International

  • October 04, 2024

    Europe Votes To Raise Tariffs On Electric Vehicles From China

    European Union member states voted Friday to impose higher tariffs on imports of battery electric vehicles from China for the next five years, adding to the already staggering tariffs imposed by the United States and Canada.

  • October 04, 2024

    Brazil Establishes 15% Global Min. Tax On Large Cos.

    Brazil's government has adopted the Organization for Economic Cooperation and Development's 15% global corporate minimum tax on large multinational corporations making €750 million ($823 million) annually.

  • October 04, 2024

    Former NJ Doctor Owes $4.8M In FBAR Penalties, Court Told

    A former physician in New Jersey faces a tax bill of almost $5 million for failing to report 19 bank accounts he opened at Indian banks, the government told a federal court.

  • October 04, 2024

    ECJ Says Interest Deduction Limits Align With EU Law

    Governments across the European Union can legislate to block businesses from getting corporate tax deductions on interest paid as part of noncommercial loans, the European Court of Justice ruled Friday.

  • October 04, 2024

    Taxation With Representation: Gibson Dunn, Weil, Simpson

    In this week's Taxation with Representation, DirectTV buys EchoStar's video business for $10 billion, Marsh McLennan inks a $7.75 billion deal for McGriff Insurance, and PepsiCo closes a $1.2 billion deal to purchase Siete Foods.

  • October 04, 2024

    McDermott Taps Big 4 Partner As Senior Tax Pro In London

    McDermott Will & Emery LLP announced it has recruited a former U.K. partner from KPMG to join its firm as a tax partner, bringing an expert in private equity to its London office.

  • October 03, 2024

    12 Lawyers Who Are The Future Of The Supreme Court Bar

    One attorney hasn't lost a single U.S. Supreme Court case she's argued, or even a single justice's vote. One attorney is perhaps "the preeminent SCOTUS advocate." And one may soon become U.S. solicitor general, despite acknowledging there are "judges out there who don't like me." All three are among a dozen lawyers in the vanguard of the Supreme Court bar's next generation, poised to follow in the footsteps of the bar's current icons.

  • October 03, 2024

    US Partnership Excluded From Tax Treaty, Irish Court Says

    A Delaware corporation with three Irish subsidiaries must pay Irish taxes on distributions to its U.S. partners because a U.S.-Ireland tax treaty designed to prevent double taxation does not apply, the Irish High Court ruled.

  • October 03, 2024

    3M Tells 8th Circ. Chevron's End Dooms IRS In $24M Dispute

    Multinational conglomerate 3M said Thursday that the U.S. Supreme Court's striking down of Chevron deference dictates that the Eighth Circuit overturn a U.S. Tax Court decision that supported the IRS' reallocation of $24 million from the company's Brazilian affiliate.

  • October 03, 2024

    K&L Gates Boosts Houston Shop With Ernst & Young Tax Ace

    K&L Gates LLP strengthened its Houston office this week with the hire of a tax partner with nearly three decades of expertise in advising multinational corporations on U.S. taxation on cross-border acquisitions and other transactions.

  • October 03, 2024

    Aerospace Co. Says Conn. Town Wrongly Taxed $8M In Assets

    A unit of a U.K.-based aerospace manufacturer is claiming that a Connecticut town overvalued its taxable personal property by nearly $8 million after the company moved nearly $20 million worth of its property out of the jurisdiction, according to a suit filed in state court.

  • October 03, 2024

    Tax Could Help Curtail Plastic Pollution By 2040, OECD Says

    Taxation targeted at plastic use could help to nearly eliminate plastic pollution by 2040 by curbing both creation and consumption, the Organization for Economic Cooperation and Development said.

  • October 03, 2024

    EU, Norway Update VAT Fraud Cooperation Agreement

    The European Union and Norway have amended their agreement on administrative cooperation to help combat value-added tax fraud as well as the recovery of claims, the European Commission announced.

  • October 03, 2024

    EU Refers 4 Countries To Court Over Pillar 2 Delays

    The European Commission said it was referring Cyprus, Poland, Portugal and Spain to the European Union's top court for missing the deadline to implement the global minimum corporate tax, known as Pillar Two.

  • October 02, 2024

    BlackBerry's $17M In R&D Not Taxable, Canada Court Rules

    BlackBerry Ltd. won't pay taxes on $17.1 million in research and development services it procured from its U.S. affiliates because the services don't fit the definition of foreign accrual property income, the Tax Court of Canada ruled.

  • October 02, 2024

    Philippines Enacts 12% VAT On Foreign Digital Services

    Google, Amazon and Netflix are among the companies expected to pay a 12% value-added tax on foreign digital service providers that was signed into law Wednesday by Philippines President Ferdinand Marcos Jr., according to government agencies.

  • October 02, 2024

    IRS Says European Energy Exchange Is A Qualified Exchange

    The European Energy Exchange is a qualified board or exchange for purposes of mark-to-market contracts under Internal Revenue Code Section 1256(g)(7)(C), the Internal Revenue Service said Wednesday. 

  • October 02, 2024

    OECD Releases Crypto Data-Swap Guidance For Tax Agencies

    The Organization for Economic Cooperation and Development released guidance Wednesday to help tax administrations automatically exchange information under a new global crypto-asset reporting framework and under an updated system for swapping traditional financial data.

  • October 02, 2024

    Mongolia Ratifies OECD Tax Treaty Standards

    Mongolia ratified the Organization for Economic Cooperation and Development's multilateral convention on base erosion and profit shifting, which updates bilateral tax treaties of its signatories with agreed-upon standards, the OECD said Wednesday.

  • October 02, 2024

    4 Arrested In €97M VAT Fraud Involving Phone Service

    Four people were arrested in Italy for their suspected roles in a value-added tax fraud scheme involving services that let users make phone calls via the internet that sought to claim over €97 million ($107 million) in fraudulent refunds, the European Public Prosecutor's Office said Wednesday.

  • October 02, 2024

    Canada Finalizes Surtax List For Chinese Steel, Aluminum

    Canada's Department of Finance issued its finalized list of Chinese-made steel and aluminum products that will be hit with a 25% surtax when imported into the country starting later this month.

  • October 01, 2024

    Tax Deadlines Extended For Victims Of Israel-Hamas War

    The Internal Revenue Service said Tuesday that it will postpone tax return and payment deadlines to Sept. 30, 2025, for those affected by the Israel-Hamas war across 2023 and 2024.

  • October 01, 2024

    Amgen Must Face Suit It Misled Investors On $10.7B Tax Bill

    Amgen lost an attempt to escape a potential class action claiming the pharmaceutical giant hid a $10.7 billion tax bill from investors after a New York federal court ruled there was sufficient evidence for the action to proceed.

  • October 01, 2024

    Ex-USTR Official Sees Possible Path Forward For Digital Taxes

    The U.S. may withhold trade threats if it believes countries are having good-faith conversations about concerns that their digital services taxes discriminate against U.S. businesses, including in current talks with Canada, the former general counsel for the Office of the U.S. Trade Representative told Law360.

  • October 01, 2024

    Ireland Eyes Infrastructure With €14B From ECJ Apple Case

    The Irish government is aiming to build infrastructure with the €14.1 billion ($15.6 billion) in corporate tax payments due from Apple Inc. following a European Court of Justice ruling that Ireland granted Apple illegal state aid, officials said Tuesday in announcing next year's budget.

Expert Analysis

  • Atty Well-Being Efforts Ignore Root Causes Of The Problem

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    The legal industry is engaged in a critical conversation about lawyers' mental health, but current attorney well-being programs primarily focus on helping lawyers cope with the stress of excessive workloads, instead of examining whether this work culture is even fundamentally compatible with lawyer well-being, says Jonathan Baum at Avenir Guild.

  • Unpacking The Circuit Split Over A Federal Atty Fee Rule

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    Federal circuit courts that have addressed Rule 41(d) of the Federal Rules of Civil Procedure are split as to whether attorney fees are included as part of the costs of a previously dismissed action, so practitioners aiming to recover or avoid fees should tailor arguments to the appropriate court, says Joseph Myles and Lionel Lavenue at Finnegan.

  • After A Brief Hiccup, The 'Rocket Docket' Soars Back To No. 1

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    The Eastern District of Virginia’s precipitous 2022 fall from its storied rocket docket status appears to have been a temporary aberration, as recent statistics reveal that the court is once again back on top as the fastest federal civil trial court in the nation, says Robert Tata at Hunton.

  • Recruitment Trends In Emerging Law Firm Frontiers

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    BigLaw firms are facing local recruitment challenges as they increasingly establish offices in cities outside of the major legal hubs, requiring them to weigh various strategies for attracting talent that present different risks and benefits, says Tom Hanlon at Buchanan Law.

  • How Associates Can Build A Professional Image

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    As hybrid work arrangements become the norm in the legal industry, early-career attorneys must be proactive in building and maintaining a professional presence in both physical and digital settings, ensuring that their image aligns with their long-term career goals, say Lana Manganiello at Equinox Strategy Partners and Estelle Winsett at Estelle Winsett Professional Image Consulting.

  • Firms Must Rethink How They Train New Lawyers In AI Age

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    As law firms begin to use generative artificial intelligence to complete lower-level legal tasks, they’ll need to consider new ways to train summer associates and early-career attorneys, keeping in mind the five stages of skill acquisition, says Liisa Thomas at Sheppard Mullin.

  • Think Like A Lawyer: Always Be Closing

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    When a lawyer presents their case with the right propulsive structure throughout trial, there is little need for further argument after the close of evidence — and in fact, rehashing it all may test jurors’ patience — so attorneys should consider other strategies for closing arguments, says Luke Andrews at Poole Huffman.

  • Litigation Inspiration: Attys Can Be Heroic Like Olympians

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    Although litigation won’t earn anyone an Olympic medal in Paris this summer, it can be worthy of the same lasting honor if attorneys exercise focused restraint — seeking both their clients’ interests and those of the court — instead of merely pursuing every advantage short of sanctionable conduct, says Bennett Rawicki at Hilgers Graben.

  • Lean Into The 'Great Restoration' To Retain Legal Talent

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    As the “great resignation,” in which employees voluntarily left their jobs in droves, has largely dissipated, legal employers should now work toward the idea of a “great restoration,” adopting strategies to effectively hire, onboard and retain top legal talent, says Molly McGrath at Hiring & Empowering Solutions.

  • Fishing Makes Me A Better Lawyer

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    Atop the list of ways fishing makes me a better lawyer is the relief it offers from the chronic stress of a demanding caseload, but it has also improved my listening skills and patience, and has served as an exceptional setting for building earnest relationships, says Steven DeGeorge​​​​​​​ at Robinson Bradshaw.

  • A Healthier Legal Industry Starts With Emotional Intelligence

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    The legal profession has long been plagued by high rates of mental health issues, in part due to attorneys’ early training and broader societal stereotypes — but developing one’s emotional intelligence is one way to foster positive change, collectively and individually, says attorney Esperanza Franco.

  • To Make Your Legal Writing Clear, Emulate A Master Chef

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    To deliver clear and effective written advocacy, lawyers should follow the model of a fine dining chef — seasoning a foundation of pure facts with punchy descriptors, spicing it up with analogies, refining the recipe and trimming the fat — thus catering to a sophisticated audience of decision-makers, says Reuben Guttman at Guttman Buschner.

  • Circuit Judge Writes An Opinion, AI Helps: What Now?

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    Last week's Eleventh Circuit opinion in Snell v. United Specialty Insurance, notable for a concurrence outlining the use of artificial intelligence to evaluate a term's common meaning, is hopefully the first step toward developing a coherent basis for the judiciary's generative AI use, says David Zaslowsky at Baker McKenzie.

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