International

  • February 09, 2024

    6th Circ. Backs Fine Against Doctor For Willful FBAR Violation

    A Michigan doctor clearly met the standard for a willful failure to file reports of foreign bank accounts, the Sixth Circuit said, confirming a lower court decision resulting in a $930,000 penalty against him.

  • February 09, 2024

    PwC Australia Probes Ex-CEO Under Fire In Aussie Senate

    PwC Australia is investigating claims that its former CEO had corrupt dealings with politicians, based on a whistleblower complaint shared with Law360 on Friday, as Australian senators said the firm snubbed Parliament by withholding a review into partners improperly sharing confidential drafts of tax laws.

  • February 09, 2024

    HMRC Seeking Input On New R&D Tax Relief Guidance

    HM Revenue & Customs asked Friday for the public to weigh in on guidance that would accompany changes to the U.K.'s research and development tax relief rules in preparation for the pending passage of the latest finance bill.

  • February 09, 2024

    Polish Co. Found Exploiting Exemption Pays $5M, Gov't Says

    A Polish real estate company paid over 20 million zloty ($5 million) in owed corporate income taxes after an audit revealed it was illegally taking advantage of an exemption from collecting and paying withholding tax, Polish tax authorities said Friday.

  • February 09, 2024

    Import Carbon Fee Having Positive Effect, EU Tax Chief Says

    A European Union program to charge a fee on imported goods entering the bloc from areas with weaker environmental rules is already having a positive impact, EU tax commissioner Paolo Gentiloni said Friday.

  • February 09, 2024

    Taxation With Representation: Sullivan & Cromwell, Kirkland

    In this week's Taxation With Representation, California Resources Corp. acquires Aera Energy, ZeroFox Holdings goes private, and Acerinox purchases Haynes International.

  • February 08, 2024

    3M Tells 8th Circ. IRS Used Invalid Regs To Allocate Income

    Multinational conglomerate 3M urged the Eighth Circuit to reverse a U.S. Tax Court decision upholding regulations that the IRS had used to disregard Brazilian legal restrictions when allocating the company's income, contending that the rules contravene an underlying transfer pricing statute.

  • February 08, 2024

    Neb. Justices To Hear Berkshire Unit's Repatriation Tax Fight

    The Nebraska Supreme Court agreed Thursday to directly review a Berkshire Hathaway entity's appeal of a district court's finding that the state's deduction for certain dividends doesn't apply to income repatriated under the 2017 federal tax overhaul.

  • February 08, 2024

    US Grantor Trusts Need Int'l Reporting Clarity, Treasury Told

    The U.S. Treasury Department should clarify that domestic grantor trusts aren't required to file international information returns, the American Institute of Certified Public Accountants said in a letter made public Thursday, claiming that current uncertainty has led to redundant reporting.

  • February 08, 2024

    German Court Convicts First In €80M Luxury Car VAT Fraud

    A German notary has become the first person convicted by a Berlin court for his role in what the European Public Prosecutor's Office said was an €80 million ($86.2 million) value-added tax fraud scheme involving luxury cars and medical face masks.

  • February 08, 2024

    DC Circ. Skeptical Of 5-Hour Energy Partner's Tax Challenge

    D.C. Circuit judges seemed skeptical of a Canadian citizen's argument that $6.5 million in gains she received from selling a share of a U.S. partnership that sold 5-Hour Energy drinks shouldn't be federally taxed, grappling to understand her reasoning during oral arguments Thursday.

  • February 08, 2024

    Ecuador Considering Smaller VAT Hike To Fund Crime Fight

    Ecuador's president introduced a proposal for a smaller, permanent value-added tax hike after his initial push for a larger but temporary increase, which he said would help fund the country's fight against organized crime, was voted down.

  • February 08, 2024

    Estonia Moves To Implement Two Late EU Tax Laws

    The Estonian government took a step Thursday to put in place two European Union-wide tax measures that it has been tardy in putting into national law, a news release from the country's Finance Ministry said.

  • February 08, 2024

    Idaho Woman Contests Lien Over Foreign Tax Form

    The Internal Revenue Service cannot unilaterally impose penalties for failing to timely file a tax form for U.S. citizens involved with certain foreign corporations, an Idaho woman told a federal court, asking it to declare invalid a $350,000 lien placed on her family home.

  • February 07, 2024

    IRS Memo Highlights Tensions In Arm's-Length Loan Pricing

    A recent IRS advice memorandum disregards certain details about affiliated companies when treating them as unrelated businesses for the purpose of pricing an intercompany loan, raising questions about how the arm's-length standard should apply to corporate group financing arrangements.

  • February 07, 2024

    US, Telecom Co. Disagree On Taxes Owed In $283M Suit

    The federal government and a telecommunications company remain at odds over how much tax is owed following a ruling in a different case that the company wasn't entitled to a $109 million refund because it exploited a tax loophole, a Colorado federal judge heard Wednesday.

  • February 07, 2024

    US Eyes Requiring Reports On All-Cash Real Estate Transfers

    Professionals involved in real estate transfers in the U.S. would be required to report on the beneficial owners of trusts and other legal entities that receive residential property in any all-cash transactions under draft regulations released Wednesday that aim to tackle tax evasion and corruption.

  • February 07, 2024

    Iceland's Tax Break For Startup Stock Cleared By Trade Body

    An Icelandic measure that will offer a more favorable tax rate for share option profits by employees of research and development startup companies won approval Wednesday from a European trade body.

  • February 07, 2024

    Dutch Gov't Says €11.5B In COVID-Deferred Tax Still Unpaid

    Dutch business owners still owe €11.5 billion ($12.4 billion) in tax out of the €47.7 billion that was allowed to be deferred under a COVID-19 pandemic relief program, the Netherlands' government said Wednesday.

  • February 07, 2024

    Big 4 Support Irish Foreign Income Tax Exemption Plans

    The Big Four accounting firms expressed broad support for Ireland's plans to introduce corporate tax exemptions for foreign-sourced dividends and foreign branch profits, saying the changes are long overdue and would reduce complexities for taxpayers, according to comments published Wednesday.

  • February 07, 2024

    German Cum-Ex Trial Ends After €2.2M Profit Payback

    German prosecutors agreed to provisionally end a trial of an unnamed individual over a fraudulent tax refund scheme after he agreed to pay back €2.2 million ($2.4 million) in illegally gained profits, a court said Wednesday.

  • February 07, 2024

    EU Urges Greece To Scrap Tax-Free Border Shops

    The European Commission called on Greece on Wednesday to remove an exemption from excise duty for shops on borders with non-European Union countries, saying the shops' untaxed status breached EU law.

  • February 07, 2024

    Germany Defying VAT Exemption For Tutoring, EU Says

    Germany isn't correctly implementing the European Union's value-added tax law, which is supposed to exempt private tutoring services from VAT, the European Commission said Wednesday.

  • February 06, 2024

    UK Windfall Tax Hits BP's Bottom Line As Profits Remain High

    London-based BP PLC laid partial blame on the U.K.'s windfall profits tax for hiking its effective tax rate 5 percentage points to 39% last year as annual profits fell 50% to $13.8 billion, according to filings published Tuesday.

  • February 06, 2024

    UK Broker Says Office Raid During Cum-Ex Probe Was Illegal

    Counsel for commodity brokerage MCML Ltd. told the High Court at a hearing Tuesday that a raid on its London offices over allegations it had defrauded the Danish authorities out of 573 million kroner ($54 million) was illegal.

Expert Analysis

  • Pro Bono Work Is Powerful Self-Help For Attorneys

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    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.

  • The Pop Culture Docket: Judge Espinosa On 'Lincoln Lawyer'

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    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.

  • How And Why Your Firm Should Implement Fixed-Fee Billing

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    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.

  • How Law Firms Can Use Account-Based Marketing Strategies

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    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.

  • Strategic Succession Planning At Law Firms Is Crucial

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    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.

  • Maximizing Law Firm Profitability In Uncertain Times

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    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.

  • 5th Circ. Ruling Reminds Attys That CBP Can Search Devices

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    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.

  • Enforcement Of International Tax Reporting Is Heating Up

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    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.

  • IRS Notice Clarifies R&E Amortization, But Questions Remain

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    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.

  • Preparing Your Legal Department For Pillar 2 Compliance

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    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.

  • What Large Language Models Mean For Document Review

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    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.

  • Participating In Living History Makes Me A Better Lawyer

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    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.

  • Private Equity Owners Can Remedy Law Firms' Agency Issues

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    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.

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