International
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July 29, 2024
Utah Biz Groups Latest To Challenge Corp. Disclosure Law
Several small-business associations in Utah became the latest group to challenge the Corporate Transparency Act's disclosure requirements, telling a federal court Monday the statute violates several constitutional provisions, including the guarantee of due process.
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July 29, 2024
Immigrants Paid $96.7B In Taxes In 2022, ITEP Study Says
Unauthorized immigrants paid $96.7 billion in federal, state, and local taxes in 2022 but received few benefits in return, according to a new study released Monday, whose authors said granting such taxpayers work authorization would boost tax revenue and economic activity.
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July 29, 2024
Sites Should Pay Sport Fishing, Archery Import Tax, GAO Says
Congress should make U.S. online marketplaces responsible for any sport fishing and archery excise taxes owed on consumer import sales they're involved with, the Government Accountability Office said in a report released Monday.
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July 29, 2024
UK Seeks Input On Rule Targeting Min. Tax's Safe Harbor
HM Revenue & Customs opened a consultation Monday seeking comments on an anti-arbitrage rule to help prevent large multinational companies from exploiting the safe harbor provision in the Organization for Economic Cooperation and Development's global minimum tax.
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July 29, 2024
ECJ Nixes Swedish Dividends Tax On Foreign Pension Funds
Sweden can't collect a withholding tax on dividends distributed by Swedish companies to public pension funds abroad while exempting its own public funds because that is inconsistent with European Union law requiring the free movement of capital, the European Court of Justice said Monday.
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July 29, 2024
France Restricts Access To Beneficial Ownership Registry
France is dialing back access to its beneficial ownership information registry by introducing what it is calling a filtering system that limits the previously entirely public database starting Wednesday, the French Finance Ministry said Monday.
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July 29, 2024
Gov't Consults On Tax Hikes For Fund Managers, Non-Doms
Chancellor Rachel Reeves said Monday that an autumn Budget planned for Oct. 30 will include feature selected tax rises, a warning accompanied by strong hints from HM Treasury that fund managers and non-domicile taxpayers could take a bigger hit.
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July 29, 2024
EU's Highest Court Upholds Disclosure Law
The European Union's highest court on Monday upheld the bloc's law requiring tax advisers to report potentially aggressive cross-border tax arrangements, rejecting a challenge from Belgian tax attorneys who said their country's implementation of the EU's DAC6 law violated European law.
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July 26, 2024
G20 Declines To Back Brazil's Plan For A Minimum Wealth Tax
Finance ministers from the Group of 20 nations declined to back Brazil's proposal for an agreement on individual wealth taxation similar to the global corporate minimum tax, instead issuing a statement Friday that opted for softer language about cooperation.
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July 26, 2024
Biz Groups Call Corp. Transparency Act Unconstitutional
The U.S. government has failed to show how the Corporate Transparency Act meets narrow exceptions to the Fourth Amendment's search warrant requirements, a group of small businesses told a Michigan federal court Friday in contending that the statute is unconstitutional.
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July 26, 2024
Denmark's Tax Losses From Evasion Fell 70%, Study Says
Denmark's tax losses from offshore evasion by individuals dropped 70% following the implementation of the automatic exchange of banking information between tax authorities, researchers found in a study of the Danish Tax Agency's data.
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July 26, 2024
Chile Considering New Tax Compliance Measures
Chile's Senate Finance Committee approved a tax compliance measure that includes creating an anonymous whistleblower process related to tax crimes, a lifting of bank secrecy measures and an overall modernization of the country's revenue agency, the country's Ministry of Finance said.
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July 26, 2024
Denmark Says Pension Plans Misread Law In $2B Fraud Case
U.S. pension plans accused by Denmark's tax agency of participating in a $2.1 billion fraud scheme involving withholding tax refunds are misconstruing Danish law as it applies to the ownership of shares, the agency told a New York federal court.
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July 26, 2024
Two Admit Trying To Bribe IRS Official On China's Behalf
Two people admitted to secretly acting on behalf of the Chinese government and bribing an undercover agent in connection with a scheme to revoke the tax-exempt status of U.S. participants in a spiritual practice banned in China, according to New York federal court filings.
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July 26, 2024
Taxation With Representation: Wachtell, Polsinelli, Kirkland
In this week's Taxation With Representation, T-Mobile partners with KKR to acquire Metronet, Exclusive Networks gets a takeover offer, KKR buys Instructure Holdings Inc., and Bally's Corp. merges with The Queen Casino & Entertainment Inc.
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July 26, 2024
Australia Clarifies Tax Treatment Of Exploration, Land Rights
The Australian government has amended its petroleum resource rent tax to clarify what is considered "exploration for petroleum" for tax purposes, and changes are coming soon regarding the depreciation of mining, quarrying and prospecting rights, the Australian Taxation Office said.
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July 26, 2024
EU Closes Investigation Into Repealed Hungarian Ad Tax
The European Commission said Friday it has closed its nearly decadelong investigation into a Hungarian advertisement tax that it said violated the European Union's state aid rules, noting that the country has repealed the law in question.
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July 26, 2024
EU Frees Up €1.5B Of Frozen Russian Assets To Aid Ukraine
The European Union's executive branch said Friday that it is freeing up €1.5 billion ($1.6 billion) of revenue generated from immobilized Russian assets to aid Ukraine in defending itself against the Russian invasion.
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July 25, 2024
Global Tax Revamp Continues To Progress, OECD Tells G20
Implementation of the Pillar Two minimum tax portion of the OECD's international plan to address tax base erosion and profit shifting is well underway, while an agreement is close on the Pillar One taxing rights overhaul, the organization told the Group of 20 nations Thursday.
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July 25, 2024
UK Telecom Co. Owes VAT For Phone Plans In £51M Dispute
A U.K. telecommunications provider will not recover £51.1 million ($65.7 million) in value-added tax payments after the First-tier Tribunal ruled that VAT is chargeable on phone plans from the point of sale, not when the services are used.
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July 25, 2024
Global Tax Police Unit Probes More Than 30 Cybercrime Cases
The Joint Chiefs of Global Tax Enforcement, an intergovernmental tax enforcement group, is investigating more than 30 active cybercrime cases tied to financial and tax criminal activities all over the world, the group announced Thursday in its first report.
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July 25, 2024
Income Inequality Calls For Stronger Tax Policies, OECD Says
More focus is being drawn to stronger tax policies as a way to solve persistent income inequality, especially in light of the continually increasing concentration of wealth by the top 0.001% of earners, the Organization for Economic Cooperation and Development said Thursday.
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July 25, 2024
Mixed Progress Made On Beneficial Ownership, OECD Says
The U.S., Japan and the European Union now have wide-reaching beneficial ownership registries in place, but many jurisdictions worldwide aren't effectively exchanging data on the owners of legal entities, the OECD said Thursday in a report based on peer reviews.
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July 25, 2024
Australian Officials Defend Basis for Tax Reporting Framework
Australia's public corporate tax disclosure legislation builds on global standards that could provide more insights into profit shifting risks than European Union reporting rules, Australian government officials said Thursday in response to calls for closer alignment between the two regimes.
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July 25, 2024
Billionaire Tax Not Fit For Global Agreement, Yellen Says
The U.S. government doesn't think it's appropriate to seek a global agreement on taxing billionaires, Treasury Secretary Janet Yellen said Thursday ahead of a discussion by the Group of 20 nations on coordinating wealth taxes.
Expert Analysis
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A Year-End Look At Florida's Capital Investment Tax Credit
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.
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Understanding Discovery Obligations In Era Of Generative AI
Excerpt from Practical Guidance
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.
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The Case For Post-Bar Clerk Training Programs At Law Firms
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.
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AI Can Help Lawyers Overcome The Programming Barrier
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.
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Preparing Law Students For A New, AI-Assisted Legal World
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.
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General Counsel Need Data Literacy To Keep Up With AI
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.
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Navigating Discovery Of Generative AI Information
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.
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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.