International
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January 15, 2025
Legislators Say Transparency Act Defies First Amendment
The Corporate Transparency Act is an unnecessary intrusion into the First Amendment rights of Americans, U.S. Sen. Thom Tillis, R-N.C., and 13 House members told the Supreme Court in seeking to maintain an injunction issued in December.
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January 15, 2025
House Clears US-Taiwan Double Tax Relief Bill
The U.S. House of Representatives overwhelmingly approved legislation Wednesday that would provide Taiwanese businesses in the United States with tax-treaty-like benefits and authorize the White House to negotiate a tax agreement with Taiwan.
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January 15, 2025
Australia Gives Guidance On Foreign-Funded Construction
The Australian Taxation Office laid out a number of key areas that private companies receiving foreign funding from a related party for property or construction projects need to be aware of in order to not run afoul of the country's transfer pricing rules.
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January 15, 2025
HMRC Board Chair Calls Fiscal Rules Nonnegotiable
The U.K. government will not change course on its fiscal rules despite higher borrowing costs from worsening market conditions, the chair of the board of Britain's tax authority told Parliament's Treasury Committee on Wednesday.
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January 15, 2025
Sweden Should Expand, Simplify R&D Tax Credit, Report Says
A government report said Sweden should simplify and expand its research and development tax credit regime and make changes to what is known as its expert tax incentives in order to improve the country's competition and productivity, its Ministry of Finance said Wednesday.
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January 15, 2025
IRS Mulling Widened Early Application Of Offshore Profit Regs
The Internal Revenue Service is considering expanding the early application option for proposed regulations designed to help U.S. multinational corporations properly account for previously taxed earnings and profits, an agency official said Wednesday.
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January 15, 2025
Chile Must Increase Tax Revenue To Cut Into Debt, OECD Says
With Chile's tax revenues making up just 21% of its gross-domestic product, the country needs to boost its revenue through broad changes to its tax regime if it hopes to keep up with rising spending needs, the Organization for Economic Cooperation and Development said Wednesday.
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January 15, 2025
30 Countries' Minimum Taxes Pass First Review, OECD Says
Policies in about 30 countries passed an initial review for compliance with the 15% global minimum tax system, the first batch to reach that milestone, the Organization for Economic Cooperation and Development said Wednesday.
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January 15, 2025
Netherlands Considering Long-Haul Flight Tax Increase
The Netherlands government is looking for feedback on a plan to replace its flat aviation tax with one that is distance-dependent in hopes of boosting revenue from the tax while encouraging more climate-friendly behaviors, the country's finance ministry said Wednesday.
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January 14, 2025
KPMG, Biz Groups, NY Tax Bar Urge Reg Fixes To Corp. AMT
Energy company and life insurance groups have proposed industry-specific adjustments to the U.S. corporate alternative minimum tax regulations, while the New York State Bar Association and KPMG advocate for simpler accounting methods to assess compliance, according to comment letters to the U.S. Treasury Department.
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January 14, 2025
Orrick Adds Paris Tax Partner From Latham
Orrick Herrington & Sutcliffe LLP added a former counsel at Latham & Watkins LLP as a partner in its Paris office, where she'll advise clients on the tax aspects of French and international transactions, the firm said.
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January 14, 2025
Spain Plans 100% Tax On Foreign-Owned Homes
The Spanish government plans to introduce a 100% tax on foreign-owned homes and stricter rules for holiday rentals to tourists, Prime Minister Pedro Sánchez said.
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January 14, 2025
Trump Announces Plans To Create 'External Revenue Service'
President-elect Donald Trump said Tuesday that he planned to create an "External Revenue Service" that would collect tariffs and revenue from foreign countries.
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January 13, 2025
IRS Puts Out Spinoff Rules, Multiyear Reporting Regime
The Internal Revenue Service released proposed regulations Monday for a narrow set of corporate separation transactions, known as spinoffs, that the agency will approve as tax-free ahead of time, alongside guidance detailing multiyear reporting requirements for those deals.
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January 13, 2025
PepsiCo Created Shell Co. To Avoid Taxes, Ill. Court Says
PepsiCo operated a shell company as part of a scheme that resulted in its Illinois income tax bill for its Frito-Lay unit being deficient nearly $10.9 million, a state circuit court ruled.
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January 13, 2025
AGs, Lobbyists Ask Justices To Keep Shell Co. Law Blocked
The U.S. Supreme Court should deny the federal government's emergency application to stay a Texas district court's injunction on a law aimed at cracking down on crimes committed with shell companies, according to numerous state attorneys general and interest groups and a handful of small businesses.
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January 13, 2025
Tax Firm Asks Court To Ax Final IRS Microcaptive Rules
A global tax services provider asked a Texas federal court to vacate finalized tax rules requiring the reporting of certain transactions involving captive insurance companies deemed as potentially abusive, arguing the guidance goes beyond the agency's authority.
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January 13, 2025
Sen. Warren To Grill Treasury Pick On Trump's Tax Agenda
Sen. Elizabeth Warren, D-Mass., plans to ask Treasury secretary nominee Scott Bessent at his confirmation hearing in front of the Senate Finance Committee on Thursday about President-elect Donald Trump's tax agenda and plans for the Internal Revenue Service, according to a letter she sent the nominee.
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January 13, 2025
The Tax Angle: GOP Lawmakers Grapple With TCJA Renewal
From a look at Congress setting parameters for consideration of legislation to renew the GOP's 2017 tax overhaul law to other upcoming tax action in the House and Senate, here's a peek into a reporter's notebook on a few of the week's developing tax stories.
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January 13, 2025
Norway Seeking Comments On Shareholder Register Plans
The Norway Tax Administration is looking for public comments on plans to introduce a shareholder register that it said would provide authorities with important ownership information, laying out four options for consideration but highlighting its preferred one, it said Monday.
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January 13, 2025
Pillar 2's Effect May Vary Based On Biz Function, Report Says
The global minimum tax deal known as Pillar Two may have a minimal effect on where multinational corporations carry out routine business functions, but companies could eventually change where they perform other operations, according to an OECD paper released Monday.
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January 13, 2025
Still No Unanimous Path Forward On Amount B, OECD Says
The Organization for Economic Cooperation and Development has still not found a path to an agreement on Pillar One's Amount B, which is designed to streamline the pricing of certain baseline marketing and distribution activities, with conversations being held up by possible "inappropriate outcomes," the OECD said Monday.
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January 13, 2025
Tax Hikes Hit Business Confidence, UK Industry Chair Says
The Labour government's decision to raise payroll taxes on employers in last year's budget has hurt business confidence, the chair of an influential British industry group said Monday.
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January 10, 2025
Treasury Finalizes Rules For Disregarded Foreign Payments
The U.S. Treasury Department issued final regulations Friday that are designed to prevent companies from receiving foreign payments in a way that allows them to reduce their overseas taxes without a corresponding increase in U.S. taxable income.
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January 10, 2025
Ga. Law Firm Latest To Fight Corporate Transparency Act
A federal law designed to combat money laundering violates the U.S. Constitution by forcing lawyers to disregard attorney-client privilege, a Georgia lawyer told a federal court, joining a chorus seeking legal action to stop the law.
Expert Analysis
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4 PR Pointers When Your Case Is In The News
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.
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Unpacking The Proposed Production Tax Credit Regulations
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.
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10 Considerations For Litigating A New York Tax Case
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.
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Law Firm Strategies For Successfully Navigating 2024 Trends
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.
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Attorneys' Busiest Times Can Be Business Opportunities
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.
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How Attorneys Can Be More Efficient This Holiday Season
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.
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How Clients May Use AI To Monitor Attorneys
Excerpt from Practical Guidance
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.
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The Pop Culture Docket: Judge D'Emic On Moby Grape
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.
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Breaking Down High Court's New Code Of Conduct
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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Legal Profession Gender Parity Requires Equal Parental Leave
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.
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A Year-End Look At Florida's Capital Investment Tax Credit
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.
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Understanding Discovery Obligations In Era Of Generative AI
Excerpt from Practical Guidance
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.
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The Case For Post-Bar Clerk Training Programs At Law Firms
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.