International

  • May 20, 2024

    India's Top Court Says Accounting Body Can Limit Tax Audits

    India's regulatory association for accountants has the authority to limit the amount of tax audits performed by an individual accountant to 60, the Supreme Court of India ruled — even as it canceled ongoing disciplinary proceedings over the restriction because of inconsistent enforcement.

  • May 20, 2024

    IRS Guidance Plan Should Cover Corp. AMT, AICPA Says

    The Internal Revenue Service should provide guidance on the definitions and applications of the 15% corporate alternative minimum tax, among other topics, the American Institute of Certified Public Accountants said in comments published by the agency Monday.

  • May 20, 2024

    Turkey Will Introduce 15% Global Minimum Tax, Minister Says

    The Turkish government will introduce the 15% global minimum corporate tax and will not provide any incentives that would allow companies to pay a lower rate, the country's finance minister told its public broadcaster Monday.

  • May 20, 2024

    Isle Of Man Commits To Portion Of Global Minimum Tax

    The Isle of Man plans to introduce legislation implementing the qualified domestic minimum top-up tax portion of the OECD's Pillar Two directive starting in 2025 but is less committed to adopting the income inclusion rule, the island's Treasury said Monday.

  • May 20, 2024

    HMRC Lays Out Registration Rules For Pillar 2

    Companies covered by the U.K.'s implementation of the Organization for Economic Cooperation and Development's Pillar Two global minimum tax directive must register with HM Revenue & Customs within six months of the accounting period that makes them eligible, the agency said Monday.

  • May 20, 2024

    US, Argentina To Carry Out 1st FATCA Info Exchange

    The Internal Revenue Service approved cybersecurity measures by Argentina in a step that clears the way for the first automatic information exchange under the Foreign Account Tax Compliance Act between the two countries in September, Argentina's revenue service said Monday.

  • May 17, 2024

    Med Device Co. Allowed $160M In Deductions, Tax Court Told

    A tax code provision in place before the 2017 federal tax overhaul changed it allows a medical device manufacturer to claim more than $160 million in deductions for dividends despite the government's attempt to apply the law retroactively, company counsel told the U.S. Tax Court on Friday.

  • May 17, 2024

    Michigan Doctor Seeks Release From Contempt In FBAR Fight

    A Michigan doctor incarcerated for civil contempt in a case in which he was ordered to repay more than $1 million in penalties for failure to report foreign accounts should be freed because he can no longer satisfy the terms of his release, he told a Michigan federal court.

  • May 17, 2024

    Koch-Tied Group Says Transparency Law Offends Federalism

    The Corporate Transparency Act is unconstitutional because it does not regulate interstate commerce yet mandates that state-registered entities disclose personal information, a conservative group affiliated with the billionaire Koch brothers told the Eleventh Circuit on Friday.

  • May 17, 2024

    Credit Suisse Can't Reverse $21.3M Biz Loss Denial

    Credit Suisse cannot carry forward $21.3 million in business losses from 2015-2017 to its 2018 Michigan tax return, a state appeals court said, letting stand a ruling that the bank miscalculated its business income from those years on its returns.

  • May 17, 2024

    New Domestic Content Guidance May Boost Energy Credits

    The U.S. Treasury Department's new guidance on bonus tax credits for clean energy projects that source domestic-made materials and components aims to simplify the process for determining eligibility and spur more development to get those extra incentives.

  • May 17, 2024

    Italian Financial Police Uncover €1B Tax Credit Scam

    The Italian Financial Police placed more than 300 people under investigation after uncovering a scheme to collect more than €1 billion ($1.09 billion) in tax credits designed to promote construction and energy matters, authorities said.

  • May 17, 2024

    Transfer Pricing Deal Needed For Pillar 1, OECD Official Says

    It's crucial for countries to agree on transfer pricing policies under an international profit reallocation agreement known as Pillar One as they work toward their end-of-June deadline to sign a related multilateral treaty, an OECD official said Friday.

  • May 17, 2024

    New Dutch Gov't Outlines Range Of Tax Measures

    The incoming Dutch government has outlined numerous tax measures affecting companies and individuals in its preliminary coalition agreement, a government document showed.

  • May 17, 2024

    UK, Peru Agree To Double-Tax Treaty

    The U.K. and Peru reached a deal on a treaty to prevent double taxation after several years of discussion, the countries said Friday.

  • May 17, 2024

    Taxation With Representation: Wachtell Lipton, Freshfields

    In this week's Taxation with Representation, Nippon Life acquires Corebridge Financial, Crescent Energy buys SilverBow Resources and Uber purchases Foodpanda.

  • May 16, 2024

    Pillar 1 Faces Hard June Deadline, Ex-Treasury Official Says

    An international agreement to reallocate certain corporate profits, known as Pillar One, will likely stall if countries miss their deadline to sign a multilateral treaty by the end of June, a former U.S. Treasury official said Thursday.

  • May 16, 2024

    Australian Lawmakers OK Tougher Corporate Promoter Rules

    Australian lawmakers agreed Thursday to raise maximum penalties on corporations that promote tax avoidance schemes and to introduce a cap on deductions under its petroleum resource rent tax despite concerns from some members, according to documents published by Parliament.

  • May 16, 2024

    P&G Exec Says FDII Uncertainty May Sway Cos.' IP Decisions

    The 2017 tax overhaul's measure for foreign-derived intangible income, a regime that gives tax breaks for domestically held intellectual property, faces uncertainty that could be one factor in keeping some companies from repatriating IP, a tax executive for Procter & Gamble said Thursday.

  • May 16, 2024

    Eaton Must Give Up Personnel Docs In Transfer Pricing Probe

    Eaton must comply with an Internal Revenue Service summons for the personnel records of its foreign employees in the government's transfer pricing investigation of the multinational power management company, an Ohio federal judge ruled Thursday.

  • May 16, 2024

    African Tax Admins Promote Use Of Voluntary Disclosures

    Voluntary disclosure programs have been very effective when countries launch them in anticipation of complying with an international standard on automatic exchanges of financial account information, the African Tax Administration Forum said Thursday in guidance on the programs.

  • May 16, 2024

    Kenya Considering Global Minimum Tax, DST Replacement

    Kenya is considering legislation that would implement the Organization for Economic Cooperation and Development's corporate global minimum tax as well as repeal and replace the country's digital services tax.

  • May 16, 2024

    Germany's 2024 Tax Revenue Estimate Drops By €14B

    Germany's 2024 tax revenue estimate decreased by roughly €14 billion ($15.2 billion) to €950.3 billion from the estimate made last fall, which its finance ministry said Thursday was due to slower-than-expected economic recovery.

  • May 16, 2024

    Suspected Ringleader Of €2M Cosmetics VAT Fraud Arrested

    The suspected ringleader of a value-added tax fraud scheme at a cosmetics company that caused more than €2 million ($2.2 million) in estimated losses has been arrested by Italian police, the European Public Prosecutor's Office said Thursday.

  • May 16, 2024

    EU Tax On Excess Corp Profits Could Yield €107B, Study Says

    A European Union tax on excessive corporate profits could yield about €107 billion ($116 billion) to partly finance the common EU budget or other urgent investments, leftists in the European Parliament said Thursday.

Expert Analysis

  • Pro Bono Work Is Powerful Self-Help For Attorneys

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    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.

  • The Pop Culture Docket: Judge Espinosa On 'Lincoln Lawyer'

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    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.

  • How And Why Your Firm Should Implement Fixed-Fee Billing

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    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.

  • How Law Firms Can Use Account-Based Marketing Strategies

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    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.

  • Strategic Succession Planning At Law Firms Is Crucial

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    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.

  • Maximizing Law Firm Profitability In Uncertain Times

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    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.

  • 5th Circ. Ruling Reminds Attys That CBP Can Search Devices

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    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.

  • Enforcement Of International Tax Reporting Is Heating Up

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    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.

  • IRS Notice Clarifies R&E Amortization, But Questions Remain

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    The IRS and Treasury Department’s recent notice clarifying the treatment of specified research and experimental expenditures under Section 174 provides taxpayers and practitioners with substantive guidance, but it misses the mark in delineating which expenditures are amortizable, say attorneys at Eversheds Sutherland.

  • Preparing Your Legal Department For Pillar 2 Compliance

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    Multinational entities should familiarize themselves with Pillar Two of the Organization for Economic Cooperation and Development’s BEPs 2.0 project and prepare their internal legal tracking systems for related reporting requirements that may go into effect as early as January, says Daniel Robyn at Ernst & Young.

  • What Large Language Models Mean For Document Review

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    Courts often subject parties using technology assisted review to greater scrutiny than parties conducting linear, manual document review, so parties using large language models for document review should expect even more attention, along with a corresponding need for quality control and validation, say attorneys at Sidley.

  • Participating In Living History Makes Me A Better Lawyer

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    My role as a baron in a living history group, and my work as volunteer corporate counsel for a book series fan association, has provided me several opportunities to practice in unexpected areas of law — opening doors to experiences that have nurtured invaluable personal and professional skills, says Matthew Parker at the Nebraska Department of Health and Human Services.

  • Private Equity Owners Can Remedy Law Firms' Agency Issues

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    Nonlawyer, private-equity ownership of law firms can benefit shareholders and others vulnerable to governance issues such as disparate interests, and can in turn help resolve agency problems, says Michael Di Gennaro at The Law Practice Exchange.

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