International
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October 03, 2024
Leading Lights Of The Supreme Court Bar's Next Generation
One attorney hasn't lost a single U.S. Supreme Court case she's argued, or even a single justice's vote. One attorney is perhaps "the preeminent SCOTUS advocate." And one may soon become U.S. solicitor general, despite acknowledging there are "judges out there who don't like me." All three are among a dozen lawyers in the vanguard of the Supreme Court bar's next generation, poised to follow in the footsteps of the bar's current icons.
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October 03, 2024
US Partnership Excluded From Tax Treaty, Irish Court Says
A Delaware corporation with three Irish subsidiaries must pay Irish taxes on distributions to its U.S. partners because a U.S.-Ireland tax treaty designed to prevent double taxation does not apply, the Irish High Court ruled.
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October 03, 2024
3M Tells 8th Circ. Chevron's End Dooms IRS In $24M Dispute
Multinational conglomerate 3M said Thursday that the U.S. Supreme Court's striking down of Chevron deference dictates that the Eighth Circuit overturn a U.S. Tax Court decision that supported the IRS' reallocation of $24 million from the company's Brazilian affiliate.
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October 03, 2024
K&L Gates Boosts Houston Shop With Ernst & Young Tax Ace
K&L Gates LLP strengthened its Houston office this week with the hire of a tax partner with nearly three decades of expertise in advising multinational corporations on U.S. taxation on cross-border acquisitions and other transactions.
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October 03, 2024
Aerospace Co. Says Conn. Town Wrongly Taxed $8M In Assets
A unit of a U.K.-based aerospace manufacturer is claiming that a Connecticut town overvalued its taxable personal property by nearly $8 million after the company moved nearly $20 million worth of its property out of the jurisdiction, according to a suit filed in state court.
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October 03, 2024
Tax Could Help Curtail Plastic Pollution By 2040, OECD Says
Taxation targeted at plastic use could help to nearly eliminate plastic pollution by 2040 by curbing both creation and consumption, the Organization for Economic Cooperation and Development said.
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October 03, 2024
EU, Norway Update VAT Fraud Cooperation Agreement
The European Union and Norway have amended their agreement on administrative cooperation to help combat value-added tax fraud as well as the recovery of claims, the European Commission announced.
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October 02, 2024
Philippines Enacts 12% VAT On Foreign Digital Services
Google, Amazon and Netflix are among the companies expected to pay a 12% value-added tax on foreign digital service providers that was signed into law Wednesday by Philippines President Ferdinand Marcos Jr., according to government agencies.
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October 02, 2024
IRS Says European Energy Exchange Is A Qualified Exchange
The European Energy Exchange is a qualified board or exchange for purposes of mark-to-market contracts under Internal Revenue Code Section 1256(g)(7)(C), the Internal Revenue Service said Wednesday.
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October 02, 2024
OECD Releases Crypto Data-Swap Guidance For Tax Agencies
The Organization for Economic Cooperation and Development released guidance Wednesday to help tax administrations automatically exchange information under a new global crypto-asset reporting framework and under an updated system for swapping traditional financial data.
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October 02, 2024
Mongolia Ratifies OECD Tax Treaty Standards
Mongolia ratified the Organization for Economic Cooperation and Development's multilateral convention on base erosion and profit shifting, which updates bilateral tax treaties of its signatories with agreed-upon standards, the OECD said Wednesday.
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October 02, 2024
4 Arrested In €97M VAT Fraud Involving Phone Service
Four people were arrested in Italy for their suspected roles in a value-added tax fraud scheme involving services that let users make phone calls via the internet that sought to claim over €97 million ($107 million) in fraudulent refunds, the European Public Prosecutor's Office said Wednesday.
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October 02, 2024
Canada Finalizes Surtax List For Chinese Steel, Aluminum
Canada's Department of Finance issued its finalized list of Chinese-made steel and aluminum products that will be hit with a 25% surtax when imported into the country starting later this month.
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October 01, 2024
Tax Deadlines Extended For Victims Of Israel-Hamas War
The Internal Revenue Service said Tuesday that it will postpone tax return and payment deadlines to Sept. 30, 2025, for those affected by the Israel-Hamas war across 2023 and 2024.
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October 01, 2024
Amgen Must Face Suit It Misled Investors On $10.7B Tax Bill
Amgen lost an attempt to escape a potential class action claiming the pharmaceutical giant hid a $10.7 billion tax bill from investors after a New York federal court ruled there was sufficient evidence for the action to proceed.
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October 01, 2024
Ireland Eyes Infrastructure With €14B From ECJ Apple Case
The Irish government is aiming to build infrastructure with the €14.1 billion ($15.6 billion) in corporate tax payments due from Apple Inc. following a European Court of Justice ruling that Ireland granted Apple illegal state aid, officials said Tuesday in announcing next year's budget.
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October 01, 2024
EU Chief Prosecutor Calls For Making Tax Fraud A Priority
As organized crime rings continue to affect the European Union budget through "massive" value-added tax and customs fraud schemes, more must be done to support the European Public Prosecutor's Office and its power to investigate such crimes, the European chief prosecutor said in remarks published Tuesday.
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October 01, 2024
Treasury Plans Final Direct Pay Partnership Regs By Year-End
The U.S. Treasury Department is eyeing the end of the year to finalize regulations for development projects to elect out of their partnership tax status to qualify for a direct cash payment of their clean energy tax credits, an official said Tuesday.
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October 01, 2024
EU General Court To Begin Hearing VAT Cases
The European Union General Court can make preliminary rulings in cases involving the EU's common system of value-added taxes, effective Tuesday, as part of an expansion of the court's jurisdiction.
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October 01, 2024
UK Tax Havens Tied To $84B In Lost Revenue, Group Says
The British Virgin Islands, Cayman Islands and Bermuda held on to their spots atop the Tax Justice Network's tax havens list, with the group saying Tuesday that the U.K.'s tax havens network is responsible for a third of global corporate tax abuse risks.
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October 01, 2024
Estate Exaggerating Value Of Exec's Tax Tipoff, DC Circ. Told
A Dutch bank executive's estate is "vastly" overstating the significance of his tips to the IRS in seeking a whistleblower award for his reporting of tax schemes, the U.S. government told the D.C. Circuit, urging it to uphold the U.S. Tax Court's denial of the award.
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September 30, 2024
Corporate Tax Rates Up In 2023, OECD Annual Report Finds
A global trend toward cutting taxes to address the economics of the COVID-19 pandemic began to wane in 2023, with more nations willing to raise taxes and broaden tax bases to fund social spending, the Organization of Economic Cooperation and Development said Monday.
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September 30, 2024
PwC Agrees To $63M Fine For Evergrande Audit, China Says
PwC's chairman agreed to the firm's six-month suspension in China and nearly $63 million in fines over its Chinese auditing arm's work for Evergrande Group, which until a court-ordered liquidation in January was the country's largest real estate firm, the country's Finance Ministry said Monday.
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September 30, 2024
IRS Seeks Input On Draft Partnership Basis-Shifting Form
The Internal Revenue Service asked for comments Monday on a draft form and instructions for partners to disclose all the property they receive from partnerships, part of upcoming regulations meant to target abusive tax avoidance that uses sophisticated partnership basis-shifting transactions.
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September 30, 2024
German Lawyer Charged Over €428M Cum-Ex Fraud
A lawyer has been charged in Germany with several counts of "serious tax evasion" over his alleged role in a €428 million ($477 million) so-called cum-ex dividend tax fraud, a German court confirmed Monday.
EU Refers 4 Countries To Court Over Pillar 2 Delays
The European Commission said it was referring Cyprus, Poland, Portugal and Spain to the European Union's top court for missing the deadline to implement the global minimum corporate tax, known as Pillar Two.
BlackBerry's $17M In R&D Not Taxable, Canada Court Rules
BlackBerry Ltd. won't pay taxes on $17.1 million in research and development services it procured from its U.S. affiliates because the services don't fit the definition of foreign accrual property income, the Tax Court of Canada ruled.
Ex-USTR Official Sees Possible Path Forward For Digital Taxes
The U.S. may withhold trade threats if it believes countries are having good-faith conversations about concerns that their digital services taxes discriminate against U.S. businesses, including in current talks with Canada, the former general counsel for the Office of the U.S. Trade Representative told Law360.
Featured Stories
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Leading Lights Of The Supreme Court Bar's Next Generation
One attorney hasn't lost a single U.S. Supreme Court case she's argued, or even a single justice's vote. One attorney is perhaps "the preeminent SCOTUS advocate." And one may soon become U.S. solicitor general, despite acknowledging there are "judges out there who don't like me." All three are among a dozen lawyers in the vanguard of the Supreme Court bar's next generation, poised to follow in the footsteps of the bar's current icons.
-
Ex-USTR Official Sees Possible Path Forward For Digital Taxes
The U.S. may withhold trade threats if it believes countries are having good-faith conversations about concerns that their digital services taxes discriminate against U.S. businesses, including in current talks with Canada, the former general counsel for the Office of the U.S. Trade Representative told Law360.
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The Tax Angle: Corporate Inversions, SALT Cap
From a look at criticisms that the 2017 federal tax law failed to stop corporations from moving overseas to GOP efforts to navigate the SALT cap ahead of the November elections, here's a peek into a reporter's notebook on a few of the week's developing tax stories.
Expert Analysis
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The Trade And Tax Issues Behind US-Canada Digital Tax Clash
The new Canadian digital services tax recently went into effect despite objections from the U.S., a controversy that represents an unusual mix of trade and tax policy, and many companies have been pondering how it will affect their e-commerce businesses, says Damon Pike at BDO.
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Litigation Inspiration: Honoring Your Learned Profession
About 30,000 people who took the bar exam in July will learn they passed this fall, marking a fitting time for all attorneys to remember that they are members in a specialty club of learned professionals — and the more they can keep this in mind, the more benefits they will see, says Bennett Rawicki at Hilgers Graben.
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AI May Limit Key Learning Opportunities For Young Attorneys
The thing that’s so powerful about artificial intelligence is also what’s most scary about it — its ability to detect patterns may curtail young attorneys’ chance to practice the lower-level work of managing cases, preventing them from ever honing the pattern recognition skills that undergird creative lawyering, says Sarah Murray at Trialcraft.
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Ruling On Foreign Dividend Break Offers 2 Tax Court Insights
In Varian v. Commissioner, the U.S. Tax Court allowed a taxpayer's deduction for dividends from foreign subsidiaries, providing clarity on how the U.S. Supreme Court’s Loper Bright decision may affect challenges to Treasury regulations, and revealing a potential disallowance of foreign tax credits, say attorneys at Davis Polk.
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Why Now Is The Time For Law Firms To Hire Lateral Partners
Partner and associate mobility data from the second quarter of this year suggest that there's never been a better time in recent years for law firms to hire lateral candidates, particularly experienced partners — though this necessitates an understanding of potential red flags, say Julie Henson and Greg Hamman at Decipher Investigative Intelligence.
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Considering Possible PR Risks Of Certain Legal Tactics
Disney and American Airlines recently abandoned certain litigation tactics in two lawsuits after fierce public backlash, illustrating why corporate counsel should consider the reputational implications of any legal strategy and partner with their communications teams to preempt public relations concerns, says Chris Gidez at G7 Reputation Advisory.
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It's No Longer Enough For Firms To Be Trusted Advisers
Amid fierce competition for business, the transactional “trusted adviser” paradigm from which most firms operate is no longer sufficient — they should instead aim to become trusted partners with their most valuable clients, says Stuart Maister at Strategic Narrative.
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Navigating A Potpourri Of Possible Transparency Act Pitfalls
Despite the Financial Crimes Enforcement Network's continued release of guidance for complying with the Corporate Transparency Act, its interpretation remains in flux, making it important for companies to understand potentially problematic areas of ambiguity in the practical application of the law, say attorneys at Sidley.
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How Methods Are Evolving In Textualist Interpretations
Textualists at the U.S. Supreme Court are increasingly considering new methods such as corpus linguistics and surveys to evaluate what a statute's text communicates to an ordinary reader, while lower courts even mull large language models like ChatGPT as supplements, says Kevin Tobia at Georgetown Law.
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Why Attorneys Should Consider Community Leadership Roles
Volunteering and nonprofit board service are complementary to, but distinct from, traditional pro bono work, and taking on these community leadership roles can produce dividends for lawyers, their firms and the nonprofit causes they support, says Katie Beacham at Kilpatrick.
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Firms Must Offer A Trifecta Of Services In Post-Chevron World
After the U.S. Supreme Court’s Loper Bright Enterprises v. Raimondo decision overturning Chevron deference, law firms will need to integrate litigation, lobbying and communications functions to keep up with the ramifications of the ruling and provide adequate counsel quickly, says Neil Hare at Dentons.
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5 Tips To Succeed In A Master Of Laws Program And Beyond
As lawyers and recent law school graduates begin their Master of Laws coursework across the country, they should keep a few pointers in mind to get the most out of their programs and kick-start successful careers in their practice areas, says Kelley Miller at Reed Smith.
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How Law Firms Can Avoid 'Collaboration Drag'
Law firm decision making can be stifled by “collaboration drag” — characterized by too many pointless meetings, too much peer feedback and too little dissent — but a few strategies can help stakeholders improve decision-making processes and build consensus, says Steve Groom at Miles Mediation.