interpretation Not Guaranteed
The loss of Chevron deference will significantly alter the relationship between the IRS, courts and Congress when it comes to tax law, potentially precipitating more transparent rulemaking, but also provoking greater uncertainty due to variability in judicial interpretation, say Michelle Levin and Carneil Wilson at Dentons.
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Texas Ethics Opinion Flags Hazards Of Unauthorized Practice
The Texas Professional Ethics Committee's recently issued proposed opinion finding that in-house counsel providing legal services to the company's clients constitutes the unauthorized practice of law is a valuable clarification given that a UPL violation — a misdemeanor in most states — carries high stakes, say Hilary Gerzhoy and Julienne Pasichow at HWG.
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How To Clean Up Your Generative AI-Produced Legal Drafts
As law firms increasingly rely on generative artificial intelligence tools to produce legal text, attorneys should be on guard for the overuse of cohesive devices in initial drafts, and consider a few editing pointers to clean up AI’s repetitive and choppy outputs, says Ivy Grey at WordRake.
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Industry Self-Regulation Will Shine Post-Chevron
The U.S. Supreme Court's Loper decision will shape the contours of industry self-regulation in the years to come, providing opportunities for this often-misunderstood practice, says Eric Reicin at BBB National Programs.
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3 Ways Agencies Will Keep Making Law After Chevron
The U.S. Supreme Court clearly thinks it has done something big in overturning the Chevron precedent that had given deference to agencies' statutory interpretations, but regulated parties have to consider how agencies retain significant power to shape the law and its meaning, say attorneys at K&L Gates.