International

  • January 01, 2025

    European Tax Policy To Watch In 2025

    The European Union may have to go it alone on international tax policy in 2025, especially because President-elect Donald Trump's return to power means the U.S. will likely oppose any multilateral solution to taxing the digital economy. Here, Law360 looks at important European tax developments to watch for this year.

  • January 01, 2025

    Top Federal Tax Cases To Watch In 2025

    Over the next year, tax practitioners will be closely monitoring suits that challenge the IRS' use of the economic substance doctrine, take advantage of the U.S. Supreme Court's landmark decision curbing federal agencies' regulatory authority and dispute the government's handling of worker retention credits. Here, Law360 looks at key federal tax cases to follow in 2025.

  • December 23, 2024

    Anti-Laundering Law Is Likely Constitutional, 5th Circ. Rules

    The Fifth Circuit on Monday lifted a lower court's nationwide block of a federal corporate transparency law, ruling in an unpublished order that the federal government made a "strong showing" that it could successfully defend the law's constitutionality.

  • December 20, 2024

    Utah Judge Pauses Challenge To Corporate Transparency Act

    A Utah federal judge has stayed a case seeking to block the Corporate Transparency Act to see how the new administration of President-elect Donald Trump handles the law after a kindred case in Texas won a preliminary injunction on it.

  • December 20, 2024

    Rules On Earnings, Profits Still Being Vetted, IRS Official Says

    Recently proposed rules for previously taxed earnings and profits aren't able to be relied on by taxpayers until they are finalized because they contain new approaches that have to be properly vetted through a notice and comment period, an IRS official said Friday.

  • December 20, 2024

    Top Federal Tax Decisions Of 2024

    Over the past year, federal courts have issued decisions further delimiting the power of the Internal Revenue Service, with the First Circuit affirming a decision to allow agency summonses for cryptocurrency account records and an Arizona federal court rejecting a call to lift the agency's moratorium on processing pandemic-era worker credits. Here, Law360 reviews some of the most significant federal tax decisions of 2024.

  • December 20, 2024

    Digital Taxes In Flux Amid Renewed US Tariff Threats

    Governments around the world revisited their approaches to digital services taxes this year by adopting broader versions, raising rates, carving out industries and analyzing the impacts of adopting unilateral measures as threats of U.S. tariffs materialize once again. Here, Law360 looks at how countries around the world are considering, adopting or changing their DSTs.

  • December 20, 2024

    Osborne Clarke Pro Fined £50K Over Zahawi Libel Letter

    A tribunal fined an Osborne Clarke LLP partner who represented Nadhim Zahawi £50,000 ($62,700) on Friday for trying to stop a blogger revealing that the former chancellor was contemplating libel action over allegations of dishonesty in his tax affairs.

  • December 19, 2024

    Atty Exits Denmark's $2.1B Tax Fraud Case After Settlement

    A New York federal court removed an attorney from a $2.1 billion tax fraud suit after Denmark's tax authority settled with him on his involvement in the matter, according to recent filings.

  • December 19, 2024

    Denmark Says $500M Recovered In Dividend Tax Fraud Suits

    Denmark's tax administration has recovered a total of 3.6 billion Danish kroner ($500 million) in money lost to suspected dividend tax refund fraud after entering settlements of civil cases in several countries in 2024, Denmark's tax minister announced.

  • 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.

  • 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.

  • 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.

  • 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. 

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

Expert Analysis

  • So You Want To Move Your Law Practice To Canada, Eh?

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    Google searches for how to move to Canada have surged in the wake of the U.S. presidential election, and if you’re an attorney considering a move to the Great White North, you’ll need to understand how the practice of law differs across the border, says David Postel at Henein Hutchison.

  • Promoting Diversity In The Selection Of ADR Neutrals

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    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.

  • Striking A Balance Between AI Use And Attorney Well-Being

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    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.

  • How Judiciary Can Minimize AI Risks In Secondary Sources

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    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.

  • How Attorneys Can Break Free From Career Enmeshment

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    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.

  • Lawyers With Disabilities Are Seeking Equity, Not Pity

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    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.

  • Judicial Committee Best Venue For Litigation Funding Rules

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    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.

  • The Strategic Advantages Of Appointing A Law Firm CEO

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    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.

  • How Cos. Can Build A Strong In-House Pro Bono Program

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    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.

  • Home Canning Makes Me A Better Lawyer

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    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.

  • Use The Right Kind Of Feedback To Help Gen Z Attorneys

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    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.

  • Congress Can And Must Enact A Supreme Court Ethics Code

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    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.

  • What To Make Of Dueling Corporate Transparency Act Rulings

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    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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