International
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April 19, 2024
India Signs Record Amount Of Advance Pricing Agreements
India's Central Board of Direct Taxes entered into a record 125 advance pricing agreements with Indian taxpayers in fiscal year 2023-24, a 31% increase compared with the previous year, the authority said.
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April 19, 2024
Taxation With Representation: Kirkland, Cleary, O'Melveny
In this week's Taxation With Representation, Resideo Technologies Inc. announced plans to buy Snap One Holdings Corp., APi Group said it bought an elevator maintenance company, Prysmian said it agreed to purchase Encore Wire, and Sayari said it closed on an investment from TPG.
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April 19, 2024
Questions Loom Over China's Pillar 2 Participation
Practical and political problems surrounding the Organization for Economic Cooperation and Development's 15% global minimum corporate tax raise questions about how China and its biggest companies could undermine that regime.
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April 19, 2024
EU Official Pushes Automatic Exchange Of Ownership Data
The automatic exchange of companies' beneficial ownership information would be a powerful tool for tax authorities and should be a future goal for governments, a senior European Union tax official said Friday.
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April 18, 2024
Estonian Tax System's Ease Key To Success, Bank Head Says
The tax system in Estonia — ranked the top country for international tax competitiveness by the Tax Foundation — is fair and easy to administer, which is key to the country's tax administration successes, the governor of the Bank of Estonia said Thursday.
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April 18, 2024
AbbVie Can't Get Deduction For $1.6B Merger Fee, IRS Says
The IRS defended its denial of AbbVie's claimed deduction for a $1.6 billion payment to a biotechnology company over their failed merger, telling the U.S. Tax Court that the pharmaceutical giant is misconstruing an underlying statute to challenge the agency's decision.
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April 18, 2024
IRS Updates Rates For Foreign Insurance Company Equations
The Internal Revenue Service published updated domestic asset/liability and yields percentages Thursday that foreign life insurance companies as well as foreign property and liability insurance companies need to compute their minimum effectively connected net investment income for tax years starting in 2023.
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April 18, 2024
Pawn Shop Owes VAT On Auction Sales, EU Court Says
A Portuguese pawn shop must pay value-added taxes of €308,000 ($327,000) from sales commissions of auctioned items because the auction is not part of the exempt loan, the Court of Justice of the European Union said Thursday.
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April 18, 2024
EU Split Stops Move Toward Corporate Tax Harmonization
A group of smaller European Union countries stopped a move toward harmonization of national corporate taxes when EU leaders met Thursday to discuss ways to promote investments in European businesses.
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April 18, 2024
$32B More In Tax Yielded In Fiscal '23 Closed Audits, IRS Says
The Internal Revenue Service closed nearly 583,000 tax return audits in fiscal year 2023, resulting in $31.9 billion of recommended additional tax after examination, the agency said Thursday in its annual data book.
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April 18, 2024
Tax Deadline Near For Irish Corporate Warehoused Debt
Companies in Ireland taking advantage of the country's debt warehousing regime are encouraged to meet with the tax department ahead of a May 1 deadline to arrange agreements to pay off their liabilities, the country's finance minister said.
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April 18, 2024
HMRC Opens Consultation On Payroll Tax In Freeports
The U.K. tax authority is mulling changes to National Insurance, a payroll levy used to fund state pensions and healthcare, for employees working in special economic zones known as freeports.
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April 18, 2024
Transfer Pricing And Dancing: Recalling KPMG's Sean Foley
Sean Foley, who died suddenly in September, was a devoted husband, father, brother and friend and a brilliant colleague. He was one of the world's top experts in an area of international tax known as transfer pricing, where he became the global leader of KPMG's practice.
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April 18, 2024
UN Tax Work Should Be Consensus-Driven, EU Official Says
The work on international taxation at the United Nations should be driven by consensus, as otherwise, whatever agreement comes out of the process won't be accepted globally, a senior European Union tax official said Thursday.
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April 17, 2024
EV Tax Credit Restrictions, Trade Bills Advance In House
The House Ways and Means Committee advanced several trade bills Wednesday that would impose more restrictions for new electric vehicles to qualify for a federal tax credit, assert congressional authority in agreements with foreign governments, and renew the country's largest and oldest trade preferences program.
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April 17, 2024
Gov't Officials Urge Global Cooperation On Taxing Wealth
Global cooperation on taxing the wealthiest individuals and companies is necessary to address climate change and create social justice, government officials from Brazil, France and Nigeria said Wednesday at the International Monetary Fund's spring meeting.
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April 17, 2024
Swedish Tax Investigations Add $90M To Crypto Miners' Bills
Investigations revealed that a number of cryptocurrency mining centers in Sweden misrepresented their business dealings, which led to the Swedish Tax Agency doling out a total of 990 million Swedish krona ($90 million) in increased tax liabilities, the agency said Wednesday.
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April 17, 2024
Consensus Key To UN Tax Progress, Developing Nations Say
Achieving consensus is important to ensure progress on the United Nations framework convention on tax, the top group for developing countries to coordinate on financial policy said in a formal statement.
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April 17, 2024
Aussie Tax Office Misses Transfer Pricing Review Goals
In each of the past two years, the Australian Taxation Office came up short of its goal to review every use of transfer pricing for related party debt made by entities included in two major economic categories, a government audit revealed Wednesday.
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April 17, 2024
Johnston Carmichael Adds Ex-Alvarez Tax Pro In Glasgow
U.K. accounting and business advisory firm Johnston Carmichael has recruited an accountant from Alvarez & Marsal to work as a financial services tax partner in its Glasgow office.
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April 17, 2024
Canada Proposes Top-End Tier To Boost Capital Gains Tax
Canada's government is seeking to introduce a new tier to its capital gains tax regime, increasing the portion of gains on which tax is paid to two-thirds from the current 50% for any capital gains more than CA$250,000 ($182,000).
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April 17, 2024
Judge Delays Trial Over $20M Allegedly Hidden From IRS
A Florida federal judge agreed Wednesday to delay the trial of a Brazilian-American businessman accused of hiding $20 million from the Internal Revenue Service by using Swiss bank accounts, but told the defendant the new deadlines are firm.
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April 17, 2024
Loeb & Loeb Adds 2 Corporate Partners From Morrison Cohen
Loeb & Loeb LLP has announced the latest in a string of corporate hires from Morrison Cohen LLP's ranks, touting two new partners with domestic and international experience with strategic transactions.
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April 17, 2024
Tax Incentives Needed To Boost EU Investments, Adviser Says
European Union countries must give tax incentives to boost long-term savings plans for individuals and institutions in an effort to gather capital for investment in businesses, a top adviser said Wednesday.
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April 17, 2024
EU To Start Review Of Disclosure Laws In May, Official Says
The European Commission plans to launch a review of some parts of its landmark tax disclosure legislation in May, a senior tax official said Wednesday, suggesting the body is open to simplifying the law.
Expert Analysis
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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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Business Litigators Have 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.
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Cayman Islands Off AML Risk Lists, Signaling Robust Controls
As a world-leading jurisdiction for securitization special purpose entities, the removal of the Cayman Islands from increased anti-money laundering monitoring lists is a significant milestone that will benefit new and existing financial services customers conducting business in the territory, say lawyers at Walkers Global.