International

  • September 18, 2024

    Tax Chiefs Eye Crypto Payment Cos., OTC Traders, IRS Says

    Tax investigators in the U.S., U.K., Canada, Australia and the Netherlands are preparing guidance on red flags for cryptocurrency payment providers and over-the-counter trading desks following a joint operation this week, a special agent with the Internal Revenue Service said Wednesday.

  • September 18, 2024

    Tax Court Wrongly Denied Premium Deduction, 5th Circ. Told

    A Texas couple asked the Fifth Circuit on Wednesday to reverse a U.S. Tax Court decision denying their bid to deduct more than $1 million in premiums paid to insurance companies they owned, arguing the Tax Court misclassified underlying insurance arrangements.

  • September 18, 2024

    Most Large Aussie Companies Paying Correct Tax Amounts

    The Australian Taxation Office has a high or medium level of assurance that 86% of the country's largest taxpayers paid the correct amount of income taxes in 2024, based on recent reviews.

  • September 18, 2024

    House GOP Vows Blowback Over OECD's Min. Tax Backstop

    House Republicans again warned the OECD that Congress will retaliate against countries that implement a backstop measure to the 15% global minimum tax, saying China will cheat the system and it will cost U.S. taxpayers about $120 billion.

  • September 18, 2024

    Estonia Implementing 2% Profit Tax To Fund Security

    Companies in Estonia will need to pay a 2% tax on their accounting profits starting in 2026 in order to boost investment in the country's defense measures, its Ministry of Finance said.

  • September 18, 2024

    Country-By-Country Reports In Place In Over 115 Jurisdictions

    More than 115 tax jurisdictions require large multinational entities to submit country-by country reports in line with the Organization for Economic Cooperation and Development standards as part of the group's fight against tax base erosion and profit shifting, the OECD reported.

  • September 18, 2024

    Colombia Should Lower 35% Corporate Tax Rate, OECD Says

    Colombia can reignite the since-slowed growth it experienced following the COVID-19 pandemic through a series of tax changes, in particular lowering its 35% corporate income tax as part of an overall rebalancing of the tax burden from corporate to personal income, according to the OECD.

  • September 18, 2024

    Latham Adds A&O Shearman Energy Group Co-Lead In DC

    Latham & Watkins LLP has hired the former co-head of Allen Overy Shearman Sterling's U.S. energy, natural resources and infrastructure group to its team of transactional tax partners based in Washington, D.C., the firm announced Monday.

  • September 18, 2024

    8th Circ. Considers Chevron's End In 3M's $24M Tax Case

    The Eighth Circuit signaled it would consider an argument by 3M that the U.S. Supreme Court's overturning of Chevron deference warranted a reversal in a transfer pricing case in which 3M is challenging the IRS' reallocation of $24 million from a Brazilian affiliate.

  • September 18, 2024

    Fixing UK Labor Market Could Raise £16B, Report Says

    The U.K. labor market has lost almost a million workers since the COVID-19 pandemic, but reversing this could raise more than £16 billion ($21.1 billion) in tax receipts, a research center said Wednesday.

  • September 18, 2024

    Dutch Government Issues Tax Cuts In First Budget

    The new Dutch government issued its first budget since the 2023 elections, including plans to cut taxes on earnings and raise the limit on certain corporate tax deductions.

  • September 17, 2024

    Tax Court Denies Mineral Co.'s $1.1M Microcaptive Deduction

    A mineral rights leasing company set up by an Oklahoma oil businessman can't take a $1.1 million deduction for what was presented as a microcaptive insurance transaction, the U.S. Tax Court ruled, saying the transaction was not a legitimate insurance arrangement.

  • September 17, 2024

    Cos. Risk Offside Call On Contractor Tax After HMRC Win

    The U.K. Supreme Court's decision Monday that Premier League referees count as employees for tax purposes means many companies may have to reassess their arrangements with contractors or risk higher tax costs in the future, tax experts say.

  • September 17, 2024

    Competitiveness Outranks Climate In New EU Commission

    European Commission President Ursula von der Leyen shifted her focus from climate change to boosting competitiveness as she proposed her team of commissioners for the next five-year mandate Tuesday, handing out key jobs covering everything from competition enforcement to trade policy.

  • September 16, 2024

    Film Producer, Accountant Hid $25M From IRS, DOJ Alleges

    A film producer who sold shares in the production company he cofounded for $25 million schemed with an Australian accountant to hide the proceeds from U.S. authorities in Swiss bank accounts, causing the IRS to lose out on some $5 million, according to the DOJ.

  • September 16, 2024

    Apple Ruling May Embolden EU's Tax Policing, Experts Say

    The European Court of Justice's ruling against Apple and Ireland last week runs contrary to its logic in a 2022 state aid ruling, potentially giving the European Commission a reason to think it can decide tax norms across Europe, tax experts said.

  • September 16, 2024

    Hospitality Sector Faces Almost £1B 'Tax Bombshell' In April

    Many companies in the hospitality sector are set to be hit with huge tax bills in April 2025 when business rates relief is phased out, an industry group said Monday.

  • September 16, 2024

    Jet Fuel Tax Could Raise Almost £6B A Year, Report Says

    HM Treasury could raise up to £5.9 billion ($7.8 billion) a year by imposing tax on jet fuel to match the duty paid by motorists, according to a think tank report published Monday.

  • September 16, 2024

    IRS Cancels Hearing On 'Basket Contract' Transactions Rule

    The Internal Revenue Service canceled a hearing on proposed rules that would flag what are known as basket option contracts as potentially abusive listed transactions, according to a notice released Monday.

  • September 16, 2024

    Football Referees Can Be Employees, Top UK Court Rules

    Referees for English football games can legally be considered employees, obliging the company they work for to deduct taxes from their pay, the U.K.'s highest court ruled Monday.

  • September 13, 2024

    The 2024 Regional Powerhouses

    The law firms on Law360's list of 2024 Regional Powerhouses reflected the local peculiarities of their states while often representing clients in deals and cases that captured national attention.

  • September 13, 2024

    EU Actors Lobby Hard For Top Jobs in New Commission

    European Union lawmakers and national governments are lobbying intensely to pull top jobs and policy their way as the new European Commission is formed for the next five years.

  • September 13, 2024

    HMRC Seeks Comments On Top-Up Tax Guidance

    HM Revenue & Customs is seeking comments on new draft guidance on the multinational top-up tax as part of implementing the global minimum corporate tax rate.

  • September 13, 2024

    EU Finance Ministers Boycott Hungary Meeting Over Russia

    Most European Union finance ministers protested on Friday against what they see as Hungary's Russia-friendly politics by boycotting a meeting with their EU peers in the country's capital, Budapest.

  • September 13, 2024

    Freeths Hires McNulty As Pensions Director In London

    Freeths LLP has appointed Sean McNulty, a former legal director at Blake Morgan as a pensions director in its London office, a move it believes will bolster its retirement income business.

Expert Analysis

  • Unpacking The Proposed Production Tax Credit Regulations

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    Recently proposed tax regulations for claiming the U.S. clean-energy manufacturers' production credit under Internal Revenue Code Section 45X are less stringent than many had feared but fail to define a fundamental eligibility requirement, say Casey August and Jared Sanders at Morgan Lewis.

  • 10 Considerations For Litigating A New York Tax Case

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    While some of New York’s recently adopted corporate tax regulations are likely to face legal challenges, aggrieved taxpayers should answer certain questions before deciding to embark on the tax litigation process, say Cyavash Ahmadi and Jeffrey Friedman at Eversheds Sutherland.

  • Law Firm Strategies For Successfully Navigating 2024 Trends

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    Though law firms face the dual challenge of external and internal pressures as they enter 2024, firms willing to pivot will be able to stand out by adapting to stakeholder needs and reimagining their infrastructure, says Shireen Hilal at Maior Consultants.

  • Attorneys' Busiest Times Can Be Business Opportunities

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    Attorneys who resolve to grow their revenue and client base in 2024 should be careful not to abandon their goals when they get too busy with client work, because these periods of zero bandwidth can actually be a catalyst for future growth, says Amy Drysdale at Alchemy Consulting.

  • How Attorneys Can Be More Efficient This Holiday Season

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    Attorneys should consider a few key tips to speed up their work during the holidays so they can join the festivities — from streamlining the document review process to creating similar folder structures, says Bennett Rawicki at Hilgers Graben.

  • How Clients May Use AI To Monitor Attorneys

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    Artificial intelligence tools will increasingly enable clients to monitor and evaluate their counsel’s activities, so attorneys must clearly define the terms of engagement and likewise take advantage of the efficiencies offered by AI, says Ronald Levine at Herrick Feinstein.

  • The Pop Culture Docket: Judge D'Emic On Moby Grape

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    The 1968 Moby Grape song "Murder in My Heart for the Judge" tells the tale of a fictional defendant treated with scorn by the judge, illustrating how much the legal system has evolved in the past 50 years, largely due to problem-solving courts and the principles of procedural justice, says Kings County Supreme Court Administrative Judge Matthew D'Emic.

  • Breaking Down High Court's New Code Of Conduct

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    The U.S. Supreme Court recently adopted its first-ever code of conduct, and counsel will need to work closely with clients in navigating its provisions, from gift-giving to recusal bids, say Phillip Gordon and Mateo Forero at Holtzman Vogel.

  • Legal Profession Gender Parity Requires Equal Parental Leave

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    To truly foster equity in the legal profession and to promote attorney retention, workplaces need to better support all parents, regardless of gender — starting by offering equal and robust parental leave to both birthing and non-birthing parents, says Ali Spindler at Irwin Fritchie.

  • A Year-End Look At Florida's Capital Investment Tax Credit

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    Notwithstanding the Walt Disney Co.’s feud with Gov. Ron DeSantis this year, Florida's capital investment tax credit will continue to make the state a favored destination for large corporations, particularly in light of the new federal alternative minimum tax and the Pillar Two top-up tax, says Alan Lederman at Gunster.

  • Understanding Discovery Obligations In Era Of Generative AI

    Excerpt from Practical Guidance
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    Attorneys and businesses must adapt to the unique discovery challenges presented by generative artificial intelligence, such as chatbot content and prompts, while upholding the principles of fairness, transparency and compliance with legal obligations in federal civil litigation, say attorneys at King & Spalding.

  • The Case For Post-Bar Clerk Training Programs At Law Firms

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    In today's competitive legal hiring market, an intentionally designed training program for law school graduates awaiting bar admission can be an effective way of creating a pipeline of qualified candidates, says Brent Daub at Gilson Daub.

  • AI Can Help Lawyers Overcome The Programming Barrier

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    Legal professionals without programming expertise can use generative artificial intelligence to harness the power of automation and other technology solutions to streamline their work, without the steep learning curve traditionally associated with coding, says George Zalepa at Greenberg Traurig.

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