International

  • June 05, 2024

    EU Corp. Tax Proposal Delayed By Uncertainty On OECD Plan

    European Union countries' negotiations on a proposal to streamline corporate taxation have been delayed because of a lack of clarity on implementation of the OECD's global minimum tax and the design of the accompanying reallocation of taxing rights, a top European Commission tax official said Wednesday.

  • June 05, 2024

    OECD Official Hopes Pillar 2 Ends Some 'Wasteful' Incentives

    The introduction of the global minimum corporate tax known as Pillar Two should lead to the end of some "wasteful" incentives that narrow the tax base, an official from the Organization for Economic Cooperation and Development said Wednesday.

  • June 05, 2024

    Labour's Pension Tax Plans Backed By Fiscal Research Body

    An influential economics think tank has backed plans by the Labour Party to reintroduce the lifetime allowance, arguing that there should be a cap on the tax-free accumulation of pensions wealth.

  • June 04, 2024

    Full DC Circ. Asked To Weigh Foreign Info Disclosure Penalties

    A D.C. Circuit panel made questionable assumptions about congressional intent when it revived the IRS' authority to assess and administratively collect penalties related to undisclosed foreign corporations, a businessman said Tuesday in asking the full appellate court to hear his case.

  • June 04, 2024

    Australian Court Upholds Ex-Chinese Citizen's $7.7M Tax Bill

    An Australian court upheld an AU$11.5 million ($7.7 million) tax bill from the Australian Taxation Office to a former Chinese citizen after determining he failed to provide enough evidence to support his alternative tax liability calculation.

  • June 04, 2024

    Calif. OTA Rejects Couple's Claim Of Bolivia Residency

    A California couple owes additional state income tax on a retirement account distribution, the state Office of Tax Appeals said in an opinion released Tuesday, rejecting the pair's assertion that they were domiciled in Bolivia at the time.

  • June 04, 2024

    EU OKs Italian Renewable Energy Plan Funded By Levy

    The European Commission said Tuesday that it approved Italy's plan to introduce a levy on the electricity bills of final consumers to fund construction of renewable energy plants, finding the benefits far outweigh any potential damage to competition and trade.

  • June 04, 2024

    Spain Sends Pillar 2 Bill To Legislature After EU Pressure

    The Spanish government announced Tuesday it has sent a bill to its legislature that would transpose the European Union directive to implement the Organization for Economic Cooperation and Development's global minimum tax on large corporations following pressure from the bloc.

  • June 04, 2024

    New Dutch Gov't Seen Returning To Pro-Biz Positions

    The incoming conservative Dutch government is expected to adopt tax policies that align with the Netherlands' long-standing reputation as a tax-friendly jurisdiction for businesses, in part by reversing a recently enacted measure that taxed companies' purchases of their own shares.

  • June 04, 2024

    Luxembourg Candidate Calls To End EU Tax Unanimity Rule

    The leading Socialist candidate in the upcoming European parliamentary elections said the European Union should scrap the need for unanimity for all tax decisions, clashing with his home country of Luxembourg's longtime stand that's meant to protect its status as a financial center.

  • June 04, 2024

    Austrian Authorities Reveal Spike In Fake Companies

    The number of fake companies in Austria is increasing, according to data from the Finance Ministry, which said that it hoped a new law would aid in combating the trend.

  • June 03, 2024

    Danish Tax Agency Says $2.1B Tax Fraud Suits Not Filed Late

    Denmark's tax administrator urged a New York federal court to reject bids to toss its suits against U.S. pension plans and individuals it accuses of participating in a $2.1 billion fraud scheme, saying the suits were not filed too late.

  • June 03, 2024

    Treasury Aims To Salvage Corp. Transparency Act At 11th Circ.

    The Corporate Transparency Act is a valid exercise of congressional authority to curb money laundering under the commerce clause and the necessary and proper clause in the Constitution, the U.S. Treasury Department told the Eleventh Circuit on Monday in a bid to restore the law's reporting requirements.

  • June 03, 2024

    Tax Convictions Withstand Poor Counsel Claim, 4th Circ. Says

    A North Carolina man's claim of ineffective counsel is not sufficient reason to vacate his convictions for filing false tax returns and obstructing an official proceeding in a case involving $2.1 million in unreported income sent from Bermuda entities, the Fourth Circuit ruled.

  • June 03, 2024

    Texas Oil Co. Says IRS Hasn't Paid $36M Promised Refund

    The Internal Revenue Service has promised to pay a Texas oil company more than $36 million in tax refunds and credits for the 2009 tax year but has failed to do so, the company told a federal court.

  • June 03, 2024

    African Gov'ts Made Big Gains From Data Swaps In 2023

    African tax authorities made huge headway last year in using the international standard for exchange of information on request to find additional revenues of €2.2 billion ($2.4 billion), which is more than over the past 13 years combined, the OECD reported Monday.

  • June 03, 2024

    UK Liberal Democrats Call For Buyback Tax, Tripling DST

    The U.K. Liberal Democrat party called for a 4% share buyback tax on the 100 largest corporations on the stock market as well as for tripling the country's 2% digital services tax, with the additional revenue generated to be earmarked to benefit schoolchildren.

  • June 03, 2024

    South Korea Extending Tax Breaks For Growing Businesses

    Companies in South Korea that graduate from being considered small and medium enterprises to middle-market enterprises will see the grace period that allows them to continue to receive tax breaks granted to smaller entities extended, the country's finance ministry said Monday.

  • June 03, 2024

    7 Arrested In €18M Italian VAT Fraud Ring

    Financial police in Italy arrested seven suspects Monday in connection with a value-added tax fraud scheme involving beverages that resulted in losses of €18 million ($19.6 million), the European Public Prosecutor's Office said.

  • June 03, 2024

    EU Court Asked To Rule On Belgian Tax On Dividends

    A Belgian court asked the European Union's highest court to rule on whether the country can tax dividends transferred from a subsidiary to a parent company, despite an EU law apparently prohibiting this, a document published Monday showed.

  • June 01, 2024

    Blockbuster Summer: 10 Big Issues Justices Still Must Decide

    As the calendar flips over to June, the U.S. Supreme Court still has heaps of cases to decide on issues ranging from trademark registration rules to judicial deference and presidential immunity. Here, Law360 looks at 10 of the most important topics the court has yet to decide.

  • May 31, 2024

    3M Tells 8th Circ. IRS Used Invalid Regs For $24M Allocation

    Multinational conglomerate 3M reiterated Friday its bid for the Eighth Circuit to reverse a U.S. Tax Court decision allowing the IRS to allocate nearly $24 million from the company's Brazilian affiliate, arguing the agency's adjustment relied on substantively invalid regulations.

  • May 31, 2024

    IRS Guidance Narrows Spinoffs Available For Preapproval

    Recent IRS guidance limiting the types of spinoff transactions that revenue officials will approve as tax-free ahead of time leaves practitioners and corporations to determine whether to pursue certain intercompany reorganizations without the agency's blessing.

  • May 31, 2024

    Ex-UBS Exec Owes $4.7M In FBAR Penalties, Court Told

    A former CEO of Swiss bank UBS' North American group faces a $4.7 million tax bill that the U.S. claims is due because he did not report his foreign bank accounts or assets, according to a suit filed in Connecticut federal court.

  • May 31, 2024

    US, Bulgaria Sign Country-By-Country Reporting Agreement

    The U.S. and Bulgaria signed an agreement Friday on the automatic exchange of country-by-country reports between the nations, Bulgaria's Ministry of Finance said.

Expert Analysis

  • 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.

  • 1st Tax Easement Convictions Will Likely Embolden DOJ, IRS

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    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.

  • Tips For Litigating Against Pro Se Parties In Complex Disputes

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    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.

  • Anticipating Intensified Partnership Enforcement From IRS

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    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.

  • 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.

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