International
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November 20, 2024
India's Top Court Allows Tax Credits For Excise Duties Paid
Excise duties that India's mobile telecommunication providers pay when building the infrastructure for their networks — such as transmission towers — can be used as tax credits, the Supreme Court of India ruled Wednesday.
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November 20, 2024
NY Says Changes To Fed. Tax Return Reset Refund Timeline
A couple living in Switzerland for part of each year timely filed their claim for overpaid New York state income taxes dating back to 2011 soon after winning double-taxation relief under the Swiss-U.S. tax treaty in 2018, the state's tax department said.
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November 20, 2024
NY Tax Withholding Not Needed For Foreign Board Member
A New York company that appointed an Italian citizen to its board of directors does not have to withhold state income tax for payments made to that board member, the state's tax department said.
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November 20, 2024
Irish Social Democrats Run On Wealth Tax For Millionaires
Ireland's Social Democrats are campaigning for this month's general election on a 0.5% tax on individuals' assets over €1 million ($1.1 million) — excluding homes, family businesses, art and pensions — and 1% for assets over €2 million, according to its manifesto.
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November 20, 2024
Israel Commits To OECD Crypto Information Swap Framework
Israel committed to implementing the Organization for Economic Cooperation and Development's framework for automatically exchanging financial information regarding crypto-assets by 2027, the country's Ministry of Finance said Wednesday.
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November 20, 2024
UK Biz Owes Taxes On £200M Sale Of Lease, Court Affirms
A U.K. property company owes tax on its intragroup purchase of a lease for a 50-story apartment tower in central London for £200 million ($253 million) despite its tax advisers' promise of a tax-free step-up in basis, the Upper Tribunal said Wednesday.
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November 20, 2024
Feds Again Seek Early Win In $11.6M Willful FBAR Dispute
The U.S. government intends to renew its request to resolve a narrow matter in a dispute with an international businessman facing an $11.6 million penalty for willful failure to report his foreign bank accounts before the case heads to trial, according to a filing in Hawaii federal court.
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November 20, 2024
Data Centers Ineligible For Tax Breaks, UK Justices Affirm
The U.K. Supreme Court dismissed a British developer's appeal Wednesday, ruling that HM Revenue & Customs was right to deny the company tax allowances it claimed on building two data centers in an enterprise zone.
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November 20, 2024
Switzerland To Expand Pillar 2 Minimum Tax Legislation
The Swiss government announced Wednesday that it is expanding its legislation under an international minimum tax agreement known as Pillar Two to add a measure that will help bring in up to 3.5 billion Swiss francs ($4 billion).
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November 20, 2024
NY Resident Owes Tax On Bonuses For Work Out Of State
A New York resident who lived out of the country until late 2018 owes state and New York City tax on bonuses and stock units that were paid in 2019 for work done in prior years, the state tax agency said.
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November 19, 2024
Turkish Tax Inspectors Target Alcohol Cos. For Evasion
Turkish tax inspectors raided 100 addresses tied to alcohol businesses as part of an ongoing crackdown against suspected tax evasion by companies with 100 billion lira ($2.9 billion) in combined revenue, Turkey's Ministry of Treasury and Finance told state news media.
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November 19, 2024
G20 To Cooperate On Soft Law For Taxing Ultra-Wealthy
Leaders of the world's largest economies intend to cooperate on taxing "ultra-high-net-worth individuals" through soft law approaches such as exchanging best practices and creating model policies that address tax avoidance, according to a Group of 20 Nations declaration.
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November 19, 2024
Liberty Global Tax Break Based On Void Moves, 10th Circ. Told
The economic substance doctrine is broad and can invalidate telecommunications company Liberty Global's transaction that led to a $2.4 billion deduction because steps taken to maximize the tax break lacked business purpose, a government attorney told the Tenth Circuit on Tuesday.
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November 19, 2024
Austrian Tax Official Tapped To Head Finance Ministry
The head of the Austrian finance ministry's tax policy and tax law section will take over as the country's temporary finance minister, the ministry announced Tuesday.
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November 19, 2024
Spain Committee Sends Min. Tax To Vote Under EU Pressure
Spain's lower house will vote Thursday on a bill that would follow through on an EU directive to implement the OECD's global corporate minimum tax after it was narrowly approved by a finance committee Tuesday as the country faces pressure from the bloc.
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November 19, 2024
Airbnb Ireland Puts Aside $1B For Tax Investigations
Airbnb has put aside €950 million ($1 billion) in Ireland during talks with the Italian Revenue Authority over a tax audit, according to company accounts reported in Irish media.
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November 19, 2024
Treasury Finalizes Partnership Tax Credit 'Direct Pay' Regs
The U.S. Treasury Department finalized regulations Tuesday to make it easier for tax-exempt entities that co-own development projects to qualify for a direct cash payment of clean energy tax credits by electing out of their partnership tax status.
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November 18, 2024
Tax Court Won't Reverse On Foreign Reporting Penalties
The U.S. Tax Court affirmed Monday its position that the IRS lacks authority to assess certain foreign information reporting penalties, denying the agency's request to reverse a ruling that let a Missouri businessowner off the hook for $120,000.
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November 18, 2024
EU Members Face Choice Over Trump Tax Stance, Group Says
Member states of the European Union will have to pick a side if President-elect Donald Trump's incoming administration abandons global tax reform, the Tax Justice Network said Monday.
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November 18, 2024
EU Court OKs Making Execs Show Cause To Escape Tax Debt
It's acceptable under European Union law to require a business director seeking to rid themselves of their company's tax debt to prove they weren't responsible for failing to notify authorities of their inability to pay, the bloc's highest court ruled.
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November 18, 2024
Countries Eye Certain Tax Credits To Get Leg Up Under Pillar 2
The international minimum tax agreement known as Pillar Two is changing how countries compete for corporate investment, in part by prompting some governments to retool their tax credit systems in ways that could edge out jurisdictions with fewer resources.
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November 18, 2024
6th Circ. Pauses IRS Summons For Eaton Worker Docs
The Sixth Circuit said Eaton Corp. doesn't have to comply with an IRS demand to produce performance reviews for its foreign employees until the appellate court decides whether to overturn a decision that the agency's transfer pricing investigation of the multinational power management company outweighed worker privacy concerns.
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November 18, 2024
Malta Should Work To Align With OECD Min. Tax, IMF Says
Despite its election to delay enacting portions of the OECD's global minimum tax plan under a European Union directive, Malta should develop a plan for adjusting its corporate income tax regime instead of waiting out the clock to implement it, the International Monetary Fund said Monday.
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November 18, 2024
Allen Matkins Adds Stradley Ronon Tax Co-Chair In NY
Allen Matkins Leck Gamble Mallory & Natsis LLP has continued growing its New York office with the addition of the co-chair of Stradley Ronon Stevens & Young LLP's tax department, the firm said Monday.
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November 18, 2024
Poland Enacts Global Min. Tax After EU Pressure
Poland officially implemented the global corporate minimum tax spearheaded by the Organization for Economic Cooperation and Development following pressure from the European Union to join the majority of the bloc in doing so.
Expert Analysis
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A Look At New IRS Rules For Domestically Controlled REITs
The Internal Revenue Services' finalized Treasury Regulations addressing whether real estate investment trusts qualify as domestically controlled adopt the basic structure of previous proposals, but certain new and modified rules may mitigate the regulations' impact, say attorneys at Simpson Thacher.
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E-Discovery Quarterly: Recent Rulings On Text Message Data
Electronically stored information on cellphones, and in particular text messages, can present unique litigation challenges, and recent court decisions demonstrate that counsel must carefully balance what data should be preserved, collected, reviewed and produced, say attorneys at Sidley.
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Don't Use The Same Template For Every Client Alert
As the old marketing adage goes, consistency is key, but law firm style guides need consistency that contemplates variety when it comes to client alert formats, allowing attorneys to tailor alerts to best fit the audience and subject matter, says Jessica Kaplan at Legally Penned.
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Think Like A Lawyer: Follow The Iron Rule Of Trial Logic
Many diligent and eager attorneys include every good fact, point and rule in their trial narratives — spurred by the gnawing fear they’ll be second-guessed for leaving something out — but this approach ignores a fundamental principle of successful trial lawyering, says Luke Andrews at Poole Huffman.
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The Art Of Asking: Leveraging Your Contacts For Referrals
Though attorneys may hesitate to ask for referral recommendations to generate new business, research shows that people want to help others they know, like and trust, so consider who in your network you should approach and how to make the ask, says Rebecca Hnatowski at Edwards Advisory.
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Unpacking The Bill To Extend TCJA's Biz-Friendly Tax Breaks
Attorneys at Skadden examine how a bipartisan bill currently being considered by the U.S. Senate to save the Tax Cuts and Jobs Act's tax breaks for research and development costs, and other expiring business-friendly provisions, would affect taxpayers.
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Deciding What Comes At The End Of WTO's Digital Tariff Ban
Companies that feel empowered by the World Trade Organization’s recent two-year extension of the ban on e-commerce tariffs should pay attention to current negotiations over what comes after the moratorium expires, as these agreements will define standards in international e-commerce for years to come, say Jan Walter, Hannes Sigurgeirsson and Kulsum Gulamhusein at Akin Gump.
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4 Ways To Refresh Your Law Firm's Marketing Strategy
With many BigLaw firms relying on an increasingly obsolete marketing approach that prioritizes stiff professionalism over authentic connection, adopting a few key communications strategies to better connect with today's clients and prospects can make all the difference, say Eric Pacifici and Kevin Henderson at SMB Law.
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This Earth Day, Consider How Your Firm Can Go Greener
As Earth Day approaches, law firms and attorneys should consider adopting more sustainable practices to reduce their carbon footprint — from minimizing single-use plastics to purchasing carbon offsets for air travel — which ultimately can also reduce costs for clients, say M’Lynn Phillips and Lisa Walters at IMS Legal Strategies.
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Cum-Ex Prosecutions Storm Shows No Sign Of Abating
The ongoing trial of Sanjay Shah in Denmark is a clear indicator that efforts remain focused on holding to account the alleged architects and beneficiaries of cum-ex trading, and with these prosecutions making their way across Europe, it is a more turbulent time now than ever, says Niall Hearty at Rahman Ravelli.
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Practicing Law With Parkinson's Disease
This Parkinson’s Awareness Month, Adam Siegler at Greenberg Traurig discusses his experience working as a lawyer with Parkinson’s disease, sharing both lessons on how to cope with a diagnosis and advice for supporting colleagues who live with the disease.
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Why Supreme Court Should Allow Repatriation Tax To Stand
If the U.S. Supreme Court doesn't reject the taxpayers' misguided claims in Moore v. U.S. that the mandatory repatriation tax is unconstitutional, it could wreak havoc on our system of taxation and result in a catastrophic loss of revenue for the government, say Christina Mason and Theresa Balducci at Herrick Feinstein.
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For Lawyers, Pessimism Should Be A Job Skill, Not A Life Skill
A pessimistic mindset allows attorneys to be effective advocates for their clients, but it can come with serious costs for their personal well-being, so it’s crucial to exercise strategies that produce flexible optimism and connect lawyers with their core values, says Krista Larson at Stinson.