International
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September 24, 2024
Exxon Claims It Beat Weak Defense In $1.8B Tax Trial
Exxon Mobil urged a Texas federal judge to find that it defeated what it called a scattered defense by the U.S. government during a five-day bench trial in April when the company argued for a $1.8 billion tax refund on its natural gas deal with Qatar, according to newly released filings.
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September 24, 2024
Azerbaijan Ratifies OECD Tax Treaty Standards
Azerbaijan ratified the Organization for Economic Cooperation and Developement's multilateral convention on base erosion and profit shifting Tuesday, which updates bilateral tax treaties of its signatories with agreed-upon standards, the OECD said.
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September 24, 2024
HMRC Set To Launch Consultation On VAT E-Invoicing
HM Revenue & Customs will hold a consultation on e-invoicing for value-added tax "soon," the British Treasury confirmed following a speech by the chancellor.
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September 24, 2024
Miller & Chevalier Adds Federal Tax Expert From White & Case
Miller & Chevalier Chtd. announced that it added a former partner at White & Case LLP to its tax controversy and litigation practice.
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September 23, 2024
Clean Energy Safe Harbor Applies To Direct Pay, Official Says
The safe harbor for the bonus clean energy tax credits' domestic content rules applies to all applicable project owners, including tax-exempt entities that are eligible to get a direct cash payment of the credits, a U.S. Treasury Department attorney said Monday.
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September 23, 2024
The Tax Angle: Corporate Inversions, SALT Cap
From a look at criticisms that the 2017 federal tax law failed to stop corporations from moving overseas to GOP efforts to navigate the SALT cap ahead of the November elections, here's a peek into a reporter's notebook on a few of the week's developing tax stories.
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September 23, 2024
Sysco Allowed $324M Dividend Deduction After Varian Ruling
Sysco Corp. can deduct $324 million in foreign dividends after agreeing with the Internal Revenue Service that a decision in a similar case brought by Varian Medical Systems resolved their dispute, the U.S. Tax Court said in an order.
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September 23, 2024
Disney Asks Justices To Review NY Tax On Foreign Royalties
New York's highest court used the wrong standard for evaluating tax statutes for discrimination when it denied deductions that The Walt Disney Co. sought for royalties received from foreign affiliates, the company argued in a petition to the U.S. Supreme Court that Law360 obtained Monday.
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September 23, 2024
Singapore Man Sentenced To 4 Years In $43M Fraud Scheme
A Singapore man involved in a scheme that made SG$55 million ($43 million) in fictitious sales that resulted in more than SG$7.5 million in fraudulent goods-and-services tax, or GST, refund claims was sentenced to more than four years in prison Monday, the country's revenue authority said.
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September 23, 2024
IRS Finalizing Pricing Pact Guidance, Official Says
The Internal Revenue Service is in the final stages of updating revenue procedures to help multinational corporations pursue advance pricing agreements and resolve tax treaty disputes, and it will release the guidance soon, an agency official said Monday.
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September 23, 2024
Irish Carbon Tax Could Generate €8.8B By 2030, Report Says
Planned rate increases and other factors could see Ireland's carbon tax generate at least €8.8 billion ($9.8 billion) in revenue over the next six years, compared with over €3.3 billion generated from 2019 through 2023, the country's Financial Services Division said.
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September 23, 2024
Squire Patton Tax Ace Joins Winston & Strawn In Dallas
Winston & Strawn LLP announced Monday it has expanded its tax offerings with the addition of an experienced attorney from Squire Patton Boggs LLP in Texas.
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September 23, 2024
HMRC Raises £1B Cracking Down On Tax Fraud
HM Revenue & Customs raised almost £1 billion ($1.3 billion) in its most serious criminal investigations of tax fraud year-on-year in April, according to research published by a law firm Monday.
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September 23, 2024
Belgium Has High Tax Burden, Public Debt, OECD Says
While there are some tax changes Belgium should consider, the country should tackle its high public debt through better spending practices because its tax burden is among the highest in the OECD, the organization said Monday.
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September 23, 2024
Pension Experts Urge Tax Breaks For UK Investment Plan
The government could best encourage investment in the economy from pension schemes by adopting tax incentives, a trade body said.
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September 20, 2024
8th Circ. To Hear Args In 3M's $24M Tax Case Next Month
The Eighth Circuit said Friday that it will hear oral arguments next month in 3M's transfer pricing appeal, in which the multinational conglomerate is challenging the Internal Revenue Service's authority to reallocate to the company $24 million from a Brazilian affiliate.
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September 20, 2024
IRS Special Trial Attorney Joins Hochman Salkin In California
When Hochman Salkin Toscher Perez PC's newest principal, Sebastian Voth, was studying at Emory University School of Law, a former chief counsel for the Internal Revenue Service told students that the IRS was a great place to start their careers. After 15 years as an IRS attorney, Voth found that the agency was also a great place to work, he told Law360 Pulse in an interview Friday.
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September 20, 2024
Australia Seeks Comments On Luxury Car Tax Green Changes
Australia is looking for comments on plans to adjust the country's luxury car tax to update the definition of a fuel-efficient car and to make changes to the way the tax threshold is indexed, the country's Treasury Department said Friday.
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September 20, 2024
Hong Kong's Tax Revenue Drops For 2nd Straight Year
Hong Kong's tax revenue dipped by HK$14 billion ($1.8 billion) to HK$342 billion in the 2023-24 tax year — the second straight year with a drop — largely because of decreases in stamp duty and profit tax collections, its tax authority said Friday.
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September 20, 2024
Taxation With Representation: Gibson Dunn, Holland & Knight
In this week's Taxation With Representation, CACI International buys Azure Summit Technology, Hotel Engine lands a valuation led by Permira, and Knowles Corp. sells its microphone business to Syntiant Corp.
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September 20, 2024
UK Budget May Seek Gains From Inheritance Tax, Firms Say
The U.K. government may try to squeeze more revenue out of the wealthy via inheritance tax, wealth management firms said Friday following the release of data showing the levy is generating higher returns for HM Treasury.
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September 19, 2024
Pillar 1's Safe Harbor Limits Split Of Taxing Rights, Study Says
The redistribution of corporate taxing rights among countries that agreed to new profit reallocation rules known as Pillar One would be "seriously affected" by a proposed safe harbor, according to report from a think tank funded by the European Union.
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September 19, 2024
Death Doesn't Preclude FBAR Penalties, Judge Says
The death of a U.S. citizen who failed to file reports of foreign bank and financial accounts doesn't stop the U.S. government from enforcing penalties against his estate, a New York federal judge ruled.
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September 19, 2024
Spain Tax Inspections Generated €16.7B In Revenue In 2023
Spain's tax agency said Thursday that it increased the number of control actions it took against large companies and other groups by nearly 14% in 2023 as part of the agency's €16.7 billion ($18.6 billion) in revenue generated from control work last year.
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September 19, 2024
Sweden Aiming For Broad Tax Cuts In 2025 Budget
Swedish taxpayers would see lower tax rates in many areas, such as on their labor and pensions, as part of a proposed 2025 budget that the government sent to the country's legislature for consideration Thursday.
Expert Analysis
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What Recent Study Shows About AI's Promise For Legal Tasks
Amid both skepticism and excitement about the promise of generative artificial intelligence in legal contexts, the first randomized controlled trial studying its impact on basic lawyering tasks shows mixed but promising results, and underscores the need for attorneys to proactively engage with AI, says Daniel Schwarcz at University of Minnesota Law School.
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How FinCEN Proposal Expands RE Transaction Obligations
Against a regulatory backdrop foreshadowing anti-money laundering efforts in the real estate sector, the Financial Crimes Enforcement Network's proposed rule significantly expands reporting requirements for certain nonfinanced residential real estate transfers and necessitates careful review, say attorneys at Fried Frank.
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Litigation Inspiration: A Source Of Untapped Fulfillment
As increasing numbers of attorneys struggle with stress and mental health issues, business litigators can find protection against burnout by remembering their important role in society — because fulfillment in one’s work isn’t just reserved for public interest lawyers, say Bennett Rawicki and Peter Bigelow at Hilgers Graben.
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Unpacking FinCEN's Proposed Real Estate Transaction Rule
Phil Jelsma and Ulrick Matsunaga at Crosbie Gliner take a close look at the Financial Crimes Enforcement Network's recently proposed rulemaking — which mandates new disclosures for professionals involved in all-cash real estate deals — and discuss best next steps for the broad range of businesses that could be affected.
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Think Like A Lawyer: Forget Everything You Know About IRAC
The mode of legal reasoning most students learn in law school, often called “Issue, Rule, Application, Conclusion,” or IRAC, erroneously frames analysis as a separate, discrete step, resulting in disorganized briefs and untold obfuscation — but the fix is pretty simple, says Luke Andrews at Poole Huffman.
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How New EU Tax And Transfer Pricing Rules May Affect M&A
Companies involved in mergers and acquisitions may need to adjust fiscal due diligence procedures to ensure they consider potential far-reaching effects of newly implemented transfer pricing measures, such as newly implemented global minimum tax and European Union anti-tax avoidance directives and proposals, says Patrick Tijhuis at BDO.
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How Firms Can Ensure Associate Gender Parity Lasts
Among associates, women now outnumber men for the first time, but progress toward gender equality at the top of the legal profession remains glacially slow, and firms must implement time-tested solutions to ensure associates’ gender parity lasts throughout their careers, say Kelly Culhane and Nicole Joseph at Culhane Meadows.
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7 Common Myths About Lateral Partner Moves
As lateral recruiting remains a key factor for law firm growth, partners considering a lateral move should be aware of a few commonly held myths — some of which contain a kernel of truth, and some of which are flat out wrong, says Dave Maurer at Major Lindsey.
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6 Pointers For Attys To Build Trust, Credibility On Social Media
In an era of information overload, attorneys can use social media strategically — from making infographics to leveraging targeted advertising — to cut through the noise and establish a reputation among current and potential clients, says Marly Broudie at SocialEyes Communications.
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US-Chile Tax Treaty May Encourage Cross-Border Investment
Provisions in the recently effective U.S.-Chile bilateral income tax treaty should encourage business between the two countries, as they reduce U.S. withholding tax on investment income for Chilean taxpayers, exempt certain U.S. taxpayers from Chilean capital gains tax, and clarify U.S. foreign tax credit rules, say attorneys at Kramer Levin.
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A Post-Mortem Analysis Of Stroock's Demise
After the dissolution of 147-year-old firm Stroock late last year shook up the legal world, a post-mortem analysis of the data reveals a long list of warning signs preceding the firm’s collapse — and provides some insight into how other firms might avoid the same disastrous fate, says Craig Savitzky at Leopard Solutions.
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SG's Office Is Case Study To Help Close Legal Gender Gap
As women continue to be underrepresented in the upper echelons of the legal profession, law firms could learn from the example set by the Office of the Solicitor General, where culture and workplace policies have helped foster greater gender equality, say attorneys at Ocean Tomo.
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Reimagining Law Firm Culture To Break The Cycle Of Burnout
While attorney burnout remains a perennial issue in the legal profession, shifting post-pandemic expectations mean that law firms must adapt their office cultures to retain talent, say Kevin Henderson and Eric Pacifici at SMB Law Group.