International
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January 21, 2025
EU Officials Still Committed To Global Tax Deal Without US
The European Union remains committed to the global tax deal signed by over 130 countries in 2021 even after President Donald Trump announced the U.S. would no longer participate in the agreement, according to EU officials speaking in Brussels on Tuesday.
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January 21, 2025
Justices Decline To Review NY Tax On IBM, Disney Royalties
The U.S. Supreme Court declined Tuesday to hear claims from Disney and IBM that New York's former method of taxing royalty payments from foreign affiliates resulted in unconstitutional discrimination against interstate commerce.
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January 21, 2025
HMRC Wins Appeal In £197M BlueCrest Tax Battle
A London appeals court has sent a challenge by British-American hedge fund BlueCrest to a demand from HM Revenue and Customs for approximately £197 million ($242 million) in tax back to a lower tribunal for fresh consideration.
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January 17, 2025
Law360 Names Practice Groups Of The Year
Law360 would like to congratulate the winners of its Practice Groups of the Year awards for 2024, which honor the attorney teams behind litigation wins and significant transaction work that resonated throughout the legal industry this past year.
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January 17, 2025
Law360 Names Firms Of The Year
Eight law firms have earned spots as Law360's Firms of the Year, with 54 Practice Group of the Year awards among them, steering some of the largest deals of 2024 and securing high-profile litigation wins, including at the U.S. Supreme Court.
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January 20, 2025
Gov't Gets Mixed Reception On Inheritance Tax Pension Plans
Proposals by the U.K. government to bring pension assets within the scope of inheritance tax will result in "numerous problems" and raise concerns in their current form, a trade body and consultants warned on Monday.
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January 17, 2025
UK Parliament Calls New Treasury Unit 'Poorly Defined'
A new HM Treasury office set up to scrutinize fiscal policy lacks staff and its purpose is poorly defined, which means it could duplicate the work of other organizations, the U.K. Parliament's Treasury Select Committee said in a report Sunday.
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January 17, 2025
US Guidance On Amount B Carries Potential For Disputes
Recent IRS guidance on a simplified and streamlined transfer pricing method for certain cross-border transactions, known as Amount B, suggests rulemakers want feedback on how it would work if it were made mandatory, but that approach could lead to controversy without global cooperation.
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January 17, 2025
Case Dismissed Against Man Accused Of Concealing Location
A former healthcare executive whose employer had accused him of avoiding CA$1.2 million ($828,000) in Canadian taxes by lying about his location no longer faces legal action, as the parties agreed to dismiss the action.
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January 17, 2025
Hawaii House Bill Seeks Worldwide Combined Reporting
Hawaii would impose a mandatory worldwide combined reporting system for corporations effective next year under a bill filed in the state House of Representatives.
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January 17, 2025
Taxation With Representation: Simpson Thacher, Covington
In this week's Taxation With Representation, Eli Lilly and Co. buys a precision breast cancer program, Applied Digital Corp. enters a financing agreement for its high-performance computing business, Clearwater Analytics buys Enfusion, and Lantheus Holdings Inc. buys Life Molecular Imaging Ltd.
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January 17, 2025
UAE, Russia Reach Agreement On Double-Tax Treaty
Representatives of the United Arab Emirates and Russia signed a draft treaty to prevent double taxation on income and capital, the UAE's state news agency said Friday, despite ongoing international tensions over Russia's war with Ukraine.
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January 17, 2025
Scottish Power Loses £28M Redress Case Against HMRC
Scottish Power lost its appeal against HM Revenue and Customs on Friday, as a tribunal ruled that the energy company was wrong to argue that just over £28 million ($34 million) in redress payments it made after being investigated for regulatory failures was tax-deductible.
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January 16, 2025
Canadian Conservatives Pledge To Kill Capital Gains Hike
The Conservative Party of Canada promised Thursday to ax a capital gains tax increase secured by the administration of outgoing Prime Minister Justin Trudeau, according to a news release shared on social media Thursday by the party's leader and its candidate for Trudeau's position, Pierre Poilievre.
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January 16, 2025
OECD's Global Minimum Tax Takes Effect In Indonesia
Indonesia began implementing the OECD's global minimum tax on multinational entities making over €750 million ($773 million) annually at the start of this year, the country's Ministry of Finance said Thursday.
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January 16, 2025
OECD To Release List Of Abusive Transactions Under Pillar 2
The Organization for Economic Cooperation and Development is putting together a list of intercompany transactions that may raise red flags as attempts to undermine an international minimum tax agreement known as Pillar Two, an OECD official said Thursday.
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January 16, 2025
Madeira Loses EU State Aid Case Over Tax Breaks
Portugal will have to recover money from companies granted reduced tax rates by its autonomous territory Madeira because the taxpayers failed to meet the terms of two European Commission decisions allowing state aid, the European Court of Justice ruled Thursday.
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January 16, 2025
Morrison Foerster Adds Tax Group Co-Chair From Jones Day
Morrison Foerster LLP announced it has added a partner from Jones Day to serve as co-chair of the firm's global tax group in its New York office.
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January 16, 2025
HMRC Cuts Response Time To Tax Info Exchange Requests
HM Revenue & Customs dropped its average response time to international information exchange requests to 127 days from 175 days, well below the international average of 180 days, the U.K. revenue agency said.
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January 16, 2025
IRS Corrects Simplified Foreign Currency Rules
The Internal Revenue Service issued corrections Thursday to finalized regulations that aim to simplify aspects of how corporations determine taxable income or loss with respect to certain affiliates that conduct business in a foreign currency.
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January 16, 2025
Treasury Updates Bonus Energy Tax Credit Safe Harbors
The U.S. Treasury Department provided updates Thursday to safe harbors that clean energy project developers can use to qualify for bonus tax credits for domestically sourcing steel and aluminum parts in response to new trade restrictions on solar products from China by President Joe Biden's administration.
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January 15, 2025
Dems, GOP Willing To Work On Certain Tax Issues, Aides Say
Democrats are willing to work with Republicans on bipartisan issues, such as providing certain treaty-like benefits to Taiwanese residents, retirement issues, and tax administration issues, Democratic and GOP aides for the House Ways and Means and Senate Finance committees said Wednesday.
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January 15, 2025
Former IRS Litigator Joins Jones Day In Boston
Jones Day announced it added an experienced IRS litigator to its Boston office who will work as of counsel in the firm's tax practice.
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January 15, 2025
Legislators Say Transparency Act Defies First Amendment
The Corporate Transparency Act is an unnecessary intrusion into the First Amendment rights of Americans, U.S. Sen. Thom Tillis, R-N.C., and 13 House members told the Supreme Court in seeking to maintain an injunction issued in December.
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January 15, 2025
House Clears US-Taiwan Double Tax Relief Bill
The U.S. House of Representatives overwhelmingly approved legislation Wednesday that would provide Taiwanese businesses in the United States with tax-treaty-like benefits and authorize the White House to negotiate a tax agreement with Taiwan.
Expert Analysis
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Reimagining Law Firm Culture To Break The Cycle Of Burnout
While attorney burnout remains a perennial issue in the legal profession, shifting post-pandemic expectations mean that law firms must adapt their office cultures to retain talent, say Kevin Henderson and Eric Pacifici at SMB Law Group.
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Cayman Islands Off AML Risk Lists, Signaling Robust Controls
As a world-leading jurisdiction for securitization special purpose entities, the removal of the Cayman Islands from increased anti-money laundering monitoring lists is a significant milestone that will benefit new and existing financial services customers conducting business in the territory, say lawyers at Walkers Global.
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The Legal Industry Needs A Cybersecurity Paradigm Shift
As law firms face ever-increasing risks of cyberattacks and ransomware incidents, the legal industry must implement robust cybersecurity measures and privacy-centric practices to preserve attorney-client privilege, safeguard client trust and uphold the profession’s integrity, says Ryan Paterson at Unplugged.
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As Promised, IRS Is Coming For Crypto Tax Evaders
The IRS is fulfilling its promise to crack down on those who have neglected to pay taxes on cryptocurrency earnings, as demonstrated by recently imposed prison sentences, enforcement initiatives and meetings with international counterparts — suggesting a few key takeaways for taxpayer compliance, say attorneys at BakerHostetler.
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5 Reasons Associates Shouldn't Take A Job Just For Money
As a number of BigLaw firms increase salary scales for early-career attorneys, law students and lateral associates considering new job offers should weigh several key factors that may matter more than financial compensation, say Albert Tawil at Lateral Hub and Ruvin Levavi at Power Forward.
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The Pop Culture Docket: Judge Djerassi On Super Bowl 52
Philadelphia Court of Common Pleas Judge Ramy Djerassi discusses how Super Bowl 52, in which the Philadelphia Eagles prevailed over the New England Patriots, provides an apt metaphor for alternative dispute resolution processes in commercial business cases.
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Employee Experience Strategy Can Boost Law Firm Success
Amid continuing business uncertainty, law firms should consider adopting a holistic employee experience strategy — prioritizing consistency, targeting signature moments and leveraging measurement tools — to maximize productivity and profitability, says Haley Revel at Calibrate Consulting.
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6 Practice Pointers For Pro Bono Immigration Practice
An attorney taking on their first pro bono immigration matter may find the law and procedures beguiling, but understanding key deadlines, the significance of individual immigration judges' rules and specialized aspects of the practice can help avoid common missteps, says Steven Malm at Haynes Boone.
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Lessons From Country Singer's Personal Service Saga
Recent reports that country singer Luke Combs won a judgment against a Florida woman who didn’t receive notice of the counterfeit suit against her should serve as a reminder for attorneys on best practices for effectuating service by electronic means, say attorneys at Jenner & Block.
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7 E-Discovery Predictions For 2024 And Beyond
The legal and technical issues of e-discovery now affect virtually every lawsuit, and in the year to come, practitioners can expect practices and policies to evolve in a number of ways, from the expanded use of relevancy redactions to mandated information security provisions in protective orders, say attorneys at Littler.
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5 Litigation Funding Trends To Note In 2024
Over the next year and beyond, litigation funding will continue to evolve in ways that affect attorneys and the larger litigation landscape, from the growth of a secondary market for funded claims, to rising interest rates restricting the availability of capital, says Jeffery Lula at GLS Capital.
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4 Legal Ethics Considerations For The New Year
As attorneys and clients reset for a new year, now is a good time to take a step back and review some core ethical issues that attorneys should keep front of mind in 2024, including approaching generative artificial intelligence with caution and care, and avoiding pitfalls in outside counsel guidelines, say attorneys at HWG.
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What The Law Firm Of The Future Will Look Like
As the legal landscape shifts, it’s become increasingly clear that the BigLaw business model must adapt in four key ways to remain viable, from fostering workplace flexibility to embracing technology, say Kevin Henderson and Eric Pacifici at SMB Law Group.