International
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April 30, 2024
Yellen Says US Pushing To Protect R&D Credit Under Pillar 2
U.S. Treasury Department negotiators are continuing to advocate for more favorable treatment of the country's research and development tax credit under the Pillar Two global minimum tax rules, Treasury Secretary Janet Yellen told the House Ways and Means Committee on Tuesday.
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April 30, 2024
German Banker Gets 3 Years For €93M Cum-Ex Tax Evasion
A German court on Tuesday sentenced a former bank board member to three years and two months in prison for his part in a €93.4 million ($100 million) so-called cum-ex dividend tax fraud.
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April 30, 2024
HMRC Proposes Special Economic Zone Tax Relief Extensions
HM Revenue & Customs proposed Tuesday to extend the time to claim tax relief measures available in special economic zones in the U.K. to 2031 in England and to 2034 in other parts of the country.
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April 30, 2024
The Tax Angle: TCJA Teams, Dear Colleague Letters
From a look at House GOP efforts to prepare for next year's expiration of their 2017 tax overhaul to ongoing attempts by lawmakers to draw attention and support for their own tax legislation, here's a peek into a reporter's notebook on a few of the week's developing tax stories.
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April 30, 2024
Global Climate Tax Could Fund Disaster Aid, Report Says
If OECD countries adopted a tax on the extraction of fossil fuels proposed by over 100 climate organizations, $900 billion could be generated cumulatively by 2030, a majority of which would be earmarked for those hit by climate disasters, some of those groups reported.
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April 30, 2024
EU Tax System Needs To Aid Climate Policy, Accountants Say
European Union lawmakers should design a tax system in their next five-year legislative term that supports the green transition and long-term employment, a European lobby for accountants said in a document posted Tuesday.
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April 29, 2024
Court Can Make Widow Pull $2.5M From Swiss Bank, US Says
A Colorado federal court can force a widow to send $2.5 million from a Swiss bank to the U.S. to repay her late husband's penalties and interest for failing to report his foreign accounts, the U.S. told the court.
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April 29, 2024
OECD Nations Steer UN Tax Talks Toward Decision-Making
The terms of reference for a United Nations global tax convention should guide the decision-making of a committee that will negotiate substantive provisions later even though some governments prefer to defer debate on the decision-making procedures to the General Assembly, several OECD government representatives said Monday.
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April 29, 2024
Canada Opens Second R&D Tax Credit Consultation
With an additional CA$600 million ($439 million) earmarked for its scientific research and experimental development tax incentive program, Canada is looking for more specific feedback on expanding and otherwise adjusting the regime.
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April 29, 2024
Poland Pushes Back Mandatory E-Filing After Finding Flaws
Polish businesses with sales totaling more than 200 million zloty ($50 million) won't have to use the country's electronic invoice system until 2025, with the full rollout delayed until 2026, due to multiple problems uncovered in the system, the country's tax authority said.
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April 29, 2024
OECD-UN Initiative Lands Developing Countries $2.3B In Tax
A joint initiative between the Organization for Economic Cooperation and Development and the United Nations to help developing countries boost tax revenues said Monday that it has generated $2.3 billion in additional revenues and $6.05 billion in additional tax assessments since its 2015 formation.
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April 29, 2024
Ex-Man City Player Benjamin Mendy Pays £710K Tax Debt
Former Manchester City footballer Benjamin Mendy avoided bankruptcy on Monday after paying a £710,000 ($892,000) tax bill minutes before a court hearing to determine whether an order should be made.
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April 29, 2024
US Expatriations Plummet In 1st Quarter, IRS Says
The number of people who expatriated from the U.S. fell nearly 70% during the first quarter of 2024 compared with the previous quarter, the Internal Revenue Service said in a notice published Monday.
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April 29, 2024
EU Official Wants Progress On New Revenue Streams
The budget commissioner of the European Union said Monday that the bloc must make progress toward agreeing on new revenue streams that would give it more diversified sources of income.
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April 26, 2024
4 Goals For Gov'ts To Pursue In The UN Tax Convention
The United Nations' framework convention on international tax cooperation should resolve digital taxation, incorporate tax transparency conventions, seek consensus on tax allocation issues but adopt best practices by simple majority, and help fund development goals, officials and experts told Law360 as governments began negotiations Friday.
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April 26, 2024
FedEx Calls Gov't Arguments On Tax Credits Contradictory
The federal government advanced contradictory arguments in FedEx's $84.6 million foreign tax credits dispute with the Internal Revenue Service, the package delivery giant said in a filing in Tennessee federal court.
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April 26, 2024
Ireland Received Nearly €24B In Corp. Taxes In 2023
Corporations paid Ireland €23.8 billion ($25.5 billion) in taxes in 2023, a 5.3% increase over 2022, making corporate tax receipts the second-largest tax revenue generator in the country, according to the Irish revenue department.
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April 26, 2024
PwC Australia Appoints 6 Partners To Guide Scandal Rebound
PwC Australia announced that it has elected six partners to its governance board as the firm continues to attempt to rebound in the wake of its scandal involving the leak of Australian government documents.
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April 26, 2024
HMRC Says Tax Digitalization Plan Will Generate £6.4B
HM Revenue & Customs said its program to modernize U.K. tax filing is expected to generate £6.38 billion ($7.97 billion) in additional revenue through 2034 after projections last year put it at £3.9 billion.
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April 26, 2024
Poland Seeks Input On Bill To Enact Minimum Tax
Poland, one of a handful of European Union countries that have delayed implementing the Organization for Economic Cooperation and Development's Pillar Two global minimum tax plan, introduced a proposal for public comment that would enact the regime.
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April 26, 2024
Abbott Labs' $417M IRS Bill Isn't Wrong, Tax Court Told
The Internal Revenue Service denied allegations by Abbott Laboratories that it incorrectly increased the global healthcare giant's income, resulting in a $417 million tax bill, in answering Abbott's lawsuit filed with the U.S. Tax Court.
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April 26, 2024
Top EU Judge Sees Lower Court Becoming Like Tax Court
The lower court of the European Union, the General Court, will over time become a venue that specializes in some tax matters after a reform is put into place, the EU's top judge has said.
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April 26, 2024
HSBC Beats Investors' £1.3B Disney Film Scheme Fraud Case
HSBC fended off on Friday a £1.3 billion ($1.6 billion) fraud claim brought by hundreds of investors who alleged the bank misled them into financing a Disney movie tax relief scheme it developed which turned out to be worthless.
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April 25, 2024
Romanian Sanctions On Fuel Violate EU Law, Court Says
A Romanian law imposing sanctions of €77,000 ($83,000) — 21 times the usual rate of taxation — on fuel placed back into storage is so extreme it violates European Union law, the EU's top court said Thursday.
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April 25, 2024
Dutch Tax Authority Aiming To Beef Up Data Security
The Netherlands' tax authority is introducing more data protection measures based on suggestions from a KPMG report commissioned after signs of possible security threats within the tax administration, it said Thursday.
Expert Analysis
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Lessons From Country Singer's Personal Service Saga
Recent reports that country singer Luke Combs won a judgment against a Florida woman who didn’t receive notice of the counterfeit suit against her should serve as a reminder for attorneys on best practices for effectuating service by electronic means, say attorneys at Jenner & Block.
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7 E-Discovery Predictions For 2024 And Beyond
The legal and technical issues of e-discovery now affect virtually every lawsuit, and in the year to come, practitioners can expect practices and policies to evolve in a number of ways, from the expanded use of relevancy redactions to mandated information security provisions in protective orders, say attorneys at Littler.
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5 Litigation Funding Trends To Note In 2024
Over the next year and beyond, litigation funding will continue to evolve in ways that affect attorneys and the larger litigation landscape, from the growth of a secondary market for funded claims, to rising interest rates restricting the availability of capital, says Jeffery Lula at GLS Capital.
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4 Legal Ethics Considerations For The New Year
As attorneys and clients reset for a new year, now is a good time to take a step back and review some core ethical issues that attorneys should keep front of mind in 2024, including approaching generative artificial intelligence with caution and care, and avoiding pitfalls in outside counsel guidelines, say attorneys at HWG.
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What The Law Firm Of The Future Will Look Like
As the legal landscape shifts, it’s become increasingly clear that the BigLaw business model must adapt in four key ways to remain viable, from fostering workplace flexibility to embracing technology, say Kevin Henderson and Eric Pacifici at SMB Law Group.
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4 PR Pointers When Your Case Is In The News
Media coverage of new lawsuits exploded last year, demonstrating why defense attorneys should devise a public relations plan that complements their legal strategy, incorporating several objectives to balance ethical obligations and advocacy, say Nathan Burchfiel at Pinkston and Ryan June at Castañeda + Heidelman.
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Unpacking The Proposed Production Tax Credit Regulations
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.
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10 Considerations For Litigating A New York Tax Case
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.
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Law Firm Strategies For Successfully Navigating 2024 Trends
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.
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Attorneys' Busiest Times Can Be Business Opportunities
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.
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How Attorneys Can Be More Efficient This Holiday Season
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.
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How Clients May Use AI To Monitor Attorneys
Excerpt from Practical Guidance
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.
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The Pop Culture Docket: Judge D'Emic On Moby Grape
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.