International
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April 16, 2024
Canada Expects Digital Tax To Increase Revenue By CA$5.9B
Canada's proposed digital services tax is estimated to bring in CA$5.9 billion ($4.3 billion) over five years, according to the country's 2024 budget, which was released Tuesday and cited continued international delays in implementing a worldwide profit reallocation agreement.
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April 16, 2024
Veteran's Signature On IRS Doc Not Forged, Tax Court Finds
U.S. Air Force veteran and his wife failed to convince the U.S. Tax Court on Tuesday that their signatures were forged on an agreement to pay federal income taxes while working in Australia for defense contractor Raytheon.
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April 16, 2024
3 Key Takeaways From The IRS' Latest Pricing Pact Snapshot
The IRS finalized a record number of advance pricing agreements in 2023, signaling the agency's increased effectiveness at completing accords at a time when its approach to transfer pricing litigation could fuel corporate taxpayers' urgency for seeking APAs. Here, Law360 breaks down three key takeaways from the agency’s latest APA report.
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April 16, 2024
Orrick Adds Former Hogan Lovells Atty To German Tax Group
Orrick Herrington & Sutcliffe LLP added a former Hogan Lovells counsel to its German tax group, the firm announced.
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April 16, 2024
McDermott Hires 2 Partners For Global Tax Practice In Paris
McDermott Will & Emery is expanding its global tax practice group with two partners in Paris who have a track record of advising on cross-border mergers and acquisitions and tax controversies before France's tax authority, the firm announced.
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April 16, 2024
Finland's Boost In Financial Crimes Led To $156M In Damage
A record nearly 2,400 financial crimes reported to Finland's authorities in 2023 — with 54% of them debtor crimes and tax and accounting crimes — resulted in €147 million ($156 million) in criminal damage, the Finnish Tax Administration said Tuesday.
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April 16, 2024
Global Economic Growth To Remain Slow, Steady, IMF Says
The global economy has been "surprisingly resilient" in its bounce back from widespread troubles, leading to projections of a slow but steady 3.2% growth continuing through this year and the next, the International Monetary Fund said in its annual report Tuesday.
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April 16, 2024
Treasury Gains £12B Fiscal Headroom In New Tax Year
HM Treasury may have an extra £12 billion ($14.9 billion) to spend this financial year started April 6 thanks to the government's fiscal rule to cut national debt by 2029, the Institute for Fiscal Studies said in a report Tuesday.
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April 16, 2024
Taylor Wessing Launches Ireland Tax Practice With New Hire
Taylor Wessing LLP has recruited its first tax partner in Ireland from Simmons & Simmons LLP to launch a new tax group in the country, continuing its expansion after initially setting up shop in Dublin three years ago.
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April 16, 2024
EU Leaders Expected To Clash Over Corp. Tax Harmonization
European Union leaders are expected to clash at their summit Wednesday and Thursday over whether national corporate taxes should be harmonized to promote equity investments, an official from the bloc said Tuesday.
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April 15, 2024
Exxon Seeks $1.8B Tax Refund As Qatar Deal Trial Opens
Exxon Mobil Corp. argued Monday in Texas federal court that its deal with Qatar to extract natural gas from the country's coast was a partnership, rather than a lease agreement, saying at the start of a trial that it's entitled to get $1.8 billion in tax benefits back from the IRS.
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April 15, 2024
House OKs Ending Exemption For Terrorist-Supporting Orgs
The House passed legislation Monday that would authorize the Internal Revenue Service to suspend the tax-exempt status of any nonprofit organization found by the U.S. Treasury secretary to support foreign terrorism.
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April 15, 2024
8th Circ. Urged To Revive IRS' Pricing For Medtronic
The U.S. government urged the Eighth Circuit on Monday to side with the IRS' method for pricing the intangible property that medical device maker Medtronic licensed to a Puerto Rican affiliate, arguing it's the only way to determine arm's-length royalty rates.
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April 15, 2024
EU Seeking Input On Tax Cooperation Program's Progress
The European Commission is looking for input from the tax administrations of the European Union and cooperating countries on the efficacy of a program meant to aid in the fight against tax fraud, tax evasion and aggressive tax planning, it said Monday.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
Expert Analysis
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A Year-End Look At Florida's Capital Investment Tax Credit
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.
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Understanding Discovery Obligations In Era Of Generative AI
Excerpt from Practical Guidance
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.
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The Case For Post-Bar Clerk Training Programs At Law Firms
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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AI Can Help Lawyers Overcome The Programming Barrier
Legal professionals without programming expertise can use generative artificial intelligence to harness the power of automation and other technology solutions to streamline their work, without the steep learning curve traditionally associated with coding, says George Zalepa at Greenberg Traurig.
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Preparing Law Students For A New, AI-Assisted Legal World
As artificial intelligence rapidly transforms the legal landscape, law schools must integrate technology and curricula that address AI’s innate challenges — from ethics to data security — to help students stay ahead of the curve, say Daniel Garrie at Law & Forensics, Ryan Abbott at JAMS and Karen Silverman at Cantellus Group.
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General Counsel Need Data Literacy To Keep Up With AI
With the rise of accessible and powerful generative artificial intelligence solutions, it is imperative for general counsel to understand the use and application of data for myriad important activities, from evaluating the e-discovery process to monitoring compliance analytics and more, says Colin Levy at Malbek.
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Navigating Discovery Of Generative AI Information
As generative artificial intelligence tools become increasingly ubiquitous, companies must make sure to preserve generative AI data when there is reasonable expectation of litigation, and to include transcripts in litigation hold notices, as they may be relevant to discovery requests, say Nick Peterson and Corey Hauser at Wiley.
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Finding Focus: Strategies For Attorneys With ADHD
Given the prevalence of ADHD among attorneys, it is imperative that the legal community gain a better understanding of how ADHD affects well-being, and that resources and strategies exist for attorneys with this disability to manage their symptoms and achieve success, say Casey Dixon at Dixon Life Coaching and Krista Larson at Stinson.
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Attorneys, Law Schools Must Adapt To New Era Of Evidence
Technological advancements mean more direct evidence is being created than ever before, and attorneys as well as law schools must modify their methods to account for new challenges in how this evidence is collected and used to try cases, says Reuben Guttman at Guttman Buschner.
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1st Tax Easement Convictions Will Likely Embolden DOJ, IRS
After recent convictions in the first criminal tax fraud trial over allegedly abusive syndicated conservation easements, the IRS and U.S. Department of Justice will likely pursue other promoters for similar alleged conspiracies — though one acquittal may help attorneys better evaluate their clients' exposure, say Bill Curtis and Lauren DeSantis-Then at Polsinelli.
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Tips For Litigating Against Pro Se Parties In Complex Disputes
Litigating against self-represented parties in complex cases can pose unique challenges for attorneys, but for the most part, it requires the same skills that are useful in other cases — from documenting everything to understanding one’s ethical duties, says Bryan Ketroser at Alto Litigation.
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Anticipating Intensified Partnership Enforcement From IRS
The Internal Revenue Service's decadeslong difficulties with partnership audits led to the recent announcement of a clear, well-funded, focused initiative, and businesses operating in the partnership form will feel the impact, with definite changes ahead, says Sharon Katz-Pearlman at Greenberg Traurig.
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Pro Bono Work Is Powerful Self-Help For Attorneys
Oct. 22-28 is Pro Bono Week, serving as a useful reminder that offering free legal help to the public can help attorneys expand their legal toolbox, forge community relationships and create human connections, despite the challenges of this kind of work, says Orlando Lopez at Culhane Meadows.