International
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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).
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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.
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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.
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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.
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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.
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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.
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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.
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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.
Expert Analysis
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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.
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The Pop Culture Docket: Judge Espinosa On 'Lincoln Lawyer'
The murder trials in Netflix’s “The Lincoln Lawyer” illustrate the stark contrast between the ethical high ground that fosters and maintains the criminal justice system's integrity, and the ethical abyss that can undermine it, with an important reminder for all legal practitioners, say Judge Adam Espinosa and Andrew Howard at the Colorado 2nd Judicial District Court.
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How And Why Your Firm Should Implement Fixed-Fee Billing
Amid rising burnout in the legal industry and client efforts to curtail spending, pivoting to a fixed-fee billing model may improve client-attorney relationships and offer lawyers financial, logistical and stress relief — while still maintaining profit margins, say Kevin Henderson and Eric Pacifici at SMB Law Group.
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How Law Firms Can Use Account-Based Marketing Strategies
Amid several evolving legal industry trends, account-based marketing can help law firms uncover additional revenue-generating opportunities with existing clients, with key considerations ranging from data analytics to relationship building, say Jennifer Ramsey at stage LLC and consultant Gina Sponzilli.
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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.