International

  • April 15, 2024

    Accounting Ethics Board Issues Int'l Tax Planning Standards

    A global accounting ethics board issued Monday what it says is the first comprehensive suite of global standards on ethical considerations in tax planning and related services in hopes of restoring public trust in accounting firms and corporations.

  • April 15, 2024

    HMRC Maintaining VAT Policies After EU Law Decoupling

    The interpretation of the U.K.'s value-added tax and excise tax regimes have remained the same despite the removal of the supremacy of the European Union's laws at the beginning of the year, HM Revenue & Customs said Monday.

  • April 15, 2024

    More EU Cooperation Needed Against VAT Fraud, Official Says

    The €11 billion ($11.7 billion) in value-added tax fraud uncovered in 2023 by the European Union's prosecution office is probably "only the tip of an iceberg" and should prompt countries to intensify joint cooperation, the office's top official said.

  • 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

    Panama Papers Attys Deny Money Laundering At Trial

    Two attorneys who ran the Mossack Fonseca law firm in Panama, at the center of a 2016 leak that produced multiple convictions for tax evasion, pled not guilty with 27 others to money-laundering charges as a trial began in Panama, according to prosecutors.

  • 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

    Swiss Bank Probe May Prompt IRS To Revive Disclosure Effort

    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.

  • 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.

Expert Analysis

  • 4 PR Pointers When Your Case Is In The News

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    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.

  • Unpacking The Proposed Production Tax Credit Regulations

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    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.

  • 10 Considerations For Litigating A New York Tax Case

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    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.

  • Law Firm Strategies For Successfully Navigating 2024 Trends

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    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.

  • Attorneys' Busiest Times Can Be Business Opportunities

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    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.

  • How Attorneys Can Be More Efficient This Holiday Season

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    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.

  • How Clients May Use AI To Monitor Attorneys

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    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.

  • The Pop Culture Docket: Judge D'Emic On Moby Grape

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    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.

  • Breaking Down High Court's New Code Of Conduct

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    The U.S. Supreme Court recently adopted its first-ever code of conduct, and counsel will need to work closely with clients in navigating its provisions, from gift-giving to recusal bids, say Phillip Gordon and Mateo Forero at Holtzman Vogel.

  • Legal Profession Gender Parity Requires Equal Parental Leave

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    To truly foster equity in the legal profession and to promote attorney retention, workplaces need to better support all parents, regardless of gender — starting by offering equal and robust parental leave to both birthing and non-birthing parents, says Ali Spindler at Irwin Fritchie.

  • A Year-End Look At Florida's Capital Investment Tax Credit

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    Notwithstanding the Walt Disney Co.’s feud with Gov. Ron DeSantis this year, Florida's capital investment tax credit will continue to make the state a favored destination for large corporations, particularly in light of the new federal alternative minimum tax and the Pillar Two top-up tax, says Alan Lederman at Gunster.

  • Understanding Discovery Obligations In Era Of Generative AI

    Excerpt from Practical Guidance
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    Attorneys and businesses must adapt to the unique discovery challenges presented by generative artificial intelligence, such as chatbot content and prompts, while upholding the principles of fairness, transparency and compliance with legal obligations in federal civil litigation, say attorneys at King & Spalding.

  • The Case For Post-Bar Clerk Training Programs At Law Firms

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    In today's competitive legal hiring market, an intentionally designed training program for law school graduates awaiting bar admission can be an effective way of creating a pipeline of qualified candidates, says Brent Daub at Gilson Daub.

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