International

  • August 12, 2024

    VAT Fraudster In Austria Sentenced To 15 Months In Prison

    A 55-year-old was convicted of value-added tax fraud while trading in protective masks, Austria's Finance Ministry said in a news release.

  • August 10, 2024

    Kyocera Targets Treasury TCJA Reg, Seeking $7M Tax Refund

    The Treasury Department acted outside its bounds by issuing a regulation changing the effective date of the 2017 tax overhaul, electronics maker Kyocera argued as it urged a South Carolina federal court to void the regulation and approve the company's claim for $7 million tax refund.

  • August 09, 2024

    Partnership Clarity Expected In First Offshore Profits Rules

    Tax attorneys anticipate answers to several questions about how partnerships should properly track, report and attribute foreign income previously taxed in the U.S. when the first round of long-awaited proposed rules is published.

  • August 09, 2024

    IRS Wrongly Penalizes For Unreported Inheritance, Court Told

    The Internal Revenue Service violated the constitutional rights of a California woman when penalizing her $92,000 for failing to report inheriting $350,000 from a parent who had lived in the U.K., the woman told a federal court.

  • August 09, 2024

    Israel Resident Says She Was Never Notified Of $9M Tax Debt

    The daughter of a dead Brooklyn rabbi was a permanent resident of Israel in the early years of this century and never received IRS notices about $9.2 million in taxes and penalties, she told a New York court Friday in arguing that she doesn't owe the money.

  • August 09, 2024

    AI Helped Uncover €185M In Austrian Tax Revenue In 2023

    A special unit in Austria's Ministry of Finance used an artificial intelligence tool to help discover tax fraud cases, generating roughly €185 million ($202 million) in tax revenue in 2023, the ministry said Friday.

  • August 09, 2024

    Bermuda Seeks Comments On Administration Of Minimum Tax

    Bermuda is looking for comments on proposed administrative changes that would accompany its implementation of the OECD's 15% global corporate minimum tax on large multinational entities, including how in-scope businesses will register with the country's new Corporate Income Tax Agency.

  • August 09, 2024

    3 Indicted On Charges Of Leading €93M VAT Fraud Scheme

    Three people suspected of heading a criminal scheme that carried out €93 million ($102 million) in value-added tax fraud involving primarily Apple AirPods have been indicted in Germany, the European Public Prosecutor's Office said Friday.

  • August 09, 2024

    Australia Seeks To Take Pepsi Royalty Tax Fight To Top Court

    The Australian Taxation Office asked the country's top court for permission to appeal a decision that payments between PepsiCo subsidiaries did not qualify for royalty withholding tax or diverted profits tax, according to a news release Friday.

  • August 09, 2024

    What Books Tax Pros Recommend For This Summer

    As practitioners monitor the tax implications of the U.S. presidential election as well as what might come out of the next European Commission, they may want to take a break with a good book. Here, Law360 takes a look at tax specialists' summer reading recommendations.

  • August 09, 2024

    Taxation With Representation: Latham, Freshfields, Wachtell

    In this week's Taxation With Representation, Quantum Capital Group agrees to a roughly $3 billion deal for Cogentrix Energy, Apax Partners LLP is acquiring Thoughtworks for roughly $1.75 billion, and Mallinckrodt inks a $925 million deal for Therakos.

  • August 08, 2024

    Cayman Co. Owes Tax On Partners' Income, Tax Court Says

    A Cayman Islands partnership is liable for withholding taxes on the share of about $24.8 million in income from its U.S. operations that was allocated to its foreign partners through special purpose vehicles, the U.S. Tax Court said Thursday.

  • August 08, 2024

    Judge In HMRC Case Won't Step Aside Over 'Scurrilous' Claim

    A London judge has refused to recuse himself from litigation involving HM Revenue & Customs because of apparent bias and institutional corruption owing to his former connection to the department, finding some of the allegations "frankly scurrilous."

  • August 08, 2024

    Nixon Peabody Hires Community Development Counsel In DC

    When Steven Feenstra, the newest member of Nixon Peabody LLP's the community development finance practice, visited a client's office some 25 years ago, the photos of the community housing projects the client had helped develop made a lasting impression on him, he told Law360 Pulse in an interview Thursday.

  • August 08, 2024

    UK, Ecuador Agree To Double-Tax Treaty

    HM Revenue & Customs published a newly agreed-upon treaty to prevent double taxation between the U.K. and Ecuador on Thursday, which would come into force after approval by both countries' legislatures.

  • August 08, 2024

    Italy Doubles Flat Tax On Nondomiciled To €200K

    Individuals who transfer their tax residence to Italy will now pay a €200,000 ($218,000) flat tax in lieu of other taxes on their foreign income instead of €100,000, the Italian government announced.

  • August 08, 2024

    EU Commission Will Visit Nations To Discuss Capital Markets

    European Commission officials plan to visit member countries beginning in the fall to discuss integrating the European Union's capital markets, which could involve tax law changes, the commission said Thursday.

  • August 08, 2024

    UK Gov't Refunds £57M In Pension Freedoms Overtaxation

    The government has been forced to repay £59.6 million ($75.5 million) in the three months between April and June to people who overpaid tax after they tapped into their pensions for the first time, according to HM Revenue and Customs.

  • August 07, 2024

    Weak Link Doomed $690M Whistleblower Claim, DC Circ. Says

    A whistleblower could not get up to $690 million, or 30% of the $2.3 billion collected in an Internal Revenue Service offshore voluntary disclosure program, because the connection between his actions and the program was weak, the D.C. Circuit said Wednesday.

  • August 07, 2024

    EU Seeking Members For Financial Advisory Board

    The European Commission put out a call Wednesday for applications from experts interested in taking over roles on the five-person European Fiscal Board, which advises the commission on certain European Union fiscal operations.

  • August 07, 2024

    Pension Plans' Expert Testimony Limited In $2B Tax Fraud Suit

    A New York federal court decided to exclude portions of an expert's testimony on behalf of pension plans that are accused of seeking to defraud Denmark's tax agency in a $2.1 billion tax refund fraud scheme.

  • August 07, 2024

    UN Economists Want Tax Talks To Address Transparency

    Governments should make tax transparency a top priority for the United Nations framework convention on international tax cooperation and create systems that benefit all countries, the organization's economists said Wednesday.

  • August 07, 2024

    Tax Court's Economic Substance Foray May Clarify Limits

    A U.S. Tax Court judge plans to address an ill-defined provision governing the relevance of the economic substance doctrine in a microcaptive insurance case, offering the courts another chance to clarify an anti-abuse tool the IRS has been deploying more often.

  • August 07, 2024

    Tripling UK's DST Would Cost US Cos. $4.4B, Report Says

    The Liberal Democrats' proposal to raise the U.K.'s digital services tax rate to 6% from 2% would cost U.S. companies up to $4.4 billion a year when accounting for the impact of passing on the costs, a business group said.

  • August 07, 2024

    Singapore's Carbon Tax Is Revenue-Neutral, Minister Says

    Singapore's carbon tax is expected to have a neutral impact on tax revenues over the next decade, even after accounting for a recent hike in the rate to SG$25 ($18.81) per metric ton of emissions, the country's environment minister said.

Expert Analysis

  • After A Brief Hiccup, The 'Rocket Docket' Soars Back To No. 1

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    The Eastern District of Virginia’s precipitous 2022 fall from its storied rocket docket status appears to have been a temporary aberration, as recent statistics reveal that the court is once again back on top as the fastest federal civil trial court in the nation, says Robert Tata at Hunton.

  • Recruitment Trends In Emerging Law Firm Frontiers

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    BigLaw firms are facing local recruitment challenges as they increasingly establish offices in cities outside of the major legal hubs, requiring them to weigh various strategies for attracting talent that present different risks and benefits, says Tom Hanlon at Buchanan Law.

  • How Associates Can Build A Professional Image

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    As hybrid work arrangements become the norm in the legal industry, early-career attorneys must be proactive in building and maintaining a professional presence in both physical and digital settings, ensuring that their image aligns with their long-term career goals, say Lana Manganiello at Equinox Strategy Partners and Estelle Winsett at Estelle Winsett Professional Image Consulting.

  • Firms Must Rethink How They Train New Lawyers In AI Age

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    As law firms begin to use generative artificial intelligence to complete lower-level legal tasks, they’ll need to consider new ways to train summer associates and early-career attorneys, keeping in mind the five stages of skill acquisition, says Liisa Thomas at Sheppard Mullin.

  • Think Like A Lawyer: Always Be Closing

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    When a lawyer presents their case with the right propulsive structure throughout trial, there is little need for further argument after the close of evidence — and in fact, rehashing it all may test jurors’ patience — so attorneys should consider other strategies for closing arguments, says Luke Andrews at Poole Huffman.

  • Litigation Inspiration: Attys Can Be Heroic Like Olympians

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    Although litigation won’t earn anyone an Olympic medal in Paris this summer, it can be worthy of the same lasting honor if attorneys exercise focused restraint — seeking both their clients’ interests and those of the court — instead of merely pursuing every advantage short of sanctionable conduct, says Bennett Rawicki at Hilgers Graben.

  • Lean Into The 'Great Restoration' To Retain Legal Talent

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    As the “great resignation,” in which employees voluntarily left their jobs in droves, has largely dissipated, legal employers should now work toward the idea of a “great restoration,” adopting strategies to effectively hire, onboard and retain top legal talent, says Molly McGrath at Hiring & Empowering Solutions.

  • Fishing Makes Me A Better Lawyer

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    Atop the list of ways fishing makes me a better lawyer is the relief it offers from the chronic stress of a demanding caseload, but it has also improved my listening skills and patience, and has served as an exceptional setting for building earnest relationships, says Steven DeGeorge​​​​​​​ at Robinson Bradshaw.

  • A Healthier Legal Industry Starts With Emotional Intelligence

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    The legal profession has long been plagued by high rates of mental health issues, in part due to attorneys’ early training and broader societal stereotypes — but developing one’s emotional intelligence is one way to foster positive change, collectively and individually, says attorney Esperanza Franco.

  • To Make Your Legal Writing Clear, Emulate A Master Chef

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    To deliver clear and effective written advocacy, lawyers should follow the model of a fine dining chef — seasoning a foundation of pure facts with punchy descriptors, spicing it up with analogies, refining the recipe and trimming the fat — thus catering to a sophisticated audience of decision-makers, says Reuben Guttman at Guttman Buschner.

  • Circuit Judge Writes An Opinion, AI Helps: What Now?

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    Last week's Eleventh Circuit opinion in Snell v. United Specialty Insurance, notable for a concurrence outlining the use of artificial intelligence to evaluate a term's common meaning, is hopefully the first step toward developing a coherent basis for the judiciary's generative AI use, says David Zaslowsky at Baker McKenzie.

  • Trauma-Informed Legal Approaches For Pro Bono Attorneys

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    As National Trauma Awareness Month ends, pro bono attorneys should nevertheless continue to acknowledge the mental and physical effects of trauma, allowing them to better represent clients, and protect themselves from compassion fatigue and burnout, say Katherine Cronin at Stinson and Katharine Manning at Blackbird.

  • How Attys Can Avoid Pitfalls When Withdrawing From A Case

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    The Trump campaign's recent scuffle over its bid to replace its counsel in a pregnancy retaliation suit offers a chance to remind attorneys that many troubles inherent in withdrawing from a case can be mitigated or entirely avoided by communicating with clients openly and frequently, says Christopher Konneker at Orsinger Nelson.

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