International
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October 07, 2024
Justices Won't Hear Man's FBAR Constitutionality Challenge
The U.S. Supreme Court let stand Monday a Seventh Circuit decision dismissing a man's challenge to the constitutionality of the Bank Secrecy Act's requirement to report his foreign bank accounts, effectively ending the man's claim that the filings were an invasion of privacy.
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October 07, 2024
Jury Finds Professor Hid Foreign Bank Accounts
An 86-year-old former college professor faces more than $500,000 plus interest in penalties after a jury found that he had deliberately failed to report his foreign bank accounts in Switzerland and Turkey, according to documents filed in a California federal court.
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October 07, 2024
Man Who Faced Espionage Case Gets Probation Over Taxes
A Chinese engineer initially accused of illegally exporting documents on military aircraft to China was given probation and fined for failing to report about $1.4 million in business income by a Texas federal court after the government dropped its export charges.
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October 07, 2024
Singapore Seeks Comments On Min. Tax Safe Harbor Rules
Singapore is looking for feedback on proposed safe harbor and transition rules that would complement its coming implementation of the OECD's Pillar Two global minimum tax on large multinational corporations, its revenue authority said.
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October 07, 2024
Norway's Gov't Looking To Close Exit Tax Loophole
Norway's government said Monday that it is looking to close a loophole by adjusting its exit tax rules, though the tightening on when the tax must be paid would be paired with a 500% increase of the threshold for when the tax becomes applicable.
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October 07, 2024
Corp. Tactics May Call For Rethinking Tax Breaks, Paper Says
Countries may want to look at scaling back corporate tax breaks to address tax planning opportunities taken advantage of by businesses over the past 20 years while those tax breaks have proliferated, according to a working paper published Monday by the Organization for Economic Cooperation and Development.
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October 07, 2024
India Seeking Feedback On Income Tax Regime
India's government said Monday it is undergoing what it called a comprehensive review of its income tax regime in hopes of reducing litigation and increasing taxpayer certainty.
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October 07, 2024
TCJA Extension, Biz Tax Cut To Reward Top 5%, Report Says
Former President Donald Trump's planned extension of the 2017 tax cuts and lowering of corporate rates contribute most among his platform to lowering taxes for the wealthiest 5% and hiking them for everyone else, the left-leaning Institute on Taxation and Economic Policy said Monday in a report.
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October 05, 2024
Biz Owners Saved £1.3B On Inheritance Tax, Report Says
Business owners have saved their families an estimated £1.3 billion ($1.7 billion) last year by claiming business property relief on inheritance tax, according to law firm TWM Solicitors.
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October 04, 2024
DC Circ. Won't Reconsider Whistleblower's $690M Claim
The D.C. Circuit on Friday rejected a whistleblower's request that it rehear a ruling upholding the denial of up to $690 million, or 30%, of the $2.3 billion collected in an Internal Revenue Service offshore voluntary disclosure program.
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October 04, 2024
Promise Of OECD's Payments Tax Treaty Called Into Question
The OECD-designed tool to provide developing countries with better means to apply a minimum tax on income sent from their jurisdictions to low-taxed entities within a corporate group is inadequate to address those countries' revenue needs, tax policy organizations said.
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October 04, 2024
Australia Wants Feedback On Tax Promoter Penalty Regime
The Australian government asked Friday for feedback on the country's current tax promoter penalty regime as part of its efforts to strengthen its regulatory frameworks in the wake of the PwC document leak scandal.
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October 04, 2024
Europe Votes To Raise Tariffs On Electric Vehicles From China
European Union member states voted Friday to impose higher tariffs on imports of battery electric vehicles from China for the next five years, adding to the already staggering tariffs imposed by the United States and Canada.
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October 04, 2024
Brazil Establishes 15% Global Min. Tax On Large Cos.
Brazil's government has adopted the Organization for Economic Cooperation and Development's 15% global corporate minimum tax on large multinational corporations making €750 million ($823 million) annually.
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October 04, 2024
Former NJ Doctor Owes $4.8M In FBAR Penalties, Court Told
A former physician in New Jersey faces a tax bill of almost $5 million for failing to report 19 bank accounts he opened at Indian banks, the government told a federal court.
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October 04, 2024
ECJ Says Interest Deduction Limits Align With EU Law
Governments across the European Union can legislate to block businesses from getting corporate tax deductions on interest paid as part of noncommercial loans, the European Court of Justice ruled Friday.
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October 04, 2024
Taxation With Representation: Gibson Dunn, Weil, Simpson
In this week's Taxation with Representation, DirectTV buys EchoStar's video business for $10 billion, Marsh McLennan inks a $7.75 billion deal for McGriff Insurance, and PepsiCo closes a $1.2 billion deal to purchase Siete Foods.
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October 04, 2024
McDermott Taps Big 4 Partner As Senior Tax Pro In London
McDermott Will & Emery LLP announced it has recruited a former U.K. partner from KPMG to join its firm as a tax partner, bringing an expert in private equity to its London office.
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October 03, 2024
12 Lawyers Who Are The Future Of The Supreme Court Bar
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.
Expert Analysis
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Finding Focus: Strategies For Attorneys With ADHD
Given the prevalence of ADHD among attorneys, it is imperative that the legal community gain a better understanding of how ADHD affects well-being, and that resources and strategies exist for attorneys with this disability to manage their symptoms and achieve success, say Casey Dixon at Dixon Life Coaching and Krista Larson at Stinson.
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Attorneys, Law Schools Must Adapt To New Era Of Evidence
Technological advancements mean more direct evidence is being created than ever before, and attorneys as well as law schools must modify their methods to account for new challenges in how this evidence is collected and used to try cases, says Reuben Guttman at Guttman Buschner.
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1st Tax Easement Convictions Will Likely Embolden DOJ, IRS
After recent convictions in the first criminal tax fraud trial over allegedly abusive syndicated conservation easements, the IRS and U.S. Department of Justice will likely pursue other promoters for similar alleged conspiracies — though one acquittal may help attorneys better evaluate their clients' exposure, say Bill Curtis and Lauren DeSantis-Then at Polsinelli.
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Tips For Litigating Against Pro Se Parties In Complex Disputes
Litigating against self-represented parties in complex cases can pose unique challenges for attorneys, but for the most part, it requires the same skills that are useful in other cases — from documenting everything to understanding one’s ethical duties, says Bryan Ketroser at Alto Litigation.
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Anticipating Intensified Partnership Enforcement From IRS
The Internal Revenue Service's decadeslong difficulties with partnership audits led to the recent announcement of a clear, well-funded, focused initiative, and businesses operating in the partnership form will feel the impact, with definite changes ahead, says Sharon Katz-Pearlman at Greenberg Traurig.
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Pro Bono Work Is Powerful Self-Help For Attorneys
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.
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The Pop Culture Docket: Judge Espinosa On 'Lincoln Lawyer'
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.
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How And Why Your Firm Should Implement Fixed-Fee Billing
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.
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How Law Firms Can Use Account-Based Marketing Strategies
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.
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Strategic Succession Planning At Law Firms Is Crucial
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.
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Maximizing Law Firm Profitability In Uncertain Times
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.
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5th Circ. Ruling Reminds Attys That CBP Can Search Devices
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.
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Enforcement Of International Tax Reporting Is Heating Up
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.