International

  • December 03, 2024

    Australia Expects Royalties, Reporting Guidance In Early 2025

    The Australian Taxation Office said it expects to release draft guidance in February related to a ruling on when payment agreements for software are considered royalties, followed by guidance for exemptions from its new country-by-country reporting laws in March.

  • December 03, 2024

    Charity's Ex-Partner Gets 10 Years For £1.5M Gift Aid Fraud

    A former finance business partner at national charity Save The Children UK has been jailed for 10 years for stealing £1.5 million ($1.9 million) through fraudulent Gift Aid claims, HM Revenue & Customs announced Tuesday.

  • December 03, 2024

    Comment Deadline Extended For Corp. Alternative Min. Tax

    Treasury and the Internal Revenue Service said Tuesday that they will accept comments on proposed rules for the new 15% corporate alternative minimum tax on corporations with reported profits of $1 billion or more until Jan. 16, a roughly one-month extension from the previous deadline.

  • December 02, 2024

    Russia Looks To 4 FSIA Cases In Bid To Stay $5B Award Suit

    Russia urged a D.C. federal judge to pause a case against it by a Yukos Oil Co. unit seeking to enforce $5 billion in arbitral awards, saying Monday that four parallel Foreign Sovereign Immunities Act cases are pending before the Supreme Court and the D.C. Circuit that could affect the suit.

  • December 02, 2024

    Texas Truck Co. Owes Chinese Tire Import Tax, 5th Circ. Says

    A Houston truck company that sold tires made by a Chinese manufacturer is on the hook for excise taxes as the beneficial owner of the tires, the Fifth Circuit decided in an opinion Monday that reversed a ruling freeing the company from its nearly $2 million tax bill.

  • December 02, 2024

    'Harry Potter' Actor Must Pay £1.8M Tax Bill, Tribunal Says

    Actor Rupert Grint, who portrayed Ron Weasley in the Harry Potter film series, faces a £1.8 million ($2.3 million) tax bill after the U.K.'s First-tier Tribunal ruled that tax avoidance was a primary purpose of an entity created to manage his career.

  • December 02, 2024

    IRS Floats Pooling, Annual Accounting In Offshore Profit Regs

    U.S. multinational companies will be required to create annual shareholder accounts and adhere to new pooling concepts to properly account for previously taxed earnings and profits under proposed rules floated by the U.S. Treasury Department and Internal Revenue Service.

  • December 02, 2024

    A&O Shearman Tax Pro Jumps To Hogan Lovells In DC

    Hogan Lovells said Monday that it has brought on a former Allen Overy Shearman Sterling tax partner who specializes in spinoffs, cross-border deals and other corporate transactions.

  • December 02, 2024

    IRS Finalizes Partnership Liability Regs After 11 Years

    The Internal Revenue Service unveiled final regulations governing the allocation of partnership liabilities 11 years after releasing the proposed rules, saying no subsequent legislative and regulatory changes had taken place to compel the agency to otherwise renew the rulemaking process.

  • December 02, 2024

    Australia Passes Public Country-By-Country Reporting

    Multinational businesses with large operations in Australia are required to publicly disclose information about their operations in tax havens as designated by the government under a country-by-country reporting law that lawmakers adopted following a two-year saga over concerns about the data's confidentiality.

  • December 02, 2024

    Skat Settles With Ex-Barclays Director In £1.4B Fraud Case

    The Danish tax authority has settled its claim against a former Barclays Capital director and four companies that it sued alongside dozens of others over an alleged scheme to defraud it of £1.4 billion ($1.8 billion) in tax revenue.

  • December 02, 2024

    Sports Direct's Ashley Says HMRC Bungled His Data Request

    Sports Direct International PLC founder Michael Ashley argued in a London court Monday that the U.K.'s tax agency improperly handled his data request related to its probe into his 2012 sale of real estate assets, calling its alleged failings "significant, wide-spread and persistent."

  • December 02, 2024

    Australia Seeks Input On Tax Treaty With Portugal

    Australia's Treasury is looking for feedback on plans to implement a treaty with Portugal that would address concerns of double taxation and alleviate cross-border costs by establishing lower withholding rates, the agency said Monday.

  • December 02, 2024

    5 Convicted In €14M COVID Test VAT Fraud Scheme

    A German court convicted five people for their roles in a value-added tax fraud scheme involving the sale of COVID-19 tests that caused about €14 million ($14.7 million) in VAT losses, the European Public Prosecutor's Office said.

  • November 29, 2024

    Audit Watchdog Urges EU To Curb Harmful Tax Practices

    The European Union is still not doing enough to stop harmful corporate tax practices that are costing governments more than €100 billion ($105 billion) a year in revenue, the bloc's independent audit watchdog has warned.

  • November 28, 2024

    Police Detain 32 People In Raids On €297M VAT Fraud Network

    Police have detained more than 30 people in raids on a €297 million ($313 million) value-added tax fraud network that spanned 16 EU countries, the European Public Prosecutor's Office said Thursday.

  • November 28, 2024

    EU Closes Tax Investigations Into Amazon, Fiat, Starbucks

    The European Commission said Thursday that it is closing tax investigations into three multinational companies — Amazon, Fiat and Starbucks — following a series of high-profile court decisions.

  • November 28, 2024

    Ex-HMRC Compliance Officer Helped Husband Launder £3M

    A former compliance officer with HM Revenue and Customs has been handed a suspended sentence for her role in a £3 million ($3.8 million) money laundering operation carried out by her husband, the Crown Prosecution Service has said.

  • November 28, 2024

    AXA Loses Time Limits Appeal In HMRC Foreign Tax Claim

    Insurer AXA has lost its fight over time limits for bringing claims for restitution against the British tax authority over taxes collected in violation of European Union law, as a London appeals court ruled that the limits could not be extended.

  • November 27, 2024

    UN Approves Start Of Formal Talks On Global Tax Convention

    The United Nations General Assembly voted Wednesday in favor of beginning formal negotiations on a global tax convention next year with the goal of finishing in 2027, a proposal that was led by the body's African bloc and won support from 125 countries.

  • November 27, 2024

    US Says Prof's 8th Amendment Argument Fails In FBAR Case

    An 86-year-old former professor cannot claim that his $545,000 penalty for failing to report foreign bank accounts violates the Eighth Amendment, the U.S. told a federal court, saying the penalty is neither excessive nor a fine, and that he never raised the argument before.

  • November 27, 2024

    BlueCrest Disputes 'Disguised Salary' Claim In HMRC Case

    British-American hedge fund BlueCrest Capital Management LLP pushed back Wednesday against arguments from the U.K. tax authority that its portfolio managers are employees receiving a disguised salary.

  • November 27, 2024

    US Seeks FBAR Penalties Over $1.7M In Foreign Accounts

    A Texas woman should face penalties for willfully failing to disclose foreign bank accounts from 2011 through 2013, which held balances exceeding $1.7 million, the U.S. government told a federal court Wednesday.

  • November 27, 2024

    UK Gambling Levy Would Generate £100M, Gov't Says

    A new levy on U.K. gambling operations would generate £100 million ($127 million), which would be earmarked for funding various ways to combat problem gambling, a government agency said Wednesday.

  • November 27, 2024

    Info On €12T In Assets Swapped Last Year, OECD Says

    Tax jurisdictions using the Organization for Economic Cooperation and Development's automatic exchange of information frameworks swapped information on 134 million financial accounts last year, representing nearly €12 trillion ($12.7 trillion) in assets, according to an OECD forum report.

Expert Analysis

  • How Clients May Use AI To Monitor Attorneys

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    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.

  • The Pop Culture Docket: Judge D'Emic On Moby Grape

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    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.

  • Breaking Down High Court's New Code Of Conduct

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    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.

  • Legal Profession Gender Parity Requires Equal Parental Leave

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    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.

  • A Year-End Look At Florida's Capital Investment Tax Credit

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    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.

  • Understanding Discovery Obligations In Era Of Generative AI

    Excerpt from Practical Guidance
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    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.

  • The Case For Post-Bar Clerk Training Programs At Law Firms

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    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.

  • AI Can Help Lawyers Overcome The Programming Barrier

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    Legal professionals without programming expertise can use generative artificial intelligence to harness the power of automation and other technology solutions to streamline their work, without the steep learning curve traditionally associated with coding, says George Zalepa at Greenberg Traurig.

  • Preparing Law Students For A New, AI-Assisted Legal World

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    As artificial intelligence rapidly transforms the legal landscape, law schools must integrate technology and curricula that address AI’s innate challenges — from ethics to data security — to help students stay ahead of the curve, say Daniel Garrie at Law & Forensics, Ryan Abbott at JAMS and Karen Silverman at Cantellus Group.

  • General Counsel Need Data Literacy To Keep Up With AI

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    With the rise of accessible and powerful generative artificial intelligence solutions, it is imperative for general counsel to understand the use and application of data for myriad important activities, from evaluating the e-discovery process to monitoring compliance analytics and more, says Colin Levy at Malbek.

  • Navigating Discovery Of Generative AI Information

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    As generative artificial intelligence tools become increasingly ubiquitous, companies must make sure to preserve generative AI data when there is reasonable expectation of litigation, and to include transcripts in litigation hold notices, as they may be relevant to discovery requests, say Nick Peterson and Corey Hauser at Wiley.

  • Finding Focus: Strategies For Attorneys With ADHD

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    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.

  • Attorneys, Law Schools Must Adapt To New Era Of Evidence

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    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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