International
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April 05, 2024
UK Urges Delay In Claiming Pensions Until Rules Change
The U.K. tax authority has warned people to delay claiming their pensions until after Saturday, when the lifetime allowance is abolished, while the government clarifies technical changes to the legislation.
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April 05, 2024
EU Executive To Probe Complaint About Hungarian Retail Tax
The European Commission will look into a complaint it received about a Hungarian tax on the retail sector, the European Union's executive branch confirmed Friday.
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April 05, 2024
18 Crime Gangs Specialize In VAT Fraud, Europol Says
Eighteen major criminal gangs in the European Union specialize in value-added tax fraud, having end-to-end control over the entire criminal process, the EU's law enforcement agency said Friday.
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April 05, 2024
Taxation With Representation: Latham, Simpson Thacher
In this week's Taxation with Representation, Endeavor and Nuvei each go private, SLB purchases ChampionX and Liberty Media Corp. buys Dorna Sports SL.
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April 04, 2024
Snell & Wilmer Adds Former McDermott Partner In Dallas
A former McDermott Will & Emery partner and tax specialist has joined Snell & Wilmer's Dallas office to advise clients on cross-border transactions, particularly in Latin America and Mexico.
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April 04, 2024
Companies In Limbo As IRS Mulls Waiver For 15% Book Tax
Corporations preparing for their quarterly estimated taxes are uncertain about paying a 15% alternative minimum tax due on April 15, since the Internal Revenue Service granted waivers last year and has yet to release proposed regulations that officials have promised since October.
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April 04, 2024
IRS Penalties Proper In $11B Amgen Dispute, Tax Court Says
The Internal Revenue Service properly authorized penalties included in a tax bill of nearly $11 billion that drugmaker Amgen is challenging, the U.S. Tax Court said Thursday.
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April 04, 2024
Ireland Would Need Big Tax Hike For Unification, Study Says
The costs of a theoretical reunification of Northern Ireland with the rest of Ireland would be between 5% and 10% of the country's gross national income, which would likely need to be made up with a "dramatic" increase in taxes, a study released Thursday said.
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April 04, 2024
Attys Awarded $1.5M In Fees On Tax Disclosure Suit
Attorneys who won a $4.5 million settlement for a class of investors claiming a Chinese startup misrepresented its tax liability will receive their requested $1.5 million in attorney fees, a New York federal judge ruled.
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April 04, 2024
Mayer Brown Adds Former KPMG Tax Specialist In London
Mayer Brown has added a former KPMG tax professional to its London office to advise clients on asset management and fund matters in the U.S., Europe and the Middle East, the firm announced.
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April 04, 2024
Singapore Co.'s Properties Transfer Ruled Capital Transaction
The transfer of properties between a Singapore company and a related company as part of a corporate restructuring would constitute a capital transaction, the country's Inland Revenue Authority said, making the swap tax-exempt.
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April 04, 2024
Parliament Committee Delaying Vote On EU Energy Tax Law
A European Parliament committee will delay a vote on a landmark energy taxation law, as it is unclear if a majority will back the measure, a European Union source familiar with the matter told Law360 on Thursday.
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April 04, 2024
Next EU Parliament Must Eye Tax Fairness, Lawmaker Says
The new European Parliament that is elected in June must continue to work on fairness in taxation, removing tax barriers to economic growth and scrutiny of international tax policies, the outgoing chair of the parliamentary tax subcommittee said Thursday.
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April 03, 2024
IRS Says $28M In Fines Against Microsemi Adhered To Rules
The Internal Revenue Service is again pressing the U.S. Tax Court to rule that it followed supervisory approval requirements when it imposed nearly $28 million in penalties against semiconductor manufacturer Microsemi in a transfer pricing dispute.
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April 03, 2024
McDermott Adds Ex-Baker McKenzie Tax Pro In Chicago
The former chair of Baker McKenzie's Chicago tax practice group has joined McDermott Will & Emery LLP and will work as a partner in the firm's Chicago office, McDermott said Wednesday.
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April 03, 2024
Dutch Seek Input On Narrowing Plot Transfer Tax Exemption
The Netherlands is seeking input on plans to amend a rule that exempts buildings on transferred plots of land from the country's transfer tax, saying that it needs to be narrowed to just agricultural buildings in line with the exemption's intention to benefit rural areas.
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April 03, 2024
UK Seeks To Share Country-Level Tax Reports, Official Says
The U.K. government wants to allow low-income countries greater access to country-by-country reports of multinational corporations' tax data as a way to help them recover revenue that they're owed, a Cabinet official said Wednesday.
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April 03, 2024
Grading State Tax Policy And Judging The 'Dirty 30'
For the first time in a quarter-century, the Council on State Taxation, which represents the state tax interests of more than 500 multinational corporations, is led by someone who is not named Douglas L. Lindholm. Here, Law360 speaks with the organization's new president emeritus.
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April 03, 2024
Taiwan Issues Tax Relief Guidance In Wake Of Earthquake
Individuals and businesses impacted by the 7.4-magnitude earthquake that hit Taiwan on Wednesday morning are eligible for tax reductions or exemptions if their property was damaged, the country's National Taxation Bureau said.
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April 03, 2024
Greece Can Have Tax Regime On Self-Employed, EU Says
Greece has the right to introduce a standardized minimum taxable income for the self-employed, according to European Union tax commissioner Paolo Gentiloni, who said rebalancing the tax burden between big and small businesses could help reduce income inequalities.
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April 02, 2024
Swiss Banker Avoids Prison For $60M Tax Evasion Conspiracy
A Manhattan federal judge allowed a Swiss finance pro to avoid prison Tuesday for facilitating a tax evasion scheme that helped wealthy Americans hide $60 million from the IRS, saying the defendant is less culpable than alleged co-conspirators.
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April 02, 2024
South Africa Relying Less On Biz Tax As Revenues Top $115B
South Africa's total tax revenue rose to 2.155 trillion rand ($115 billion) last year, buoyed by collections of personal income tax increasing more than 8% and despite corporate income tax collections sinking nearly 9%, the South African Revenue Service said Tuesday.
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April 02, 2024
Norway Floats Tax Framework For Activities On Sea Shelf
With an increase in economic activity expected on Norway's continental sea shelf in the future, the country's Ministry of Finance said Tuesday that it wants to introduce tax liabilities on foreign companies generating income from certain activities there and is looking for public comment.
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April 02, 2024
Luxembourg's Deduction Rules Flout EU Law, Bloc Tells Court
The European Commission asked the European Union's Court of Justice to rule that Luxembourg is breaking EU law by including securitized entities among financial undertakings that are allowed deductibility of interest payments, the EU's Official Journal said Tuesday.
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April 02, 2024
Small UK Cos. 'Freed' From VAT Payments By Threshold Rise
Some 28,000 businesses have been "freed" from paying value-added tax as the registration threshold rose from £85,000 ($106,000) to £90,000 in revenue, HM Treasury has said.
Expert Analysis
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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.
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How The OECD Global Tax Proposal Could Affect M&A
Following agreement on the Organization for Economic Cooperation and Development’s Pillar Two proposal to introduce a global minimum tax, domestic implementation is expected to have a significant impact on international M&A transactions, with financial modeling, deal structuring, risk allocation and joint venture arrangements likely to be affected, say lawyers at Freshfields.
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UK Shares-Tax Proposals Offer Long-Awaited Modernization
The U.K. government's recent consultation on the introduction of a new tax on transactions in securities raises detailed legal and practical issues, but the prospect of a single digital stamp tax offering both streamlined legislation and administration will be welcomed, say Zoë Arnautov and Mark Sheiham at Simmons & Simmons.