International
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December 09, 2024
Woman Appeals Tax Court's Canadian Debt Ruling To 9th Circ.
A woman appealed to the Ninth Circuit a U.S. Tax Court decision that prevented her from challenging a federal tax lien issued by the Internal Revenue Service to secure her $200,000 tax debt to Canada on behalf of the Canadian government.
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December 09, 2024
16 EU Members Call For Revamped Tobacco Taxation
The European Commission needs to prioritize an overhaul of the bloc's tobacco taxation rules in the upcoming term, a group of 16 member countries said Monday, arguing that major changes in the industry since the rules last updated have left countries to fend for themselves, fragmenting the tax regime.
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December 09, 2024
Man Owed $264K Under US-Canada Tax Treaty, Court Says
A U.S. man living abroad is allowed under the U.S.-Canada tax treaty to claim a foreign tax credit for nearly $264,000 in payments of the Affordable Care Act's net investment income tax, the Federal Claims Court said.
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December 09, 2024
Latin America Should Improve Tax Collection, OECD Says
Latin American and Caribbean countries' average tax-to-gross-domestic-product ratio falls well below the Organization for Economic Cooperation and Development average, and improvements will be key to the area's ability to meet sustainable development goals, the OECD said Monday.
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December 09, 2024
UAE Implementing Global Minimum Tax In 2025
Large multinational businesses in the United Arab Emirates making at least €750 million ($792 million) annually will be subject to the OECD's 15% corporate global minimum tax starting in 2025, the country's Finance Ministry said Monday.
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December 09, 2024
Proposed Canadian Tax Holiday Will Cost $1B, Office Says
Canada's proposed two-month goods-and-services tax holiday on certain goods would result in the loss of at least CA$1.46 billion ($1 billion) in federal tax revenues, a Canadian budget watchdog said Monday.
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December 09, 2024
Germany Floats Plans To Adopt Additional Min. Tax Guidance
Germany's Federal Ministry of Finance is seeking feedback on additional proposed updates to its legislation under an international minimum tax agreement known as Pillar Two, including incorporating global guidance on how to approach deferred taxes.
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December 09, 2024
Insurer Launches Estate Planning Cover After Tax Changes
Royal London said on Monday that it has launched an insurance product designed to help consumers with their end-of-life planning, as a growing number of estates are set to become subject to inheritance tax after recent government changes.
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December 06, 2024
DC Circ. Affirms Man's $1.2M 'Seriously Delinquent' Tax Debt
A Florida man owes more than $1.2 million in federal taxes, the D.C. Circuit said Friday, affirming the Internal Revenue Service's certification of his liability under a law that allows those with a "seriously delinquent" tax debt to have their passport revoked.
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December 06, 2024
NZ Considering Edits To 'Internationally Unusual' Tax Regime
New Zealand's government received feedback that its rules for taxing investments of 10% or less in foreign companies may be discouraging people who hold interests in such entities from moving to the country, and it is seeking feedback on possible solutions, its tax authority said Friday.
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December 06, 2024
Gov't Appeals Texas Judge's Block On Anti-Laundering Law
The U.S. government has appealed a Texas federal judge's order that halted the rollout of new reporting requirements aimed at unmasking anonymous shell companies, setting the stage for the Fifth Circuit to weigh in on the nationwide preliminary injunction.
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December 06, 2024
Simpson Thacher Adds Tax Pro From Ropes & Gray
Simpson Thacher & Bartlett LLP announced the firm has added a tax professional from Ropes & Gray LLP as a partner in its Washington, D.C., office.
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December 06, 2024
Authorities Investigating Possible €200M German VAT Fraud
The European Public Prosecutor's Office carried out searches at a Munich bank as part of an investigation into a man who created a fictitious business to process more than €200 million ($211 million) in funds generated from a value-added tax fraud scheme, the EPPO said Friday.
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December 06, 2024
Canada's Chinese Import Surtaxes Expected To Raise $334M
Canada's new surtaxes on Chinese electric vehicles and steel and aluminum products are estimated to generate CA$473 million ($334 million) over the next five years, though the EV surtax on its own is likely to cause a dip in revenue, a government analysis said.
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December 06, 2024
Taxation With Representation: Skadden, Gibson Dunn
In this week's Taxation With Representation, BlackRock buys HPS Investment Partners, TreeHouse Foods Inc. buys Harris Tea, Aya Healthcare acquires Cross Country Healthcare, and Bruin Capital launches a soccer representation business.
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December 05, 2024
11th Circ. Won't Rethink $100M Credit For John Hancock
The Eleventh Circuit won't reconsider its decision to let John Hancock Life Insurance Co. keep $100 million in foreign tax credits, leaving in place its October ruling against a Florida law firm retirement plan's trustees.
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December 05, 2024
OECD Suggests Tax Shifts To Address Greece's Debt
Greece has a lot of work to do to reduce its nearly 164% public-debt-to-gross domestic product ratio, and one avenue to generate the kind of budget surplus needed is through a suite of tax changes, the Organization for Economic Cooperation and Development said Thursday.
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December 05, 2024
OECD Removes Application Deadline For Int'l Pricing Program
The Organization for Economic Cooperation and Development said Thursday it has removed biannual deadlines for large multinational entities to apply for the International Compliance Assurance Program, a multilateral effort to resolve transfer pricing issues.
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December 05, 2024
Australia Mulling More Country-By-Country Reporting Advice
While the Australian Taxation Office is already working on guidance for the country's newly adopted public country-by-country reporting rules, it is looking for input on what other areas of the provision businesses may need assistance in interpreting.
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December 05, 2024
Authorities Say €38M Greece VAT Fraud Tied To Larger Ring
Authorities in Greece carried out searches in Athens as part of an investigation into a scheme estimated to have caused €38 million ($40 million) in value-added tax losses, which the European Public Prosecutor's Office said Thursday had connections to a larger €2.2 billion scheme.
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December 05, 2024
Dutch Gov't Will Not Adopt Amount B Pricing Framework
The Dutch government announced that it will not apply a new international tax framework known as Amount B that is designed to streamline the pricing of certain cross-border operations, but it will accept the outcome when other countries apply it.
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December 05, 2024
Australia To Limit Access To Beneficial Ownership Registry
Australia's government intends to limit public access to a registry of beneficial owners for unlisted entities so that only law enforcement, regulators, journalists and academics can request files initially based on its solicitor's privacy recommendations, the Treasury said Wednesday.
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December 05, 2024
Watchdog Urges Ireland To Stash More Of €84B Tax Surplus
The Irish government should put aside more than the €31 billion ($32.7 billion) it has planned to reserve of the €84 billion tax surplus it expects to have between 2026 and 2030, a budget watchdog said Thursday, citing concerns about U.S. policy changes.
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December 05, 2024
HMRC Wins Freezing Order Over Alleged £171M Tax Fraud
A court imposed a freezing order against three British businesses on Thursday after the U.K. tax authority accused them of orchestrating a £171 million ($218 million) National Insurance fraud.
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December 04, 2024
Retired Professor Says He Didn't Waive Rights In FBAR Fight
An 86-year-old former professor told a California federal court that he raised his Eighth Amendment rights against excessive fines when defending himself against a $545,000 penalty for failing to report foreign bank accounts, disputing arguments by the U.S. government that he had waived those rights.
Expert Analysis
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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Tips For Tax Equity-Tax Credit Transfers That Pass IRS Muster
Although the Internal Revenue Service has increased its scrutiny of complex partnership structures, which must demonstrate their economic substance and business purpose, recent cases and IRS guidance together provide a reliable road map for creating legitimate tax equity structures, say Ian Boccaccio and Michael Messina at Ryan Tax.
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Mirror, Mirror On The Wall, Is My Counterclaim Bound To Fall?
A Pennsylvania federal court’s recent dismissal of the defendants’ counterclaims in Morgan v. Noss should remind attorneys to avoid the temptation to repackage a claim’s facts and law into a mirror-image counterclaim, as this approach will often result in a waste of time and resources, says Matthew Selmasska at Kaufman Dolowich.