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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How Judiciary Can Minimize AI Risks In Secondary Sources
Because courts’ standing orders on generative artificial intelligence and other safeguards do not address the risk of hallucinations in secondary source materials, the judiciary should consider enlisting legal publishers and database hosts to protect against AI-generated inaccuracies, say attorneys at Lankler Siffert & Wohl.
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How Attorneys Can Break Free From Career Enmeshment
Ambitious attorneys can sometimes experience career enmeshment — when your sense of self-worth becomes unhealthily tangled up in your legal vocation — but taking the time to discover and realign with your core personal values can help you recover your identity, says Janna Koretz at Azimuth Psychological.
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Lawyers With Disabilities Are Seeking Equity, Not Pity
Attorneys living with disabilities face extra challenges — including the need for special accommodations, the fear of stigmatization and the risk of being tokenized — but if given equitable opportunities, they can still rise to the top of their field, says Kate Reder Sheikh, a former attorney and legal recruiter at Major Lindsey & Africa.
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Judicial Committee Best Venue For Litigation Funding Rules
The Advisory Committee on Civil Rules' recent decision to consider developing a rule for litigation funding disclosure is a welcome development, ensuring that the result will be the product of a thorough, inclusive and deliberative process that appropriately balances all interests, says Stewart Ackerly at Statera Capital.
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The Strategic Advantages Of Appointing A Law Firm CEO
The impact on law firms of the recent CrowdStrike outage underscores that the business of law is no longer merely about providing supplemental support for legal practice — and helps explain why some law firms are appointing dedicated, full-time CEOs to navigate the challenges of the modern legal landscape, says Jennifer Johnson at Calibrate Strategies.
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How Cos. Can Build A Strong In-House Pro Bono Program
During this year’s pro bono celebration week, companies should consider some key pointers to grow and maintain a vibrant in-house program for attorneys to provide free legal services for the public good, says Mary Benton at Alston & Bird.
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Home Canning Makes Me A Better Lawyer
Making my own pickles and jams requires seeing a process through from start to finish, as does representing clients from the start of a dispute at the Patent Trial and Appeal Board through any appeals to the Federal Circuit, says attorney Kevin McNish.
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Use The Right Kind Of Feedback To Help Gen Z Attorneys
Generation Z associates bring unique perspectives and expectations to the workplace, so it’s imperative that supervising attorneys adapt their feedback approach in order to help young lawyers learn and grow — which is good for law firms, too, says Rachael Bosch at Fringe Professional Development.
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Congress Can And Must Enact A Supreme Court Ethics Code
As public confidence in the U.S. Supreme Court dips to historic lows following reports raising conflict of interest concerns, Congress must exercise its constitutional power to enact a mandatory and enforceable code of ethics for the high court, says Muhammad Faridi, president of the New York City Bar Association.
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What To Make Of Dueling Corporate Transparency Act Rulings
Although challenges to the Corporate Transparency Act abound — as highlighted by recent federal court decisions from Alabama and Oregon taking opposite positions on its constitutionality — the act is still law, so companies should comply with their filing requirements or face the potential consequences, say attorneys at Lowenstein Sandler.
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The Pop Culture Docket: Justice Lebovits On Gilbert And Sullivan
Characters in the 19th century comic operas of Gilbert and Sullivan break the rules of good lawyering by shamelessly throwing responsible critical thought to the wind, providing hilarious lessons for lawyers and judges on how to avoid a surfeit of traps and tribulations, say acting New York Supreme Court Justice Gerald Lebovits and law student Tara Scown.
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State Of The States' AI Legal Ethics Landscape
Over the past year, several state bar associations, as well as the American Bar Association, have released guidance on the ethical use of artificial intelligence in legal practice, all of which share overarching themes and some nuanced differences, say Eric Pacifici and Kevin Henderson at SMB Law Group.
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8 Childhood Lessons That Can Help You Be A Better Attorney
A new school year is underway, marking a fitting time for attorneys to reflect on some fundamental life lessons from early childhood that offer a framework for problems that no legal textbook can solve, say Chris Gismondi and Chris Campbell at DLA Piper.