International

  • April 25, 2024

    OECD Consolidates Past Pillar 2 Guidance Into Single Doc

    The Organization for Economic Cooperation and Development published administrative guidance Thursday that consolidates past publications on the interpretation and application of the international minimum tax agreement known as Pillar Two, which countries began implementing this year.

  • April 25, 2024

    EU Parliament Gives Final Approval To AML Package

    The European Parliament has given the final go-ahead to a package of laws to fight money laundering and terrorist financing, creating a single rule book and establishing a dedicated agency for the bloc.

  • April 25, 2024

    Ministers From 4 Countries Back Billionaire Tax

    Government ministers from Germany, Spain, South Africa and Brazil said Thursday that they have backed a global plan to ensure that billionaires pay a minimum amount of tax, arguing that the move is necessary to make the tax system more equitable.

  • April 24, 2024

    EU Court Won't Disturb Spanish Tax Break Rulings

    A Spanish company on Wednesday lost its attempt to legitimize a tax scheme declared illegal by the European Commission when the European Union's General Court rejected its appeal, refusing to disturb prior decisions in the long-running dispute.

  • April 24, 2024

    GOP Reps Seek IRS Nonprofit Info After China Reports

    House Ways and Means Republicans asked the Internal Revenue Service to provide information about how it monitors tax-exempt organizations for possible violations of their status after reports China may be funding and improperly influencing nonprofits, according to a letter sent Wednesday.

  • April 24, 2024

    Treasury Limits Reach Of Look-Through Rule In Final Regs

    The U.S. Treasury Department finalized regulations Wednesday that retain but narrow the scope of a proposal to, in a manner of speaking, look through the corporate owners of real estate investment entities to determine whether they are domestically controlled.

  • April 24, 2024

    Tax Pros Suggest How HMRC Can Assess Digitalization Effort

    HM Revenue & Customs should abide by a set of benchmarks when evaluating tests of its digitalization program for income tax self-assessment forms, two groups representing U.K. tax professionals said.

  • April 24, 2024

    Ex-England Footballer Banned As Director For Unpaid Tax

    Former England football international John Barnes has been banned from being a company director after his business failed to pay more than £190,000 ($236,000) in tax, a U.K. government agency announced on Wednesday.

  • April 24, 2024

    Papua New Guinea Commits To Automatic Tax Info Exchange

    Papua New Guinea has committed to enacting the Organization for Economic Cooperation and Development's standard for automatic exchange of financial account information in tax matters by September 2027, the OECD said Wednesday.

  • April 24, 2024

    EU Keeps Gibraltar, Panama, UAE On AML Blacklist

    Gibraltar, Panama and the United Arab Emirates should remain on the European Union's blacklist of high-risk countries for money laundering, the European Parliament said, stopping the EU from following the lead of a global organization promoting standards for countries to fight those crimes.

  • April 24, 2024

    EU Expected To OK Withholding Tax, Digital VAT Laws In May

    European Union finance ministers are expected to agree on a new withholding tax refund law and a package to modernize value-added tax reporting at their May 14 meeting, an EU official said Wednesday, speaking on the condition of anonymity.

  • April 24, 2024

    EU Says 3 States Aren't Correctly Following AML Law

    The European Commission said Wednesday that three European Union countries — Ireland, France and Latvia — aren't correctly implementing the bloc's laws against money laundering, meaning that the countries now have two months to correct the shortcomings.

  • April 23, 2024

    Treasury Says Aussie Royalty Ruling Contradicts US, OECD

    Australia's updated draft ruling regarding when payments for the rights to distribute software would be considered royalties conflicts with OECD and U.S. standards on the treatment of such deals, a U.S. Department of the Treasury official said in a letter made public Tuesday.

  • April 23, 2024

    Biz Ownership Law Constitutional, Lawmakers Tell 11th Circ.

    The Corporate Transparency Act is a garden-variety exercise of Congress' powers to address threats to national security, foreign affairs, commerce and tax collection, five Democratic lawmakers told the Eleventh Circuit, disputing a ruling that the law is unconstitutional.

  • April 23, 2024

    DC Circ. Backs Tax Penalties Against Swiss Couple

    A Swiss couple who incurred $500,000 in penalties for failing to report millions of dollars they held in Swiss bank accounts can't get out of paying, the D.C. Circuit ruled Tuesday, rejecting their argument that the IRS didn't properly approve the fines.

  • April 23, 2024

    Int'l Pricing Pact Guidance Is Coming Soon, IRS Official Says

    Updated Internal Revenue Service guidance that would help multinational corporations pursue advance pricing agreements will likely be released in a few months, an agency official said Tuesday.

  • April 23, 2024

    Disney, IBM Stuck With Tax On Royalties, NY Top Court Holds

    New York's highest court rejected Disney and IBM's arguments that the state unconstitutionally denied their attempts to take tax deductions on royalties received from foreign affiliates, holding Tuesday that the law at issue didn't discriminate against interstate commerce.

  • April 23, 2024

    EV Levy Could Blunt Swiss Climate Plan Pains, Report Says

    The first report on the long-term fiscal impact of climate change mitigation measures in Switzerland, released Tuesday, projects a major negative impact on public funds as certain tax sources dry up, but a planned replacement levy on electric vehicles could lessen that effect.

  • April 23, 2024

    Irish Minister Warns Corp. Tax Windfall Still Shrouds Deficit

    Ireland's budget is projected to have an €8.6 billion ($9.2 billion) surplus this year, but the country's finance minister again cautioned Tuesday that without the slowly decreasing windfall corporate tax receipts there would actually be a deficit.

  • April 23, 2024

    Tax Experts Want Cut To Healthcare Insurance Levy

    Tax experts on Tuesday urged the U.K. government to partially suspend a levy on healthcare insurance products, after it revealed record premium tax revenue of £8.1 billion ($10.1 billion) last year.

  • April 23, 2024

    Talk Of Int'l Wealth Tax Fuels Debate On UN Vs. OECD

    Discussion of an international tax on the world's wealthiest individuals has intensified a debate about whether international tax policy would be better steered by the Organization for Economic Cooperation and Development or the United Nations.

  • April 23, 2024

    EU Parliament OKs Extending Duty-Free Imports From Ukraine

    The European Parliament approved the suspension of the European Union's customs duties and quotas on Ukrainian imports into the EU for one year until June 2025 on Tuesday, overcoming discord in March over farm imports that threatened the deal.

  • April 22, 2024

    Scotiabank Fights To Keep Peru VAT Claim Alive

    The Bank of Nova Scotia urged the World Bank's international arbitration institution in recently released documents not to dismiss the arbitration of its value-added tax dispute against Peru, saying the case raises issues of fact.

  • April 22, 2024

    Congress Can Enact Corp. Transparency, Orgs Tell 11th Circ.

    Congress is empowered to require American companies to report their beneficial owners to the federal government because there is ample evidence they've previously been used to fund hostile foreign actors, evade sanctions and traffic drugs, two think tanks told the Eleventh Circuit in an amici brief.

  • April 22, 2024

    Partnership Can't Claim $22.7M Loss, Tax Court Says

    The U.S. Tax Court on Monday upheld the IRS' decision to deny a $22.7 million loss deduction claimed by a Connecticut partnership, finding that underlying transactions involving a bankrupt Brazilian company's debt obligations amounted to a disguised property sale.

Expert Analysis

  • 7 E-Discovery Predictions For 2024 And Beyond

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    The legal and technical issues of e-discovery now affect virtually every lawsuit, and in the year to come, practitioners can expect practices and policies to evolve in a number of ways, from the expanded use of relevancy redactions to mandated information security provisions in protective orders, say attorneys at Littler.

  • 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

    Excerpt from Practical Guidance
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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.

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