International

  • February 14, 2024

    Gov't Atty Says IRS Has Authority For Failure-To-File Penalty

    Internal Revenue Code Section 6021(a) gives the IRS broad authority to assess penalties for failing to file a form mandated by Section 6038(b) on which a company reports its foreign corporations, even though that authority isn't spelled out, a government attorney told the D.C. Circuit on Wednesday.

  • February 14, 2024

    OECD Chief Claims No Knowledge Of Aussie PwC Breaches

    The OECD's top official had no knowledge of PwC Australia's breaches of confidentiality when he took equity in its former CEO's consulting firm that he relinquished when the existence of the equity became public knowledge, his spokesperson told Law360.

  • February 14, 2024

    Jury Wipes Away Texaco Heiress' $21M FBAR Penalties

    A Florida federal jury found Wednesday that the U.S. government hadn't proved a Texaco heiress willfully failed to report foreign bank account information on time, eliminating the almost $21 million in penalties assessed against her estate, according to a court filing.

  • February 14, 2024

    Tech Group Backs 3M In 8th Circ. Transfer Pricing Appeal

    A tax group representing multinational tech companies urged the Eighth Circuit to overturn a U.S. Tax Court ruling that found 3M Co. owed taxes stemming from an additional $23 million in income reallocated from its Brazilian affiliate, saying the decision wrongly upheld transfer pricing regulations that were improperly enacted.

  • February 14, 2024

    UK Top Court Rejects Jersey Co.'s £15M VAT Case

    A company based on the island of Jersey had no grounds to seek £15 million ($18.8 million) in damages from HM Treasury after the U.K. ended a value-added tax relief arrangement in what the company said was a violation of EU law, the U.K.'s Supreme Court ruled Wednesday.

  • February 14, 2024

    Cameroon Agrees To Automatic Exchange Of Tax Info

    Cameroon 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 2026, the OECD said Wednesday.

  • February 14, 2024

    EU To Remove 4 Jurisdictions From Tax Blacklist

    The European Union is scheduled to remove four jurisdictions from its list of noncooperative jurisdictions, people familiar with the matter told Law360 on Wednesday.

  • February 14, 2024

    HMRC Warns Self-Employed Taxpayers Of Scammers

    Fraudsters are likely to target people who fill in self-assessment tax returns with phishing scams promising a tax refund now that the Jan. 31 filing deadline has passed, HM Revenue and Customs warned Wednesday.

  • February 14, 2024

    EU Tax Havens Shine Because Of Pro Biz Policies, Study Says

    European tax havens differ from their Caribbean counterparts because they attract investors via a favorable combination of taxes and business policies rather than by offering zero tax rates and not cooperating with foreign tax authorities, a study has concluded.

  • February 13, 2024

    Think Tank Says US Should Undermine OECD Global Tax Deal

    The U.S. should try to undermine the OECD's global tax deal by pursuing reforms to corporate tax policy that would maximize the country's attractiveness to international investors and by cutting funding to the organization, the libertarian Cato Institute said Tuesday.

  • February 13, 2024

    Group Wants Long Phase-In Of Rules On Currency Gain, Loss

    The Internal Revenue Service should gradually phase in proposed regulations that would let taxpayers recognize foreign currency gains or losses from a business on an annual basis, the National Foreign Trade Council told the agency.

  • February 13, 2024

    Lawmakers Brace For Lobbying Blitz On Expiring Tax Breaks

    Some lawmakers foresee an increase in lobbying activity this year as Congress considers renewing parts of the GOP's 2017 tax law that are approaching expiration, while efforts to address the influence of dark money in politics remain on hold.

  • February 13, 2024

    Aussie Tax Staffers Took Part In $1.3B Refund Fraud Scheme

    An Australian Taxation Office investigation into a goods and services tax refund fraud scheme determined that it cost the country AU$2 billion ($1.29 billion) in lost revenue and that 12 ATO employees committed the fraud while working there, Australia's audit office said.

  • February 13, 2024

    Finland Car Tax Revenue Down 24% As EV Buying Jumps

    Finland's revenue from its car tax dropped 24% last year compared with 2022 thanks in part to tax-exempt electric vehicles making up a greater share of new car purchases, the Finnish Tax Administration said Tuesday.

  • February 13, 2024

    Former Italian PM Pushes European Tax Harmonization

    A former prime minister of Italy urged European Union countries to pursue more harmonization in their taxation system, arguing that taking this step would make the bloc more competitive.

  • February 13, 2024

    EU Orders Denmark To Recover Tax Break For Bridge

    The European Commission said Tuesday that special Danish tax treatment for the construction of a bridge between Denmark and Sweden was partly illegal and should be repaid, adding that Denmark would have to determine the exact amount.

  • February 13, 2024

    Andersen Announces Expansion Of Global Valuation Practice

    Professional services firm Andersen has added 14 groups across Europe to its valuation practice in the last 12 months, part of its drive to become a leading valuation provider worldwide, the company announced Tuesday.

  • February 13, 2024

    Belgian Finance Minister Wants Debate On Veto On Tax Files

    The European Union should examine whether to limit the power of individual countries to veto tax legislation, Belgium's finance minister said Tuesday, adding that member states have sometimes used the unanimity rule as a way to hold files hostage. 

  • February 12, 2024

    Aussie Gov't Eyes Limited Public Country-By-Country Reports

    Companies with significant operations in Australia would need to begin publicly reporting tax data on operations in 41 jurisdictions on a country-by-country basis under a revised proposal the government released Monday following backlash to its original proposal's global scope and exceptional requirements.

  • February 12, 2024

    IRS To Float Requirements For Tax-Free Spinoffs, Official Says

    The Internal Revenue Service is planning to propose guidance that would replace regulations floated in 2016 to clarify when corporations can undertake spinoffs and other tax-free distributions without unlawfully distributing earnings and profits, an agency official said Monday.

  • February 12, 2024

    Malta Dividend Tax Refunds Cut Expected Revenue By €1.3B

    While Malta-based companies were expected to generate roughly €1.5 billion ($1.6 billion) in taxes on their foreign-earned income in 2022, they ultimately paid just €216.6 million because of a system that lets much of those taxes be refunded, a local news agency reported Monday.

  • February 12, 2024

    UAE Signs Tax Agreements With Kuwait, Bahrain, Egypt

    The United Arab Emirates signed agreements to prevent double taxation and address other cross-border tax issues with Kuwait, Bahrain and Egypt before a summit held in Dubai, the UAE's official news agency said.

  • February 12, 2024

    EU Countries Agree To Set Aside Russia Revenues

    European Union countries formally decided Monday to identify net income from immobilized Russian state assets and move them to separate accounts to help rebuild Ukraine, though it is unclear when the money will ultimately make it to Ukraine. 

  • February 09, 2024

    Pillar 2 Shouldn't Hit 'Double Dipping' Loss Rules, CPAs Say

    The Pillar Two international minimum tax agreement should not impact U.S. rules that are designed to prevent companies from "double dipping" with a single economic loss, the American Institute of Certified Public Accountants recommended in a letter made public Friday.

  • February 09, 2024

    Colombian Court OKs Lower Thresholds For Tax Sentences

    Colombian legislation that lets the country dole out certain prison sentences based on lower monetary amounts of tax fraud or evasion was approved by the country's highest court, the Colombian tax authority said.

Expert Analysis

  • 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.

  • A Year-End Look At Florida's Capital Investment Tax Credit

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    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.

  • Understanding Discovery Obligations In Era Of Generative AI

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    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.

  • The Case For Post-Bar Clerk Training Programs At Law Firms

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    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.

  • AI Can Help Lawyers Overcome The Programming Barrier

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    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.

  • Preparing Law Students For A New, AI-Assisted Legal World

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    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.

  • General Counsel Need Data Literacy To Keep Up With AI

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    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.

  • Navigating Discovery Of Generative AI Information

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    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.

  • Finding Focus: Strategies For Attorneys With ADHD

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    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.

  • Attorneys, Law Schools Must Adapt To New Era Of Evidence

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    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.

  • 1st Tax Easement Convictions Will Likely Embolden DOJ, IRS

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    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.

  • Tips For Litigating Against Pro Se Parties In Complex Disputes

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    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.

  • Anticipating Intensified Partnership Enforcement From IRS

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    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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