International

  • 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.

  • 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. 

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.     

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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).

  • 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.

  • 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.

  • 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.

  • 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.

  • April 17, 2024

    Swedish Bank Tax Not A State Aid Violation, EU Court Affirms

    A Swedish banking tax does not run afoul of the European Union's rules on state aid, the EU's lower court said Wednesday, dismissing a bid by the country's banking lobby to annul the European Commission's approval of the measure.

  • April 16, 2024

    Corp. Transparency Act A Valid Use Of Powers, 11th Circ. Told

    The U.S. Department of Treasury told the Eleventh Circuit that a federal district court erred in finding the Corporate Transparency Act unconstitutional, saying the lower court misunderstood the law's scope and relation to efforts to curb financial crime.

Expert Analysis

  • 5 Litigation Funding Trends To Note In 2024

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    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.

  • 4 Legal Ethics Considerations For The New Year

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    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.

  • What The Law Firm Of The Future Will Look Like

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    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.

  • 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.

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