International
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June 07, 2024
Chile Says Filing Restriction Program Stopped $203M In Fraud
Chile's tax agency said Friday that its strategy for blocking value-added tax fraud via fraudulent invoices prevented the disbursement of 186 billion Chilean pesos ($203 million) of incorrect value-added tax credits since the start of 2023 through April 2024.
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June 07, 2024
Taxation With Representation: Vinson, Latham, Ropes & Gray
In this Week's Taxation with Representation, Waste Management buys Stericycle, Becton Dickinson pays $4.2 billion for Edwards Lifesciences' critical care products unit, Aquiline Capital Partners raises over $3.4 billion in fund capital, and Bain Capital buys PowerSchool Holdings.
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June 07, 2024
Swiss Launch Consultation On Data Exchange Law
The Swiss government said Friday that it has begun a consultation on a law concerning the international exchange of salary data, which it says is needed to support laws pertaining to the taxation of cross-border workers.
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June 07, 2024
Tax Discriminates Against Risky Assets, Dutch Court Says
The Netherlands must compensate investors for a tax on investment income that discriminates against riskier assets by using calculations of fictitious returns, the Dutch Supreme Court said.
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June 06, 2024
Medtronic Urges 8th Circ. To Back Its Transfer Pricing Method
Medical device maker Medtronic reiterated Thursday its bid for the Eighth Circuit to revive its method for pricing intangible property that was licensed to a Puerto Rican affiliate, arguing the government's concessions show why the company's approach is more reliable.
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June 06, 2024
Oil Cos. Stifle Bids For Tax Transparency, SEC Letters Show
At least three oil companies have stifled proposals initiated by the nonprofit Oxfam America for public country-by-country reporting of business activities, profits and taxes this year, according to letters from the U.S. Securities and Exchange Commission obtained by Law360.
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June 06, 2024
Australia Seeking Feedback On Tax Returns For Biggest Cos.
The Australian Taxation Office said it is reaching out to advisory firms and other groups about plans to introduce a supplementary goods-and-services tax form for the country's biggest companies.
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June 06, 2024
Fox Rothschild Brings On Tax Pro From Atlanta Boutique
Fox Rothschild LLP has added an attorney in Atlanta from tax law boutique Wiggam Law to strengthen the firm's taxation and wealth planning department.
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June 06, 2024
EU Must Improve Country-By-Country Reporting, Group Says
While there has been an uptick in voluntary country-by-country public disclosures, the large multinational corporations that do so make up just 2% of all large companies and account for less than 5% of global revenue and profits, necessitating further improvements, an EU-funded research group said Thursday.
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June 06, 2024
Co. Did Not Abuse UK-Ireland Tax Agreement, Tribunal Affirms
The fact that an Ireland-based company benefited from the U.K.-Ireland double-taxation agreement when it acquired an £83.5 million ($106.8 million) investment doesn't mean it entered the transaction only for tax benefits, the U.K.'s Upper Tribunal said, affirming a lower court.
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June 06, 2024
Pharma Co. Should Get Hungarian Rebate, ECJ Adviser Says
Danish pharmaceutical company Novo Nordisk's mandatory payments into the Hungarian health system should reduce the company's tax base for value-added tax payments, an adviser to the European Union's highest court said Thursday.
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June 06, 2024
Switzerland, Italy Agree To Permanent Rules For Remote Work
Switzerland and Italy have established permanent rules regarding the taxation of cross-border workers, replacing a temporary arrangement that was agreed to last year, the Swiss government said Thursday.
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June 05, 2024
Nigeria Holding US Binance Exec Hostage, Lawmakers Say
The White House's hostage negotiator should begin seeking the release of a top executive at cryptocurrency exchange Binance whom the Nigerian government is holding personally liable for tax evasion charges against the company, the House Foreign Affairs Committee's chairman has said.
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June 05, 2024
German Draft Bill Would Adjust Tax Laws To EU Rules
Changes could be coming to a number of German tax laws, including some spurred by European Union law and both national and international case law, Germany's Finance Ministry said Wednesday.
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June 05, 2024
Win May Embolden IRS Use Of Economic Substance Doctrine
The IRS' successful wielding of the economic substance doctrine to characterize multinational telecommunications corporation Liberty Global's sophisticated set of intercompany deals as an abusive tax shelter could encourage the agency to apply similar analysis to even the most basic tax transactions.
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June 05, 2024
Streamers To Be Hit With 5% Charge On Canadian Revenue
Streaming services such as Netflix and Disney+ soon will be required to contribute 5% of their Canadian revenues to the country's broadcasting system, which could generate CA$200 million ($146 million) a year, Canada's government said, drawing the ire of the National Foreign Trade Council.
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June 05, 2024
Gov't UK ISA Savings Proposal Gets Cold Shoulder
More financial firms on Wednesday warned that the U.K. government's plans to give consumers a new tax break for investing in U.K. companies was unworkable, adding it could conflict with the Financial Conduct Authority's consumer protection rules.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
Expert Analysis
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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.
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The Pop Culture Docket: Judge Espinosa On 'Lincoln Lawyer'
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.
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How And Why Your Firm Should Implement Fixed-Fee Billing
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.