International

  • April 12, 2024

    FedEx Not Entitled To $84.6M In Tax Credit Dispute, US Says

    FedEx is not entitled to a judgment of nearly $84.6 million that the company requested in March for its foreign tax credit dispute, the federal government said Friday in a Tennessee federal court filing.

  • April 12, 2024

    Adviser Urges ECJ To Toss Ad Co.'s State Aid Appeal

    An outdoor furniture and advertising company shouldn't be allowed to challenge a finding from the European Union's General Court that it should have paid rent and taxes for ads in Brussels that stayed up after its contract with the city ended, an adviser to the bloc's highest court has said.

  • April 12, 2024

    4 Takeaways From Tax Court Nix Of Easement Perpetuity Rule

    The U.S. Tax Court's scrapping of an IRS rule on the perpetuity requirements for conservation easements could draw yet more judicial scrutiny to the agency's rulemaking and shift the focus of easement disputes to how the transactions are valued. Here, Law360 examines four key takeaways from the decision.

  • April 12, 2024

    Australia Issues Outsourced IT Tax Credit Guidance

    The Australian Taxation Office provided guidance for how those making reduced input tax credit claims for complex information technology outsourcing agreements can adequately support such claims.

  • April 12, 2024

    OECD Base Erosion Project Still Percolating, Think Tank Says

    Policymakers should recognize that the Organization for Economic Cooperation and Development's tax project from roughly a decade ago to reduce base erosion and profit shifting may still be affecting companies' behavior, according to a publication released Friday from the fiscally conservative-leaning Tax Foundation.

  • April 12, 2024

    Final 'Look-Through' Rules Coming Soon, IRS Official Says

    The IRS is about to release final regulations that would, in a manner of speaking, look through the corporate owners of real estate investment entities to determine whether they are domestically controlled, an agency official said Friday.

  • April 12, 2024

    Co. Suspected Of Laundering AU$1B To Enable Tax Fraud

    Australian authorities seized AU$500,000 ($323,000) from an operation in Sydney suspected of laundering over AU$1 billion to facilitate tax fraud schemes, the authorities announced.

  • April 12, 2024

    4 Arrested In France In €60M VAT Fraud Probe

    European Union prosecutors arrested four people in western France suspected of a €60 million ($63.6 million) value-added fraud scheme involving the transfer of goods and money between several countries inside and outside the bloc, the European Public Prosecutor's Office said Friday.

  • April 12, 2024

    Denmark's £1.4B Tax Fraud Trial Heads For 'Uncharted Waters'

    Denmark will open its £1.4 billion ($1.7 billion) dividend fraud case in London on Monday, beginning a yearlong trial that will have wide implications for other disputes arising out of the cum-ex trading scandal that has swept Europe.

  • April 12, 2024

    Taxation With Representation: Freshfields, Kirkland & Ellis

    In this week's Taxation with Representation, eBay acquires Collectors' Goldin auction house, Vertex Pharmaceuticals buys Alpine Immune Sciences, Vista Equity Partners purchases Model N and Tradeweb Markets buys Institutional Cash Distributors.

  • April 12, 2024

    Countries Late On Pillar 2 Need To Catch Up, EU Official Says

    Countries within the European Union that are late implementing the global minimum tax rules need to do so soon, an official with the European Commission said Friday, adding that countries failing to do so could face fines.

  • April 11, 2024

    BlackRock Can't Deduct Interest On $4B, London Court Finds

    Financial services firm BlackRock cannot deduct interest on $4 billion in loans it used for the 2009 purchase of Barclays Global Investors because avoiding taxes was the main reason for the way it structured the transaction, a London appeals court ruled Thursday.

  • April 11, 2024

    France's Anti-Money Laundering Reports Up 15% In 2023

    France's anti-money laundering unit received 15% more reports of suspicious financial transactions in 2023 compared with 2022, continuing a trend that has resulted in a seven-fold increase in such reports over the past decade, the country's finance ministry said Thursday.

  • April 11, 2024

    Int'l Salesman Stuck With FBAR Fines For Swiss Account

    An agricultural salesman earning money in Ukraine willfully hid a Swiss bank account from the IRS that neither his accountant nor his wife knew about, a Nebraska federal judge said Thursday in upholding more than $600,000 in reporting penalties against him.

  • April 11, 2024

    Tax Controversy Quintet Joins Bradley Arant In Atlanta

    Bradley Arant Boult Cummings LLP announced that it hired a five-person tax controversy team from Chamberlain Hrdlicka White Williams & Aughtry highlighted by the addition of three experienced partners, including two former Internal Revenue Service trial attorneys.

  • April 11, 2024

    Proskauer Adds Kirkland Partner For Tax, Estate Issues

    Proskauer Rose LLP has added to its private client services department a partner from Kirkland & Ellis LLP who specializes in developing domestic and international tax and estate plans for clients with very high net worth, the firm announced.

  • April 11, 2024

    Australia Considering Build-To-Rent Tax Break Increases

    Australia is seeking public input on a plan to increase tax breaks for builders constructing rental properties in the country while also introducing conditions to qualify for those breaks.

  • April 11, 2024

    EU Parliament Advances Small Biz Single File Tax Plan

    Small businesses in the European Union would be able to file a single tax return with the administration of the business' head office instead of with every member country where the entity operates under a proposal approved by the European Parliament.

  • April 11, 2024

    Adviser Urges ECJ To Annul Nix Of UK's CFC Tax Breaks

    The European Union's General Court erred by relying on controlled foreign company rules in Great Britain when it found that U.K. corporate tax breaks were illegal, an adviser to the bloc's highest court said Thursday in urging the reversal of that ruling.

  • April 11, 2024

    OECD Plans More Guidance On Global Min. Tax, Official Says

    The Organization for Economic Cooperation and Development will issue further guidance on the global minimum corporate tax, a top official from the organization said Thursday, and another official defended a backstop provision of the minimum tax.

  • April 10, 2024

    Plastic Surgeon Owes $7.7M From Offshore Scheme, US Says

    A now-retired plastic surgeon owes the Internal Revenue Service more than $7.7 million after he ran an offshore employee leasing scheme and he and his wife transferred nearly all their assets to their then-11-year-old daughter, who is now a lawyer, the government told an Ohio federal court.

  • April 10, 2024

    Australia's Tax Office Seeks Input On Risk-Weighted Assets

    The Australian Taxation Office is seeking comments on a paper about how it measures the risk-weighted assets of a foreign bank's Australian branch when applying thin capitalization rules, the ATO announced.

  • April 10, 2024

    EU Parliament Wants Transfer Pricing Rules To Apply Sooner

    The European Parliament voted Wednesday to adopt new transfer pricing rules that would take effect one year earlier than previously planned, sending the proposal to the European Union's council of member countries for consideration.

  • April 10, 2024

    Belgium's Anticipated Green Tax Break Carries Some Doubts

    A proposal working its way through the Belgian Parliament would create opportunities for investors in green and sustainable technologies, but questions about the long-term durability of the measure, which would offer an expanded deduction for such investments, could weigh on its popularity and effectiveness.

  • April 10, 2024

    EU Gave €46B In State Aid As Tax Breaks In 2022

    European Union countries gave their companies tax breaks worth about €46 billion ($49.4 billion) in state aid in 2022, some to weather the fallout from the Ukraine war and the COVID-19 pandemic and other aid to promote infrastructure projects or environmental protection, a European Commission report said.

Featured Stories

  • 4 Takeaways From Tax Court Nix Of Easement Perpetuity Rule

    Kat Lucero

    The U.S. Tax Court's scrapping of an IRS rule on the perpetuity requirements for conservation easements could draw yet more judicial scrutiny to the agency's rulemaking and shift the focus of easement disputes to how the transactions are valued. Here, Law360 examines four key takeaways from the decision.

  • Denmark's £1.4B Tax Fraud Trial Heads For 'Uncharted Waters'

    No Photo Available

    Denmark will open its £1.4 billion ($1.7 billion) dividend fraud case in London on Monday, beginning a yearlong trial that will have wide implications for other disputes arising out of the cum-ex trading scandal that has swept Europe.

  • Swiss Bank Probe May Prompt IRS To Revive Disclosure Effort

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    Senate Finance Committee Chairman Ron Wyden's latest investigation into the Swiss banking industry may apply further pressure to federal law enforcement officials to revive a program designed to encourage taxpayers' voluntary compliance in disclosing income held overseas to the IRS.

Expert Analysis

  • Practicing Law With Parkinson's Disease

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    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.

  • 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.

  • For Lawyers, Pessimism Should Be A Job Skill, Not A Life Skill

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    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.

  • Requiring Leave To File Amicus Briefs Is A Bad Idea

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    A proposal to amend the Federal Rules of Appellate Procedure that would require parties to get court permission before filing federal amicus briefs would eliminate the long-standing practice of consent filing and thereby make the process less open and democratic, says Lawrence Ebner at the Atlantic Legal Foundation and DRI Center.

  • 4 Ways To Motivate Junior Attorneys To Bring Their Best

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    As Gen Z and younger millennial attorneys increasingly express dissatisfaction with their work and head for the exits, the lawyers who manage them must understand and attend to their needs and priorities to boost engagement and increase retention, says Stacey Schwartz at Katten.

  • Former Minn. Chief Justice Instructs On Writing Better Briefs

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    Former Minnesota Supreme Court Chief Justice Lorie Gildea, now at Greenberg Traurig, offers strategies on writing more effective appellate briefs from her time on the bench.

  • Stay Interviews Are Key To Retaining Legal Talent

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    Even as the economy shifts and layoffs continue, law firms still want to retain their top attorneys, and so-called stay interviews — informal conversations with employees to identify potential issues before they lead to turnover — can be a crucial tool for improving retention and morale, say Tina Cohen Nicol and Kate Reder Sheikh at Major Lindsey.

  • Neb. Justices Should Weigh IRC Terms In Dividend Tax Case

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    Nebraska’s highest court, which will hear oral arguments in Precision CastParts v. Department of Revenue on April 1, should recognize that the Internal Revenue Code provides key clues to defining “dividends received or deemed to be received,” and therefore limits Nebraska’s tax on foreign-sourced corporate income, says Joseph Schmidt at Ryan.

  • Judicial Independence Is Imperative This Election Year

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    As the next election nears, the judges involved in the upcoming trials against former President Donald Trump increasingly face political pressures and threats of violence — revealing the urgent need to safeguard judicial independence and uphold the rule of law, says Benes Aldana at the National Judicial College.

  • Spartan Arbitration Tactics Against Well-Funded Opponents

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    Like the ancient Spartans who held off a numerically superior Persian army at the Battle of Thermopylae, trial attorneys and clients faced with arbitration against an opponent with a bigger war chest can take a strategic approach to create a pass to victory, say Kostas Katsiris and Benjamin Argyle at Venable.

  • What Recent Study Shows About AI's Promise For Legal Tasks

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    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.

  • How FinCEN Proposal Expands RE Transaction Obligations

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    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.

  • Business Litigators Have A Source Of Untapped Fulfillment

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    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.