International

  • June 24, 2024

    Loss Guidance Will Cover Pillar 2, IRS Official Says

    Forthcoming guidance to address U.S. tax issues with dual consolidated losses will also include language advising taxpayers how to account for those losses under the Pillar Two global minimum tax, the IRS' top international tax counsel said Monday.

  • June 24, 2024

    UN Tax Convention Should Be Crafted Carefully, NFTC Says

    The United Nations' work toward a framework convention on international tax cooperation is welcome but should be done carefully and with continued input from stakeholders, the National Foreign Trade Council said, providing specific areas of feedback.

  • June 24, 2024

    German Banker's Cum-Ex Trial Dropped Due To Health

    The former chairman of M.M. Warburg & Co. KGaA will not face trial for alleged dividend-tax evasion linked to cum-ex transactions spanning from 2006 to 2019 after a German court halted the trial due to his health, according to a Monday court statement.

  • June 24, 2024

    Asia Tax Transparency Generated €1.8B In Revenue In 2023

    Tax transparency measures in 13 Asian jurisdictions collected at least €1.8 billion ($1.9 billion) in extra tax revenue in 2023 alone as such mechanisms continue to be adopted in the region, the Organization for Economic Cooperation and Development reported Monday.

  • June 24, 2024

    EU Dodges Hungary To Send Ukraine €1.4B In Russian Profits

    European Union foreign ministers agreed Monday to send €1.4 billion ($1.5 billion) of windfall profits from frozen and immobilized Russian state assets in military support to Ukraine next month, finding a legal loophole to bypass a potential veto from Hungary.

  • June 24, 2024

    OECD Tax Plan Issues Still Being Hashed Out, US Official Says

    Both the global minimum corporate tax and taxing rights overhaul plans designed by the Organization for Economic Cooperation and Development have outstanding issues that stakeholders are attempting to resolve, a U.S. Treasury Department official said at a conference Monday.

  • June 24, 2024

    EU States Turn Down Transfer Pricing Proposal, Report Says

    European Union countries have declined to accept a new law on transfer pricing that the EU's executive proposed last year, a report published by the body representing EU member states showed Monday.

  • June 24, 2024

    French PM Hopeful Sees VAT Stay As Anti-Inflation Tool

    A hopeful to become the next prime minister of France wants to use the suspension of value-added tax to counter the effects of inflation, an outline of policy proposals released Monday showed.

  • June 21, 2024

    UK Tax Fraud Cases Rose 49% Over One-Year Period

    The U.K. tax authority launched more criminal cases for tax fraud for the year ended June 30, 2023, increasing 49% from 63 cases for the previous year to 94, Pinsent Masons LLP said Monday.

  • June 21, 2024

    Supreme Court Leaves Lifeline For Billionaire Income Tax

    The U.S. Supreme Court narrowed but did not entirely block the path to billionaire income tax legislation when the majority's opinion declined to weigh constitutional questions about taxing unrealized gains in its decision to uphold a mandatory repatriation levy.

  • June 21, 2024

    USTR Warns Canada After Digital Services Tax Enactment

    The U.S. Trade Representative's Office remains concerned about Canada's enactment of its digital services tax and is weighing options in defense of potential discrimination against U.S. businesses, a USTR official told Law360 on Friday.

  • June 21, 2024

    Fed. Circ. Backs Subsidy Duties For Canadian Wind Towers

    A Canadian wind tower manufacturer can't get a break on countervailing duties despite being upfront about errors in its sales data, with the Federal Circuit ruling Friday that the errors raise the possibility of additional mistakes.

  • June 21, 2024

    US Formally Suspends Part Of Tax Treaty With Russia

    The U.S. government has provided formal notice to Russia suspending, via mutual agreement, parts of the countries' double-taxation treaty.

  • June 21, 2024

    Big 4 Continue Push For Broader Irish Dividend Exemption

    The Big Four accounting firms reiterated support for Ireland's plans to implement a corporate tax exemption for foreign-sourced dividends and foreign branch profits, but they found the latest proposal still too narrow and complicated to qualify for, according to comments released Friday.

  • June 21, 2024

    Norway Seeking Feedback On Undertaxed Profits Rule

    Norway is looking for feedback on a proposal that would implement the undertaxed profits rule, one component of the Organization for Economic Cooperation and Development's 15% corporate global minimum tax plan, the country's Finance Ministry said.

  • June 21, 2024

    OECD Official Sees Amount B Deal Helping With Amount A

    The Organization for Economic Cooperation and Development is close to a final deal on a key part of its efforts to establish new international taxing rights under Amounts A and B of its Pillar One plans, according to the organization's tax chief.

  • June 21, 2024

    Taxation With Representation: Travers Smith, Potamitis Vekris

    In this week's Taxation With Representation, RSK Group Ltd. gets a £500 million ($632 million) investment, Boston Scientific Corp. acquires Silk Road Medical Inc., Masdar takes a part of Terna Energy SA, and Tate & Lyle PLC buys CP Kelco from JM Huber Corp.

  • June 21, 2024

    EU Digital Tax Is Backup If Pillar 1 Stalls, French Official Says

    Finalizing the Pillar One agreement to reallocate corporate taxing rights globally should remain a paramount goal, but if the effort stalls, the European Union should revive its plan for a digital tax of mostly U.S.-based tech giants, French Finance Minister Bruno Le Maire said Friday.

  • June 21, 2024

    Estonia Again Blocks Agreement On VAT Deal

    For the second straight month, Estonia blocked agreement Friday on a European Union proposal for platform companies such as Airbnb, Uber and Estonia-based Bolt to collect value-added tax on behalf of service providers.

  • June 21, 2024

    Next UK Gov't Urged To Ease Private Healthcare Insurance Tax

    Whoever wins the U.K. election on July 4 should introduce tax breaks on private medical insurance to relieve pressure on the National Health Service, a consultancy warned Friday.

  • June 20, 2024

    German Court Convicts 5 In €52M VAT Fraud In Cars, Masks

    Five people who played roles in a value-added tax fraud scheme involving the trade of luxury cars and medical face masks that caused over €52 million ($55.7 million) in losses were convicted by a Berlin court, the European Public Prosecutor's Office announced Thursday.

  • June 20, 2024

    EU Court Rejects Co.'s Portuguese Tax Breaks Appeal

    An appeal contesting a European Commission decision against a Portuguese tax exemption scheme was rejected by the European General Court, which found a Panama-based food company unable to prove why recovering the illegal state aid should be prohibited.

  • June 20, 2024

    China Denies Tax Crackdown As 2 Cos. Report $80M In Bills

    China's tax authority denied a nationwide crackdown on companies' old tax returns Thursday, less than a week after a chemical firm facing 500 million yuan ($69 million) in additional liabilities halted production and a beverage maker reported owing 85 million yuan.

  • June 20, 2024

    UK Tax Pros Largely Support 2027 Carbon Border Tax Plan

    Two groups representing tax professionals welcomed the U.K. government's plan to introduce a carbon border tax on certain carbon-intensive imports by 2027, but specifics regarding both default embedded emissions values and carveouts for smaller businesses must be ironed out, they said.

  • June 20, 2024

    Norway's $95M Yearly Dividend Tax Losses Spur Joint Audit

    Norway's tax agency announced a joint audit with other Nordic tax agencies, saying it loses an estimated 1 billion kroner ($95 million) a year in withholding taxes that should be paid by foreign shareholders on dividends but aren't due to aggressive tax planning.

Expert Analysis

  • 4 Ways To Refresh Your Law Firm's Marketing Strategy

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    With many BigLaw firms relying on an increasingly obsolete marketing approach that prioritizes stiff professionalism over authentic connection, adopting a few key communications strategies to better connect with today's clients and prospects can make all the difference, say Eric Pacifici and Kevin Henderson at SMB Law.

  • This Earth Day, Consider How Your Firm Can Go Greener

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    As Earth Day approaches, law firms and attorneys should consider adopting more sustainable practices to reduce their carbon footprint — from minimizing single-use plastics to purchasing carbon offsets for air travel — which ultimately can also reduce costs for clients, say M’Lynn Phillips and Lisa Walters at IMS Legal Strategies.

  • Cum-Ex Prosecutions Storm Shows No Sign Of Abating

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    The ongoing trial of Sanjay Shah in Denmark is a clear indicator that efforts remain focused on holding to account the alleged architects and beneficiaries of cum-ex trading, and with these prosecutions making their way across Europe, it is a more turbulent time now than ever, says Niall Hearty at Rahman Ravelli.

  • Practicing Law With Parkinson's Disease

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    This Parkinson’s Awareness Month, Adam Siegler at Greenberg Traurig discusses his experience working as a lawyer with Parkinson’s disease, sharing both lessons on how to cope with a diagnosis and advice for supporting colleagues who live with the disease.

  • Why Supreme Court Should Allow Repatriation Tax To Stand

    If the U.S. Supreme Court doesn't reject the taxpayers' misguided claims in Moore v. U.S. that the mandatory repatriation tax is unconstitutional, it could wreak havoc on our system of taxation and result in a catastrophic loss of revenue for the government, say Christina Mason and Theresa Balducci at Herrick Feinstein.

  • For Lawyers, Pessimism Should Be A Job Skill, Not A Life Skill

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    A pessimistic mindset allows attorneys to be effective advocates for their clients, but it can come with serious costs for their personal well-being, so it’s crucial to exercise strategies that produce flexible optimism and connect lawyers with their core values, says Krista Larson at Stinson.

  • Requiring Leave To File Amicus Briefs Is A Bad Idea

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    A proposal to amend the Federal Rules of Appellate Procedure that would require parties to get court permission before filing federal amicus briefs would eliminate the long-standing practice of consent filing and thereby make the process less open and democratic, says Lawrence Ebner at the Atlantic Legal Foundation and DRI Center.

  • 4 Ways To Motivate Junior Attorneys To Bring Their Best

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    As Gen Z and younger millennial attorneys increasingly express dissatisfaction with their work and head for the exits, the lawyers who manage them must understand and attend to their needs and priorities to boost engagement and increase retention, says Stacey Schwartz at Katten.

  • Former Minn. Chief Justice Instructs On Writing Better Briefs

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    Former Minnesota Supreme Court Chief Justice Lorie Gildea, now at Greenberg Traurig, offers strategies on writing more effective appellate briefs from her time on the bench.

  • Stay Interviews Are Key To Retaining Legal Talent

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    Even as the economy shifts and layoffs continue, law firms still want to retain their top attorneys, and so-called stay interviews — informal conversations with employees to identify potential issues before they lead to turnover — can be a crucial tool for improving retention and morale, say Tina Cohen Nicol and Kate Reder Sheikh at Major Lindsey.

  • Neb. Justices Should Weigh IRC Terms In Dividend Tax Case

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    Nebraska’s highest court, which will hear oral arguments in Precision CastParts v. Department of Revenue on April 1, should recognize that the Internal Revenue Code provides key clues to defining “dividends received or deemed to be received,” and therefore limits Nebraska’s tax on foreign-sourced corporate income, says Joseph Schmidt at Ryan.

  • Judicial Independence Is Imperative This Election Year

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    As the next election nears, the judges involved in the upcoming trials against former President Donald Trump increasingly face political pressures and threats of violence — revealing the urgent need to safeguard judicial independence and uphold the rule of law, says Benes Aldana at the National Judicial College.

  • Spartan Arbitration Tactics Against Well-Funded Opponents

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    Like the ancient Spartans who held off a numerically superior Persian army at the Battle of Thermopylae, trial attorneys and clients faced with arbitration against an opponent with a bigger war chest can take a strategic approach to create a pass to victory, say Kostas Katsiris and Benjamin Argyle at Venable.

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