International
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December 19, 2024
5th Circ. Urged To Deny Tax Break For Doc's Captive Insurance
A physician who owns a network of urgent care clinics was correctly denied tax deductions along with his wife for over $1 million in premiums they paid to insurance companies they owned, the government told the Fifth Circuit, saying the captive arrangements didn't qualify as insurance for tax purposes.
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December 19, 2024
UK Adds Pillar 2 Backstop To Finance Bill
The U.K. government introduced amendments to its latest finance bill Thursday that would update its Pillar Two global minimum tax system and add the backstop to the regime known as the undertaxed profits rule.
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December 18, 2024
Skat Fights To Bring New Cum-Ex Fraud Case Against Broker
The Danish tax authority argued at a London appeals court on Wednesday that it should not be blocked from bringing fresh tax fraud claims against an English brokerage, contending that the claims cover new material not already decided in earlier proceedings.
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December 18, 2024
Morrison Foerster Cites Tariffs As Key M&A Variable For 2025
International law firm Morrison Foerster LLP is among those citing President-elect Donald Trump's tariff plans as a key wild card that could affect mergers and acquisitions deal flow in 2025, a Wednesday report from the firm shows.
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December 18, 2024
Dutch Bank Exec Gave IRS Good Tax Tip, DC Circ. Judge Says
D.C. Circuit judges grappled Wednesday with the denial of a whistleblower award to a late Dutch bank executive who tipped off the IRS to tax reporting schemes, with one judge saying during oral arguments that the executive appeared to have handed the agency "gift-wrapped" evidence of wrongdoing.
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December 18, 2024
EU Court Rejects Latest Challenge To Portugal's Tax Clawback
A European court rejected a Brazilian-based company's challenge Wednesday to a European Commission ruling that Portugal must claw back tax breaks provided to companies with no local economic activity because that ran counter to commission-approved policies.
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December 18, 2024
Upcoming IRS Regs Will Have Optional Amount B Pricing
The Internal Revenue Service announced Wednesday that is planning to propose regulations that will give corporations the option to price certain cross-border transactions using a simplified and streamlined approach under a new international tax framework known as Amount B.
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December 18, 2024
EU VAT Gap Rises To €89B Despite Progress, Report Says
Most European countries have made progress toward tackling the compliance gap for value-added tax, but that gap rose to €89.3 billion ($93.6 billion) in 2022 from just under €76 billion in 2021, the European Commission reported Wednesday.
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December 18, 2024
Police Can Seize £2.6M From Influencers Over Unpaid Tax
Police can seize £2.6 million ($3.3 million) in unpaid taxes from internet influencer Andrew Tate and his brother Tristan Tate over millions they made from online businesses, a London court ruled Wednesday.
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December 17, 2024
Texas Judge Won't Pause Block Of Corp. Transparency Law
A Texas federal judge on Tuesday denied the government's request to stay his nationwide block of a corporate transparency law while an appeal is pending, saying his view that Congress lacks the constitutional authority to enact the legislation is likely to prevail at the Fifth Circuit.
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December 17, 2024
Yukos Capital Opposes Stay In $5B Russia Award Suit
The financing arm of Yukos Oil Co. urged a D.C. federal court on Monday not to pause its lawsuit looking to enforce a $5 billion arbitral award against Russia while litigation involving similar issues plays out, saying the Kremlin is needlessly dragging its feet.
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December 17, 2024
Cyprus, Facing EU Pressure, Passes Minimum Tax
Cyprus' unicameral legislature passed a bill implementing the Organization for Economic Cooperation and Development's global minimum tax on large multinational entities, according to a local news report, ending its holdout as the final country facing pressure from the European Union to do so.
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December 17, 2024
NY Urges Justices To Pass On IBM, Disney Royalty Tax Fight
The U.S. Supreme Court should decline to hear appeals by IBM and Disney that claim New York state's tax treatment of royalties received from foreign affiliates resulted in unconstitutional discrimination against interstate commerce, the state told the court Tuesday.
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December 17, 2024
Canadian Cabinet Official Takes Over Finance Minster Role
Canada's intergovernmental affairs minister is now also the country's finance minister following the sudden resignation of the previous official to hold the post, who cited conflicting views with Prime Minister Justin Trudeau about how to respond to U.S. tariff threats.
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December 17, 2024
Trinity International Adds Tax Expert To Paris Office
Trinity International LLP announced the addition of an experienced tax attorney from Dentons to serve as a partner in its Paris office.
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December 17, 2024
Japan Signs Double-Tax Treaty With Turkmenistan
Japan and Turkmenistan have reached an agreement on a double-tax treaty to replace the convention Japan had with the Soviet Union, Japan's Ministry of Finance said Tuesday.
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December 17, 2024
Ireland Could Lose €15B Due To Trump, Central Bank Warns
The Irish government could lose up to €15 billion ($15.7 billion) of this year's corporate tax surplus if the incoming U.S. administration changes policy, the Central Bank of Ireland warned Tuesday.
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December 16, 2024
Mich. Judge Troubled By Scope Of Feds' CTA Data Collection
A federal judge in Michigan said new disclosure requirements for small businesses seem burdensome and intrusive during a Monday hearing focused on the privacy implications of the currently blocked anti-money laundering law.
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December 16, 2024
Aussie R&D Scheme Promoters Hit With $8.7M In Penalties
The Federal Court of Australia ordered an Australian, his tax agent and his companies to pay a total of AU$13.6 million ($8.7 million) in penalties for promoting illegal research and development tax fraud schemes, the Australian Taxation Office announced.
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December 16, 2024
Canadian Finance Minister Resigns Amid Trump Tariff Threats
Canada's deputy prime minister and minister of finance announced Monday that she is resigning from her post, citing conflicting views with Prime Minister Justin Trudeau about how to respond to tariff threats under President-elect Donald Trump's incoming administration.
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December 16, 2024
Work Still Needed To Keep VAT In EU Effective, Group Says
Following the European Union's agreement on a value-added tax reform package, a group of EU VAT experts presented a wide-ranging suite of short- and long-term proposals Monday aimed at making sure the bloc's regime remains effective as the landscape continues to shift.
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December 16, 2024
Cos. Urge Judge To Maintain Injunction On Transparency Law
A Texas federal judge doesn't need to stay his preliminary injunction on the rollout of new corporate transparency rules while the U.S. government's appeal of his decision is pending at the Fifth Circuit, a business lobbying group and others said Monday.
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December 16, 2024
Wyden Bill Would Nix Tax Perks For Private Placement Plans
U.S. Senate Finance Committee Chairman Ron Wyden unveiled legislation Monday that would remove the tax benefits of a special type of private life insurance plan that he said high-net-worth individuals have been abusing to avoid paying taxes on their investments in the policies.
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December 16, 2024
HMRC Chief Defends Record On Fighting Tax Evasion
The chief executive of HM Revenue & Customs told Parliament on Monday that the British tax authority has reduced the level of tax noncompliance in response to claims it needs a better strategy on tax evasion.
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December 16, 2024
Info On Over 1,900 Tax Rulings Swapped In OECD Last Year
Tax jurisdictions within the Organization for Economic Cooperation and Development spontaneously shared information related to over 1,900 tax rulings involving foreign companies in 2023, the OECD said Monday, highlighting the widespread adoption of its transparency framework aimed at mitigating harmful tax practices.
Expert Analysis
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Promoting Diversity In The Selection Of ADR Neutrals
Excerpt from Practical Guidance
Choosing neutrals from diverse backgrounds is an important step in promoting inclusion in the legal profession, and it can enhance the legitimacy and public perception of alternative dispute resolution proceedings, say attorneys at Lowenstein Sandler.
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Striking A Balance Between AI Use And Attorney Well-Being
As the legal industry increasingly adopts generative artificial intelligence tools to boost efficiency, leaders must note the hidden costs of increased productivity, and work to protect attorneys’ well-being while unlocking AI’s full potential, says Ed Sohn at Factor.
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How Judiciary Can Minimize AI Risks In Secondary Sources
Because courts’ standing orders on generative artificial intelligence and other safeguards do not address the risk of hallucinations in secondary source materials, the judiciary should consider enlisting legal publishers and database hosts to protect against AI-generated inaccuracies, say attorneys at Lankler Siffert & Wohl.
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How Attorneys Can Break Free From Career Enmeshment
Ambitious attorneys can sometimes experience career enmeshment — when your sense of self-worth becomes unhealthily tangled up in your legal vocation — but taking the time to discover and realign with your core personal values can help you recover your identity, says Janna Koretz at Azimuth Psychological.
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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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The 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.