International
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May 14, 2024
A Fifth Of Big Cos. Use Tax Transparency Standard, Org. Says
About a fifth of the largest 1,000 public companies worldwide have voluntarily used a public country-by-country reporting standard created by an international independent standards organization, the nonprofit said Tuesday.
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May 14, 2024
Law Prof Comes To Treasury's Aid In 3M Transfer Pricing Fight
The U.S. Department of the Treasury did not act arbitrarily when it wrote transfer pricing regulations that allowed the government to disregard foreign legal restrictions on royalty payments when allocating income to 3M from an affiliate, a law professor told the Eighth Circuit on Tuesday.
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May 14, 2024
Solarium Sunbaths Not Tax-Free Wellness, Sweden Says
After receiving multiple questions about whether paying to sunbathe in a solarium is eligible for Sweden's tax-free wellness allowance, the country's tax agency said Tuesday that such activity is not eligible.
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May 14, 2024
Microsemi Calls IRS' Penalty Approval 'Woefully Inadequate'
An Internal Revenue Service supervisor's sign-off on a transfer pricing penalty for Microsemi was "woefully inadequate" to meet statutory requirements for penalty approval, the semiconductor manufacturer told the U.S. Tax Court.
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May 14, 2024
Aussie Budget Proposes Green Credits, Capital Gains Change
Australia would offer tax credits for hydrogen production and critical mineral mining and update its foreign resident capital gains tax rules as part of a proposed 2024-25 budget released Tuesday.
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May 14, 2024
British Industry Group Calls For Green Energy Tax Breaks
The U.K. needs to "outsmart rather than outspend" other countries to grow in the green energy sector, a British business advocacy group said, calling for the government to create a 40% so-called green innovation tax credit, among other tax breaks.
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May 14, 2024
Ex-Whiteford Taylor Business Co-Chair Joins Baker Donelson
Baker Donelson Bearman Caldwell & Berkowitz PC has welcomed a new shareholder who spent more than a decade with the Internal Revenue Service and previously co-chaired Whiteford Taylor & Preston LLP's business department, the firm announced on Monday.
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May 14, 2024
EU Finance Ministers Strike Deal On Withholding Tax Refunds
European Union finance ministers agreed Tuesday to a withholding tax refund law, as previous holdouts Poland and the Czech Republic withdrew their objections.
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May 14, 2024
EU Chair To Fight On For VAT Deal After Estonia's Rejection
The chair of the European Union's council of finance ministers said he will fight to get unanimous support for a wide-ranging reform of value-added tax rules after Estonia blocked agreement to the law Tuesday.
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May 14, 2024
Aussie Senate Faces Separation Of Promoter Penalty, Gas Tax
The Australian government is poised to double the penalty for corporate promoters of tax avoidance schemes, but it may first have to compromise by separating its bill from another one dealing with a tax on offshore gas exports, according to a legislative report.
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May 13, 2024
Corp. Transparency Act An Overbroad Dragnet, 11th Circ. Told
Congress exceeded its authority in passing the Corporate Transparency Act, which prompted the U.S. Treasury Department to solicit personal information for law enforcement purposes from those that registered and owned state-registered entities, a small-business group told the Eleventh Circuit on Monday.
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May 13, 2024
House GOP Bills Target Foreign Funding To Tax-Exempt Orgs
The House Ways and Means Committee will vote Wednesday on a package of bills that would increase scrutiny of foreign donations to tax-exempt organizations, including legislation that would require those organizations to publicly report the donations, the Joint Committee on Taxation announced Monday.
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May 13, 2024
Income Nixes Exxon's 'Final Loss' Deduction, Court Says
Exxon's Norwegian operation cannot deduct 900 million krone ($83.2 million) from its fiscal year 2012 taxable income that it spent liquidating an Exxon subsidiary in Denmark, a European court ruled Monday.
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May 13, 2024
2nd Circ. Won't Revive UBS Suit Over Disclosed Account Info
The Second Circuit declined Monday to revive a couple's suit accusing UBS of fraudulently flagging an account to the Internal Revenue Service, finding that any alleged harm resulting from an audit would have been caused by the agency itself.
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May 13, 2024
Int'l Authorities Want Increased Anti-Money Laundering Efforts
Countries need to do more to tackle the "huge illicit profits" being generated by international crime organizations and used for harmful practices such as funding terrorism, the heads of the Financial Action Task Force, Interpol and a United Nations group said Monday.
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May 13, 2024
Estonia Needs To Improve Property, Health Taxes, OECD Says
While Estonia has the lowest ratio of government debt to gross domestic product of any OECD country, it has numerous areas where it could improve its tax system, from broadening its tax base to increasing healthcare funding, the OECD said Monday.
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May 13, 2024
EU Initiative Pushes Bloc To Strengthen Carbon Taxing
The European Commission on Monday officially registered a citizen initiative to focus on accelerating the taxing of greenhouse gas emissions as well as making it more equitable, giving the group behind it a year to meet certain criteria that would force the European Union's executive arm to act.
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May 13, 2024
Houston Truck Co. Doesn't Owe $2M Excise Tax, 5th Circ. Told
A Houston truck company that sells tires made by a Chinese manufacturer doesn't owe $2 million in import taxes because it's not legally the tire importer, the company told the Fifth Circuit in asking it to affirm a ruling that could split circuits.
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May 13, 2024
Estonia Objecting To VAT Proposal On 'Neutrality' Grounds
Estonia is objecting to a proposed overhaul of European Union value-added tax rules because the proposal doesn't respect the principle of "neutrality," the country's finance minister said Monday, casting doubt on the fate of the proposal, which needs agreement by all 27 EU countries to pass.
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May 13, 2024
EU Chair Offers Compromise To Clinch Withholding Tax Deal
The chair of European Union finance ministers offered last-minute concessions to try to persuade holdouts the Czech Republic and Poland to agree to a withholding tax refund law, a document published Monday showed.
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May 11, 2024
Gov't Urges 8th Circ. To Uphold 3M's $24M Pricing Adjustment
The U.S. government asked the Eighth Circuit to uphold a U.S. Tax Court decision allowing the IRS to allocate nearly $24 million from 3M's Brazilian affiliate, arguing the company's appeal involves misplaced reliance on a U.S. Supreme Court decision.
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May 10, 2024
5 Goals Gov'ts Have For The UN Tax Convention
Transfer pricing, country-by-country reporting, wealth taxation, the digital economy and the participation of developing countries in negotiations are topics governments at the United Nations said they want to address during the first session on drafting terms of reference for the Framework Convention on International Tax Cooperation.
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May 10, 2024
Austria Eyes Fines For Fake Invoices Used In Tax Fraud
People creating false invoices in Austria could face fines of up to €100,000 ($108,000) as the country looks to crack down on tax fraud involving fictitious businesses, the country's Ministry of Finance said Friday.
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May 10, 2024
DC Tax Atty Can't Use Ch. 7 To Ditch Depo In $19M Theft Suit
A corporate D.C. tax attorney accused of bilking a former client out of $19 million via a captive insurance scam will be deposed, despite a stay in the Maryland federal case against him and his firm after both filed for bankruptcy.
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May 10, 2024
Use Of AI For Tax Comment Letters Poses Ethical Quandaries
While artificial intelligence can streamline the process of conducting a comprehensive review of complex, IRS-proposed federal tax regulations, tax attorneys must be aware of professional and ethical considerations when using it to help draft comment letters to submit to the agency.
Expert Analysis
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How And Why Your Firm Should Implement Fixed-Fee Billing
Amid rising burnout in the legal industry and client efforts to curtail spending, pivoting to a fixed-fee billing model may improve client-attorney relationships and offer lawyers financial, logistical and stress relief — while still maintaining profit margins, say Kevin Henderson and Eric Pacifici at SMB Law Group.
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How Law Firms Can Use Account-Based Marketing Strategies
Amid several evolving legal industry trends, account-based marketing can help law firms uncover additional revenue-generating opportunities with existing clients, with key considerations ranging from data analytics to relationship building, say Jennifer Ramsey at stage LLC and consultant Gina Sponzilli.
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Strategic Succession Planning At Law Firms Is Crucial
Senior partners' reluctance to retire, the rise of the nonequity partner tier and generational differences in expectations are all contributing to an increasing number of departures from BigLaw, making it imperative for firms to encourage retirement among senior ranks and provide clearer leadership pathways to junior attorneys, says Laura Leopard at Leopard Solutions.
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Maximizing Law Firm Profitability In Uncertain Times
As threats of an economic downturn loom, firms can boost profits by embracing the power of bottom-line management and creating an ecosystem where strategic financial oversight and robust timekeeping practices meet evolved client relations, says Shireen Hilal at Maior Strategic Consulting.
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5th Circ. Ruling Reminds Attys That CBP Can Search Devices
The Fifth Circuit’s recent Malik v. Department of Homeland Security decision adds to the chorus of federal courts holding that border agents don’t need a warrant to search travelers’ electronic devices, so attorneys should consider certain special precautions to secure privileged information when reentering the U.S., says Jennifer Freel at Jackson Walker.
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Enforcement Of International Tax Reporting Is Heating Up
Since the U.S. Supreme Court’s February decision in Bittner v. U.S. changed how penalties for failure to report offshore accounts are calculated, recent developments suggest the government is preparing to step up enforcement and vigorously pursue the collection of resulting penalties, say Daniel Silva and Agustin Ceballos at Buchalter.
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IRS Notice Clarifies R&E Amortization, But Questions Remain
The IRS and Treasury Department’s recent notice clarifying the treatment of specified research and experimental expenditures under Section 174 provides taxpayers and practitioners with substantive guidance, but it misses the mark in delineating which expenditures are amortizable, say attorneys at Eversheds Sutherland.
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Preparing Your Legal Department For Pillar 2 Compliance
Multinational entities should familiarize themselves with Pillar Two of the Organization for Economic Cooperation and Development’s BEPs 2.0 project and prepare their internal legal tracking systems for related reporting requirements that may go into effect as early as January, says Daniel Robyn at Ernst & Young.
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What Large Language Models Mean For Document Review
Courts often subject parties using technology assisted review to greater scrutiny than parties conducting linear, manual document review, so parties using large language models for document review should expect even more attention, along with a corresponding need for quality control and validation, say attorneys at Sidley.
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Participating In Living History Makes Me A Better Lawyer
My role as a baron in a living history group, and my work as volunteer corporate counsel for a book series fan association, has provided me several opportunities to practice in unexpected areas of law — opening doors to experiences that have nurtured invaluable personal and professional skills, says Matthew Parker at the Nebraska Department of Health and Human Services.
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Private Equity Owners Can Remedy Law Firms' Agency Issues
Nonlawyer, private-equity ownership of law firms can benefit shareholders and others vulnerable to governance issues such as disparate interests, and can in turn help resolve agency problems, says Michael Di Gennaro at The Law Practice Exchange.
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How Taxpayers Can Prep As Justices Weigh Repatriation Tax
The U.S. Supreme Court might strike down the 2017 federal tax overhaul's corporate repatriation tax in Moore v. U.S., so taxpayers should file protective tax refund claims before the case is decided and repatriate previously taxed earnings that could become entangled in dubious potential Section 965 refunds, say Jenny Austin and Gary Wilcox at Mayer Brown.
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OFAC Designation Prosecutions Are Constitutionally Suspect
Criminal prosecutions based on the Office of Foreign Assets Control’s sanctions-related listing decisions — made with nearly unfettered discretion through an opaque process — present several constitutional issues, so it is imperative that courts recognize additional rights of review, say Solomon Shinerock and Annika Conrad at Lewis Baach.