International
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June 07, 2024
IRS Updates EV Battery Reporting Guide For Tax Credits
The Internal Revenue Service provided updated guidance Friday for automakers planning to provide a report on meeting the battery sourcing requirements that can qualify their new electric vehicle models for the consumer tax credit of up to $7,500.
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June 07, 2024
NZ Sets Foreign Investment Interest Deemed Rate Of Return
New Zealand has set the deemed rate of return for attributing interest on foreign investment funds — one of the ways to calculate income from such sources for tax purposes — at 8.63% for the 2023-24 income year, the country's revenue agency said.
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June 07, 2024
Dentons Adds Pair Of Husch Blackwell Tax Attys
Two South Carolina tax attorneys have joined Dentons' corporate, tax and private client practice as partners after moving from Husch Blackwell LLP, the firm announced on Thursday.
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June 07, 2024
Chile Says Filing Restriction Program Stopped $203M In Fraud
Chile's tax agency said Friday that its strategy for blocking value-added tax fraud via fraudulent invoices prevented the disbursement of 186 billion Chilean pesos ($203 million) of incorrect value-added tax credits since the start of 2023 through April 2024.
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June 07, 2024
Taxation With Representation: Vinson, Latham, Ropes & Gray
In this Week's Taxation with Representation, Waste Management buys Stericycle, Becton Dickinson pays $4.2 billion for Edwards Lifesciences' critical care products unit, Aquiline Capital Partners raises over $3.4 billion in fund capital, and Bain Capital buys PowerSchool Holdings.
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June 07, 2024
Swiss Launch Consultation On Data Exchange Law
The Swiss government said Friday that it has begun a consultation on a law concerning the international exchange of salary data, which it says is needed to support laws pertaining to the taxation of cross-border workers.
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June 07, 2024
Tax Discriminates Against Risky Assets, Dutch Court Says
The Netherlands must compensate investors for a tax on investment income that discriminates against riskier assets by using calculations of fictitious returns, the Dutch Supreme Court said.
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June 06, 2024
Medtronic Urges 8th Circ. To Back Its Transfer Pricing Method
Medical device maker Medtronic reiterated Thursday its bid for the Eighth Circuit to revive its method for pricing intangible property that was licensed to a Puerto Rican affiliate, arguing the government's concessions show why the company's approach is more reliable.
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June 06, 2024
Australia Seeking Feedback On Tax Returns For Biggest Cos.
The Australian Taxation Office said it is reaching out to advisory firms and other groups about plans to introduce a supplementary goods-and-services tax form for the country's biggest companies.
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June 06, 2024
Fox Rothschild Brings On Tax Pro From Atlanta Boutique
Fox Rothschild LLP has added an attorney in Atlanta from tax law boutique Wiggam Law to strengthen the firm's taxation and wealth planning department.
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June 06, 2024
EU Must Improve Country-By-Country Reporting, Group Says
While there has been an uptick in voluntary country-by-country public disclosures, the large multinational corporations that do so make up just 2% of all large companies and account for less than 5% of global revenue and profits, necessitating further improvements, an EU-funded research group said Thursday.
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June 06, 2024
Co. Did Not Abuse UK-Ireland Tax Agreement, Tribunal Affirms
The fact that an Ireland-based company benefited from the U.K.-Ireland double-taxation agreement when it acquired an £83.5 million ($106.8 million) investment doesn't mean it entered the transaction only for tax benefits, the U.K.'s Upper Tribunal said, affirming a lower court.
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June 06, 2024
Pharma Co. Should Get Hungarian Rebate, ECJ Adviser Says
Danish pharmaceutical company Novo Nordisk's mandatory payments into the Hungarian health system should reduce the company's tax base for value-added tax payments, an adviser to the European Union's highest court said Thursday.
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June 06, 2024
Switzerland, Italy Agree To Permanent Rules For Remote Work
Switzerland and Italy have established permanent rules regarding the taxation of cross-border workers, replacing a temporary arrangement that was agreed to last year, the Swiss government said Thursday.
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June 05, 2024
Nigeria Holding US Binance Exec Hostage, Lawmakers Say
The White House's hostage negotiator should begin seeking the release of a top executive at cryptocurrency exchange Binance whom the Nigerian government is holding personally liable for tax evasion charges against the company, the House Foreign Affairs Committee's chairman has said.
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June 05, 2024
German Draft Bill Would Adjust Tax Laws To EU Rules
Changes could be coming to a number of German tax laws, including some spurred by European Union law and both national and international case law, Germany's Finance Ministry said Wednesday.
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June 05, 2024
Streamers To Be Hit With 5% Charge On Canadian Revenue
Streaming services such as Netflix and Disney+ soon will be required to contribute 5% of their Canadian revenues to the country's broadcasting system, which could generate CA$200 million ($146 million) a year, Canada's government said, drawing the ire of the National Foreign Trade Council.
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June 05, 2024
Gov't UK ISA Savings Proposal Gets Cold Shoulder
More financial firms on Wednesday warned that the U.K. government's plans to give consumers a new tax break for investing in U.K. companies was unworkable, adding it could conflict with the Financial Conduct Authority's consumer protection rules.
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June 05, 2024
EU Corp. Tax Proposal Delayed By Uncertainty On OECD Plan
European Union countries' negotiations on a proposal to streamline corporate taxation have been delayed because of a lack of clarity on implementation of the OECD's global minimum tax and the design of the accompanying reallocation of taxing rights, a top European Commission tax official said Wednesday.
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June 05, 2024
OECD Official Hopes Pillar 2 Ends Some 'Wasteful' Incentives
The introduction of the global minimum corporate tax known as Pillar Two should lead to the end of some "wasteful" incentives that narrow the tax base, an official from the Organization for Economic Cooperation and Development said Wednesday.
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June 05, 2024
Labour's Pension Tax Plans Backed By Fiscal Research Body
An influential economics think tank has backed plans by the Labour Party to reintroduce the lifetime allowance, arguing that there should be a cap on the tax-free accumulation of pensions wealth.
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June 04, 2024
Full DC Circ. Asked To Weigh Foreign Info Disclosure Penalties
A D.C. Circuit panel made questionable assumptions about congressional intent when it revived the IRS' authority to assess and administratively collect penalties related to undisclosed foreign corporations, a businessman said Tuesday in asking the full appellate court to hear his case.
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June 04, 2024
Australian Court Upholds Ex-Chinese Citizen's $7.7M Tax Bill
An Australian court upheld an AU$11.5 million ($7.7 million) tax bill from the Australian Taxation Office to a former Chinese citizen after determining he failed to provide enough evidence to support his alternative tax liability calculation.
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June 04, 2024
Calif. OTA Rejects Couple's Claim Of Bolivia Residency
A California couple owes additional state income tax on a retirement account distribution, the state Office of Tax Appeals said in an opinion released Tuesday, rejecting the pair's assertion that they were domiciled in Bolivia at the time.
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June 04, 2024
EU OKs Italian Renewable Energy Plan Funded By Levy
The European Commission said Tuesday that it approved Italy's plan to introduce a levy on the electricity bills of final consumers to fund construction of renewable energy plants, finding the benefits far outweigh any potential damage to competition and trade.
Halliburton Wrongly Denied $11.3M Deduction, Court Told
The Internal Revenue Service is arbitrarily and wrongfully refusing to refund Halliburton over $11.3 million in tax deductions taken for a payment to a foreign government to secure the safety of the company's employees, Halliburton told a federal court.
Oil Cos. Stifle Bids For Tax Transparency, SEC Letters Show
At least three oil companies have stifled proposals initiated by the nonprofit Oxfam America for public country-by-country reporting of business activities, profits and taxes this year, according to letters from the U.S. Securities and Exchange Commission obtained by Law360.
Win May Embolden IRS Use Of Economic Substance Doctrine
The IRS' successful wielding of the economic substance doctrine to characterize multinational telecommunications corporation Liberty Global's sophisticated set of intercompany deals as an abusive tax shelter could encourage the agency to apply similar analysis to even the most basic tax transactions.
Featured Stories
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Win May Embolden IRS Use Of Economic Substance Doctrine
The IRS' successful wielding of the economic substance doctrine to characterize multinational telecommunications corporation Liberty Global's sophisticated set of intercompany deals as an abusive tax shelter could encourage the agency to apply similar analysis to even the most basic tax transactions.
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New Dutch Gov't Seen Returning To Pro-Biz Positions
The incoming conservative Dutch government is expected to adopt tax policies that align with the Netherlands' long-standing reputation as a tax-friendly jurisdiction for businesses, in part by reversing a recently enacted measure that taxed companies' purchases of their own shares.
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IRS Guidance Narrows Spinoffs Available For Preapproval
Recent IRS guidance limiting the types of spinoff transactions that revenue officials will approve as tax-free ahead of time leaves practitioners and corporations to determine whether to pursue certain intercompany reorganizations without the agency's blessing.
Expert Analysis
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Fishing Makes Me A Better Lawyer
Atop the list of ways fishing makes me a better lawyer is the relief it offers from the chronic stress of a demanding caseload, but it has also improved my listening skills and patience, and has served as an exceptional setting for building earnest relationships, says Steven DeGeorge at Robinson Bradshaw.
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A Healthier Legal Industry Starts With Emotional Intelligence
The legal profession has long been plagued by high rates of mental health issues, in part due to attorneys’ early training and broader societal stereotypes — but developing one’s emotional intelligence is one way to foster positive change, collectively and individually, says attorney Esperanza Franco.
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To Make Your Legal Writing Clear, Emulate A Master Chef
To deliver clear and effective written advocacy, lawyers should follow the model of a fine dining chef — seasoning a foundation of pure facts with punchy descriptors, spicing it up with analogies, refining the recipe and trimming the fat — thus catering to a sophisticated audience of decision-makers, says Reuben Guttman at Guttman Buschner.
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Circuit Judge Writes An Opinion, AI Helps: What Now?
Last week's Eleventh Circuit opinion in Snell v. United Specialty Insurance, notable for a concurrence outlining the use of artificial intelligence to evaluate a term's common meaning, is hopefully the first step toward developing a coherent basis for the judiciary's generative AI use, says David Zaslowsky at Baker McKenzie.
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Trauma-Informed Legal Approaches For Pro Bono Attorneys
As National Trauma Awareness Month ends, pro bono attorneys should nevertheless continue to acknowledge the mental and physical effects of trauma, allowing them to better represent clients, and protect themselves from compassion fatigue and burnout, say Katherine Cronin at Stinson and Katharine Manning at Blackbird.
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How Attys Can Avoid Pitfalls When Withdrawing From A Case
The Trump campaign's recent scuffle over its bid to replace its counsel in a pregnancy retaliation suit offers a chance to remind attorneys that many troubles inherent in withdrawing from a case can be mitigated or entirely avoided by communicating with clients openly and frequently, says Christopher Konneker at Orsinger Nelson.
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Using A Children's Book Approach In Firm Marketing Content
From “The Giving Tree” to “Where the Wild Things Are,” most children’s books are easy to remember because they use simple words and numbers to tell stories with a human impact — a formula law firms should emulate in their marketing content to stay front of mind for potential clients, says Seema Desai Maglio at The Found Word.
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New Crypto Reporting Will Require Rigorous Recordkeeping
The release of a form for reporting digital asset transactions is a pivotal moment in the Internal Revenue Service's efforts to track cryptocurrency activities that increases oversight by requiring brokers to report investor sales and exchanges, say Shaina Kamen and Max Angel at Holland & Knight.
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Exploring An Alternative Model Of Litigation Finance
A new model of litigation finance, most aptly described as insurance-backed litigation funding, differs from traditional funding in two key ways, and the process of securing it involves three primary steps, say Bob Koneck, Christopher Le Neve Foster and Richard Butters at Atlantic Global Risk LLC.
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A Vision For Economic Clerkships In The Legal System
As courts handle increasingly complex damages analyses involving vast amounts of data, an economic clerkship program — integrating early-career economists into the judicial system — could improve legal outcomes and provide essential training to clerks, say Mona Birjandi at Data for Decisions and Matt Farber at Secretariat.
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A Look At New IRS Rules For Domestically Controlled REITs
The Internal Revenue Services' finalized Treasury Regulations addressing whether real estate investment trusts qualify as domestically controlled adopt the basic structure of previous proposals, but certain new and modified rules may mitigate the regulations' impact, say attorneys at Simpson Thacher.
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E-Discovery Quarterly: Recent Rulings On Text Message Data
Electronically stored information on cellphones, and in particular text messages, can present unique litigation challenges, and recent court decisions demonstrate that counsel must carefully balance what data should be preserved, collected, reviewed and produced, say attorneys at Sidley.
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Don't Use The Same Template For Every Client Alert
As the old marketing adage goes, consistency is key, but law firm style guides need consistency that contemplates variety when it comes to client alert formats, allowing attorneys to tailor alerts to best fit the audience and subject matter, says Jessica Kaplan at Legally Penned.