International

  • June 26, 2024

    Pepsi's Royalty Tax Liability Overturned By Australian Panel

    A Federal Court of Australia judge incorrectly ruled that payments for beverage concentrate between Pepsi subsidiaries in Australia and Singapore included the license to use Pepsi's trademark and so triggered royalty taxes, a panel of the court ruled Wednesday. 

  • June 26, 2024

    Fed. Circ. Denies Contractor's $37M Tax Reimbursement Bid

    A U.S. State Department armed security contractor is not entitled to $37 million in reimbursement tied to tax payments to the Afghan government because the contractor's parent company, not the company itself, incurred the costs associated with the payments, the Federal Circuit said Wednesday.

  • June 26, 2024

    Medical Device Co. To Pay $935K Atty Fees In Tax Fraud Suit

    A medical equipment company's leaders will pay $935,000 in attorney fees to investors' counsel after mediating a settlement in a proposed class action alleging the company breached fiduciary duty in failing to disclose its former CEO's involvement in a tax fraud dispute with Denmark.

  • June 26, 2024

    Kenya President Backs Off Finance Bill After Fatal Protests

    Kenyan President William Ruto said Wednesday that he will withdraw a controversial finance bill that included tax hikes that inspired mass protests, including storming the country's Parliament building leaving multiple people dead, according to local news reports.

  • June 26, 2024

    EU Justice Head Loses Bid To Lead Human Rights Group

    The European Union's justice commissioner failed in his bid to lead a European human rights organization and returned Wednesday from his leave of absence for the remaining four months of his term as commissioner.

  • June 26, 2024

    EU State Auditors Must Respect Tax Incentives, Lawyer Says

    European Union countries need to make sure that their tax authorities are supporting incentive programs, such as those related to research and development, rather than interpreting laws in inconsistent ways, a tax lawyer said Wednesday.

  • June 26, 2024

    Irish Pick New Finance Minister After Former Heads To EU

    Ireland picked a current junior minister as its new finance minister, the ministry confirmed to Law360 on Wednesday, one day after the government nominated the outgoing finance minister to serve on the next European Commission. 

  • June 25, 2024

    US Needs To Broaden Tax Base, Increase Rates, OECD Says

    The United States' debt-to-gross-domestic-product ratio is the highest it's been since World War II, necessitating a wide range of tax changes to both expand the tax base and increase rates to alleviate fiscal pressures, the OECD said Tuesday.

  • June 25, 2024

    Pharma Co. Teva To Pay Israel $750M In Tax Debt Settlement

    Israel-based multinational Teva Pharmaceutical Industries Ltd. reached an agreement with the Israel Tax Authority to settle 12 years' worth of pending tax litigation by paying $750 million over the course of five years, the company said Tuesday.

  • June 25, 2024

    Asia, Pacific Tax-To-GDP Ratio Returns To Pre-COVID Level

    Tax revenue in Asia and the Pacific rebounded to pre-pandemic levels in 2022 thanks to boosts in tourism and commodity prices, but the region's average tax-to-gross domestic product ratio is still lagging behind the average OECD ratio, the group said Tuesday.

  • June 25, 2024

    Pension Plans Can't Escape $2B Danish Tax Fraud Dispute

    Two U.S. pension plans made an "extremely strained" contention that Denmark's tax administrator waited too long to accuse them of participating in a $2.1 billion fraud scheme, a New York federal judge said in declining to toss the case.

  • June 25, 2024

    Hong Kong, Armenia Reach Double-Tax Treaty Deal

    Hong Kong signed an agreement with Armenia on a treaty to prevent double taxation as part of a larger goal to establish such treaties with countries participating in China's Belt and Road global infrastructure project, Hong Kong's Inland Revenue Department said.

  • June 25, 2024

    Ex-DOJ Atty Among New Trio At Chamberlain Hrdlicka

    Chamberlain Hrdlicka White Williams & Aughtry has strengthened its tax controversy and litigation practice with the addition of three attorneys in Atlanta, including a former senior trial attorney in the Tax Division of the U.S. Department of Justice for more than three decades.

  • June 25, 2024

    J&J Counsel Urges OECD To Ease Burdens Of Global Min. Tax

    Counsel for Johnson & Johnson on Tuesday urged the OECD and government officials working on the Pillar Two global minimum corporate tax to consider more permanent safe harbor provisions to reduce the compliance burdens associated with the levy.

  • June 25, 2024

    Global Tax Overhaul Won't Squash Competition, US Rep. Says

    The global tax overhaul designed by the Organization for Economic Cooperation and Development won't eliminate countries competing for companies' investments, a U.S. House lawmaker said Tuesday.

  • June 25, 2024

    EU Leaders To Include Tax Revamp In 5-Year Plan, Draft Says

    A targeted makeover of the tax systems in European Union countries will be part of the bloc's top priorities for the next five years as it aims to improve business financing to sharpen its competitiveness, a draft document suggested.

  • June 25, 2024

    New EU Chair Hungary Eyes Talks On Corp. Tax, But No Deals

    Hungary, the incoming chair of meetings of European Union countries, plans to discuss energy taxation and several proposals on corporate taxation during the next six months but doesn't expect to reach any agreements, according to meeting agendas.

  • June 24, 2024

    Miner Wins $9.6M In Royalty Fight With Colombia

    An international tribunal ordered Colombia to pay $9.56 million to a British mining and metals company following a dispute over royalties collected on a nickel mine, as the tribunal concluded that there had been "irregularities" in the way the country calculated the amount due.

  • June 24, 2024

    UN Tax Work Threatens OECD's Progress, EU Official Says

    The United Nations' efforts to consider international tax issues risk upending the early finished work of countries negotiating a global tax plan at the Organization for Economic Cooperation and Development, a top European Commission tax official said Monday.

  • June 24, 2024

    Better Digital Tax Ban In Pillar 1 Treaty, Treasury Official Says

    The final text of a multilateral convention to implement the OECD-designed taxing rights overhaul will include improved language to eliminate existing digital services tax and prohibit prospective ones, a U.S. Treasury Department official said Monday.

  • June 24, 2024

    Loss Guidance Will Cover Pillar 2, IRS Official Says

    Forthcoming guidance to address U.S. tax issues with dual consolidated losses will also include language advising taxpayers how to account for those losses under the Pillar Two global minimum tax, the IRS' top international tax counsel said Monday.

  • June 24, 2024

    UN Tax Convention Should Be Crafted Carefully, NFTC Says

    The United Nations' work toward a framework convention on international tax cooperation is welcome but should be done carefully and with continued input from stakeholders, the National Foreign Trade Council said, providing specific areas of feedback.

  • June 24, 2024

    German Banker's Cum-Ex Trial Dropped Due To Health

    The former chairman of M.M. Warburg & Co. KGaA will not face trial for alleged dividend-tax evasion linked to cum-ex transactions spanning from 2006 to 2019 after a German court halted the trial due to his health, according to a Monday court statement.

  • June 24, 2024

    Asia Tax Transparency Generated €1.8B In Revenue In 2023

    Tax transparency measures in 13 Asian jurisdictions collected at least €1.8 billion ($1.9 billion) in extra tax revenue in 2023 alone as such mechanisms continue to be adopted in the region, the Organization for Economic Cooperation and Development reported Monday.

  • June 24, 2024

    EU Dodges Hungary To Send Ukraine €1.4B In Russian Profits

    European Union foreign ministers agreed Monday to send €1.4 billion ($1.5 billion) of windfall profits from frozen and immobilized Russian state assets in military support to Ukraine next month, finding a legal loophole to bypass a potential veto from Hungary.

Expert Analysis

  • Employee Experience Strategy Can Boost Law Firm Success

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    Amid continuing business uncertainty, law firms should consider adopting a holistic employee experience strategy — prioritizing consistency, targeting signature moments and leveraging measurement tools — to maximize productivity and profitability, says Haley Revel at Calibrate Consulting.

  • 6 Practice Pointers For Pro Bono Immigration Practice

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    An attorney taking on their first pro bono immigration matter may find the law and procedures beguiling, but understanding key deadlines, the significance of individual immigration judges' rules and specialized aspects of the practice can help avoid common missteps, says Steven Malm at Haynes Boone.

  • Lessons From Country Singer's Personal Service Saga

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    Recent reports that country singer Luke Combs won a judgment against a Florida woman who didn’t receive notice of the counterfeit suit against her should serve as a reminder for attorneys on best practices for effectuating service by electronic means, say attorneys at Jenner & Block.

  • 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.

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