International
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January 22, 2025
UK Insurance Premium Tax Haul Up 10%, Hits Record £6.7B
The U.K. government raised a record £6.7 billion ($8.3 billion) in insurance premium tax in the first nine months of the financial year ending March, up 10% from the corresponding period a year earlier, according to HMRC figures released Wednesday.
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January 21, 2025
Parliamentary Panel Faults HMRC's Customer Service
HM Revenue & Customs is failing to deliver a good service to taxpayers, with its standards sliding even lower last tax year compared with the prior year, the U.K. Parliament's Public Accounts Committee said in a report published Tuesday.
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January 21, 2025
Detroit Council OKs $45K Settlement Over Holding Co.'s Gain
The city of Detroit approved a settlement Tuesday in the Michigan Tax Tribunal in a long-running tax assessment dispute stemming from a holding company's gain from selling stock in a Canadian tobacco testing company.
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January 21, 2025
Mexico Extends Tax Breaks To Domestic Taxpayers
Mexico is extending a number of tax breaks aimed at foreign companies to qualifying domestic taxpayers, such as the ability to reduce taxable income by immediately deducting investments in fixed assets through late 2030, according to a presidential decree Tuesday.
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January 21, 2025
Skadden Hires Tax Pro In London From Baker McKenzie
Skadden Arps Slate Meagher & Flom LLP has hired a former Baker McKenzie partner to serve in the firm's tax group in London.
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January 21, 2025
Expat Facing $6.9M In FBAR Penalties, Interest
An American woman living in Switzerland faces $6.9 million in penalties, interest and late fees because she did not report her accounts that were held at a Swiss bank, the U.S. government told a D.C. federal court.
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January 21, 2025
UK Waste Management Co. Denies Ties To £2.2M Tax Scam
A U.K. waste management company denied involvement in a scheme to reduce tax rates that put a business affiliate on the hook for £2.2 million ($2.7 million), contending that the affiliate failed to detect red flags.
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January 21, 2025
Sweden Considering Wind Turbine Property Tax Hike
Sweden is considering increasing the property tax on wind turbines to 0.5% of their assessed value from the current 0.2% starting in 2026, the country's Ministry of Finance said Tuesday.
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January 21, 2025
EU Officials Still Committed To Global Tax Deal Without US
The European Union remains committed to the global tax deal signed by over 130 countries in 2021 even after President Donald Trump announced the U.S. would no longer participate in the agreement, according to EU officials speaking in Brussels on Tuesday.
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January 21, 2025
Justices Decline To Review NY Tax On IBM, Disney Royalties
The U.S. Supreme Court declined Tuesday to hear claims from Disney and IBM that New York's former method of taxing royalty payments from foreign affiliates resulted in unconstitutional discrimination against interstate commerce.
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January 21, 2025
HMRC Wins Appeal In £197M BlueCrest Tax Battle
A London appeals court has sent a challenge by British-American hedge fund BlueCrest to a demand from HM Revenue and Customs for approximately £197 million ($242 million) in tax back to a lower tribunal for fresh consideration.
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January 17, 2025
Law360 Names Practice Groups Of The Year
Law360 would like to congratulate the winners of its Practice Groups of the Year awards for 2024, which honor the attorney teams behind litigation wins and significant transaction work that resonated throughout the legal industry this past year.
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January 17, 2025
Law360 Names Firms Of The Year
Eight law firms have earned spots as Law360's Firms of the Year, with 54 Practice Group of the Year awards among them, steering some of the largest deals of 2024 and securing high-profile litigation wins, including at the U.S. Supreme Court.
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January 20, 2025
Gov't Gets Mixed Reception On Inheritance Tax Pension Plans
Proposals by the U.K. government to bring pension assets within the scope of inheritance tax will result in "numerous problems" and raise concerns in their current form, a trade body and consultants warned on Monday.
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January 17, 2025
UK Parliament Calls New Treasury Unit 'Poorly Defined'
A new HM Treasury office set up to scrutinize fiscal policy lacks staff and its purpose is poorly defined, which means it could duplicate the work of other organizations, the U.K. Parliament's Treasury Select Committee said in a report Sunday.
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January 17, 2025
US Guidance On Amount B Carries Potential For Disputes
Recent IRS guidance on a simplified and streamlined transfer pricing method for certain cross-border transactions, known as Amount B, suggests rulemakers want feedback on how it would work if it were made mandatory, but that approach could lead to controversy without global cooperation.
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January 17, 2025
Case Dismissed Against Man Accused Of Concealing Location
A former healthcare executive whose employer had accused him of avoiding CA$1.2 million ($828,000) in Canadian taxes by lying about his location no longer faces legal action, as the parties agreed to dismiss the action.
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January 17, 2025
Hawaii House Bill Seeks Worldwide Combined Reporting
Hawaii would impose a mandatory worldwide combined reporting system for corporations effective next year under a bill filed in the state House of Representatives.
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January 17, 2025
Taxation With Representation: Simpson Thacher, Covington
In this week's Taxation With Representation, Eli Lilly and Co. buys a precision breast cancer program, Applied Digital Corp. enters a financing agreement for its high-performance computing business, Clearwater Analytics buys Enfusion, and Lantheus Holdings Inc. buys Life Molecular Imaging Ltd.
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January 17, 2025
UAE, Russia Reach Agreement On Double-Tax Treaty
Representatives of the United Arab Emirates and Russia signed a draft treaty to prevent double taxation on income and capital, the UAE's state news agency said Friday, despite ongoing international tensions over Russia's war with Ukraine.
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January 17, 2025
Scottish Power Loses £28M Redress Case Against HMRC
Scottish Power lost its appeal against HM Revenue and Customs on Friday, as a tribunal ruled that the energy company was wrong to argue that just over £28 million ($34 million) in redress payments it made after being investigated for regulatory failures was tax-deductible.
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January 16, 2025
Canadian Conservatives Pledge To Kill Capital Gains Hike
The Conservative Party of Canada promised Thursday to ax a capital gains tax increase secured by the administration of outgoing Prime Minister Justin Trudeau, according to a news release shared on social media Thursday by the party's leader and its candidate for Trudeau's position, Pierre Poilievre.
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January 16, 2025
OECD's Global Minimum Tax Takes Effect In Indonesia
Indonesia began implementing the OECD's global minimum tax on multinational entities making over €750 million ($773 million) annually at the start of this year, the country's Ministry of Finance said Thursday.
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January 16, 2025
OECD To Release List Of Abusive Transactions Under Pillar 2
The Organization for Economic Cooperation and Development is putting together a list of intercompany transactions that may raise red flags as attempts to undermine an international minimum tax agreement known as Pillar Two, an OECD official said Thursday.
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January 16, 2025
Madeira Loses EU State Aid Case Over Tax Breaks
Portugal will have to recover money from companies granted reduced tax rates by its autonomous territory Madeira because the taxpayers failed to meet the terms of two European Commission decisions allowing state aid, the European Court of Justice ruled Thursday.
Expert Analysis
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After Chevron: Delegation Of Authority And Tax Regulators
The U.S. Department of the Treasury and the Internal Revenue Service will face higher standards following Loper Bright’s finding that courts should determine whether agency rules meet the best possible interpretation of the tax code, as well as the scope of the authority delegated by Congress, says Edward Froelich at McDermott.
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Lawyers Can Take Action To Honor The Voting Rights Act
As the Voting Rights Act reaches its 59th anniversary Tuesday, it must urgently be reinforced against recent efforts to dismantle voter protections, and lawyers can pitch in immediately by volunteering and taking on pro bono work to directly help safeguard the right to vote, says Anna Chu at We The Action.
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How To Grow Marketing, Biz Dev Teams In A Tight Market
Faced with fierce competition and rising operating costs, firms are feeling the pressure to build a well-oiled marketing and business development team that supports strategic priorities, but they’ll need to be flexible and creative given a tight talent market, says Ben Curle at Ambition.
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Rock Climbing Makes Me A Better Lawyer
Rock climbing requires problem-solving, focus, risk management and resilience, skills that are also invaluable assets in my role as a finance lawyer, says Mei Zhang at Haynes and Boone.
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Contract Disputes Recap: Preserving Payment Rights
Stephanie Magnell and Zachary Jacobson at Seyfarth examine three recent decisions that together illustrate the importance of keeping accurate records and adhering to contractual procedures to avoid inadvertently waiving contractual rights to cost reimbursements or nonroutine payments.
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Think Like A Lawyer: Dance The Legal Standard Two-Step
From rookie brief writers to Chief Justice John Roberts, lawyers should master the legal standard two-step — framing the governing standard at the outset, and clarifying why they meet that standard — which has benefits for both the drafter and reader, says Luke Andrews at Poole Huffman.
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Lead Like 'Ted Lasso' By Embracing Cognitive Diversity
The Apple TV+ series “Ted Lasso” aptly illustrates how embracing cognitive diversity can be a winning strategy for teams, providing a useful lesson for law firms, which can benefit significantly from fresh, diverse perspectives and collaborative problem-solving, says Paul Manuele at PR Manuele Consulting.
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Now More Than Ever, Lawyers Must Exhibit Professionalism
As society becomes increasingly fractured and workplace incivility is on the rise, attorneys must champion professionalism and lead by example, demonstrating how lawyers can respectfully disagree without being disagreeable, says Edward Casmere at Norton Rose.
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Reading Between The Lines Of Justices' Moore Ruling
The U.S. Supreme Court's recent Moore v. U.S. decision, that the Internal Revenue Code Section 965 did not violate the 16th Amendment, was narrowly tailored to minimally disrupt existing tax regimes, but the justices' various opinions leave the door open to future tax challenges and provide clues for what the battles may look like, say Caroline Ngo and Le Chen at McDermott.
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A Midyear Forecast: Tailwinds Expected For Atty Hourly Rates
Hourly rates for partners, associates and support staff continued to rise in the first half of this year, and this growth shows no signs of slowing for the rest of 2024 and into next year, driven in part by the return of mergers and acquisitions and the widespread adoption of artificial intelligence, says Chuck Chandler at Valeo Partners.
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States Should Loosen Law Firm Ownership Restrictions
Despite growing buzz, normalized nonlawyer ownership of law firms is a distant prospect, so the legal community should focus first on liberalizing state restrictions on attorney and firm purchases of practices, which would bolster succession planning and improve access to justice, says Michael Di Gennaro at The Law Practice Exchange.
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After Chevron: Uniform Tax Law Interpretation Not Guaranteed
The loss of Chevron deference will significantly alter the relationship between the IRS, courts and Congress when it comes to tax law, potentially precipitating more transparent rulemaking, but also provoking greater uncertainty due to variability in judicial interpretation, say Michelle Levin and Carneil Wilson at Dentons.
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Texas Ethics Opinion Flags Hazards Of Unauthorized Practice
The Texas Professional Ethics Committee's recently issued proposed opinion finding that in-house counsel providing legal services to the company's clients constitutes the unauthorized practice of law is a valuable clarification given that a UPL violation — a misdemeanor in most states — carries high stakes, say Hilary Gerzhoy and Julienne Pasichow at HWG.