International
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December 09, 2024
Microsoft Wrong On Foreign Earnings, Ore. Tells Tax Court
The Oregon Tax Court was correct to reject alternatives pitched by Microsoft for treatment of its repatriated foreign earnings when calculating Oregon taxable income, the state tax department told the court.
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December 09, 2024
UN Tax Pact Should Include Climate Focus, Report Says
Coming negotiations for a global tax convention at the United Nations should include discussions about designing tax policies that could generate resources to help address climate change, according to a report published Monday by the advocacy group Tax Justice Network.
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December 09, 2024
Woman Appeals Tax Court's Canadian Debt Ruling To 9th Circ.
A woman appealed to the Ninth Circuit a U.S. Tax Court decision that prevented her from challenging a federal tax lien issued by the Internal Revenue Service to secure her $200,000 tax debt to Canada on behalf of the Canadian government.
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December 09, 2024
16 EU Members Call For Revamped Tobacco Taxation
The European Commission needs to prioritize an overhaul of the bloc's tobacco taxation rules in the upcoming term, a group of 16 member countries said Monday, arguing that major changes in the industry since the rules last updated have left countries to fend for themselves, fragmenting the tax regime.
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December 09, 2024
Man Owed $264K Under US-Canada Tax Treaty, Court Says
A U.S. man living abroad is allowed under the U.S.-Canada tax treaty to claim a foreign tax credit for nearly $264,000 in payments of the Affordable Care Act's net investment income tax, the Federal Claims Court said.
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December 09, 2024
Latin America Should Improve Tax Collection, OECD Says
Latin American and Caribbean countries' average tax-to-gross-domestic-product ratio falls well below the Organization for Economic Cooperation and Development average, and improvements will be key to the area's ability to meet sustainable development goals, the OECD said Monday.
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December 09, 2024
UAE Implementing Global Minimum Tax In 2025
Large multinational businesses in the United Arab Emirates making at least €750 million ($792 million) annually will be subject to the OECD's 15% corporate global minimum tax starting in 2025, the country's Finance Ministry said Monday.
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December 09, 2024
Proposed Canadian Tax Holiday Will Cost $1B, Office Says
Canada's proposed two-month goods-and-services tax holiday on certain goods would result in the loss of at least CA$1.46 billion ($1 billion) in federal tax revenues, a Canadian budget watchdog said Monday.
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December 09, 2024
Germany Floats Plans To Adopt Additional Min. Tax Guidance
Germany's Federal Ministry of Finance is seeking feedback on additional proposed updates to its legislation under an international minimum tax agreement known as Pillar Two, including incorporating global guidance on how to approach deferred taxes.
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December 09, 2024
Insurer Launches Estate Planning Cover After Tax Changes
Royal London said on Monday that it has launched an insurance product designed to help consumers with their end-of-life planning, as a growing number of estates are set to become subject to inheritance tax after recent government changes.
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December 06, 2024
DC Circ. Affirms Man's $1.2M 'Seriously Delinquent' Tax Debt
A Florida man owes more than $1.2 million in federal taxes, the D.C. Circuit said Friday, affirming the Internal Revenue Service's certification of his liability under a law that allows those with a "seriously delinquent" tax debt to have their passport revoked.
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December 06, 2024
NZ Considering Edits To 'Internationally Unusual' Tax Regime
New Zealand's government received feedback that its rules for taxing investments of 10% or less in foreign companies may be discouraging people who hold interests in such entities from moving to the country, and it is seeking feedback on possible solutions, its tax authority said Friday.
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December 06, 2024
Gov't Appeals Texas Judge's Block On Anti-Laundering Law
The U.S. government has appealed a Texas federal judge's order that halted the rollout of new reporting requirements aimed at unmasking anonymous shell companies, setting the stage for the Fifth Circuit to weigh in on the nationwide preliminary injunction.
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December 06, 2024
Simpson Thacher Adds Tax Pro From Ropes & Gray
Simpson Thacher & Bartlett LLP announced the firm has added a tax professional from Ropes & Gray LLP as a partner in its Washington, D.C., office.
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December 06, 2024
Authorities Investigating Possible €200M German VAT Fraud
The European Public Prosecutor's Office carried out searches at a Munich bank as part of an investigation into a man who created a fictitious business to process more than €200 million ($211 million) in funds generated from a value-added tax fraud scheme, the EPPO said Friday.
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December 06, 2024
Canada's Chinese Import Surtaxes Expected To Raise $334M
Canada's new surtaxes on Chinese electric vehicles and steel and aluminum products are estimated to generate CA$473 million ($334 million) over the next five years, though the EV surtax on its own is likely to cause a dip in revenue, a government analysis said.
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December 06, 2024
Taxation With Representation: Skadden, Gibson Dunn
In this week's Taxation With Representation, BlackRock buys HPS Investment Partners, TreeHouse Foods Inc. buys Harris Tea, Aya Healthcare acquires Cross Country Healthcare, and Bruin Capital launches a soccer representation business.
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December 05, 2024
11th Circ. Won't Rethink $100M Credit For John Hancock
The Eleventh Circuit won't reconsider its decision to let John Hancock Life Insurance Co. keep $100 million in foreign tax credits, leaving in place its October ruling against a Florida law firm retirement plan's trustees.
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December 05, 2024
OECD Suggests Tax Shifts To Address Greece's Debt
Greece has a lot of work to do to reduce its nearly 164% public-debt-to-gross domestic product ratio, and one avenue to generate the kind of budget surplus needed is through a suite of tax changes, the Organization for Economic Cooperation and Development said Thursday.
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December 05, 2024
OECD Removes Application Deadline For Int'l Pricing Program
The Organization for Economic Cooperation and Development said Thursday it has removed biannual deadlines for large multinational entities to apply for the International Compliance Assurance Program, a multilateral effort to resolve transfer pricing issues.
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December 05, 2024
Australia Mulling More Country-By-Country Reporting Advice
While the Australian Taxation Office is already working on guidance for the country's newly adopted public country-by-country reporting rules, it is looking for input on what other areas of the provision businesses may need assistance in interpreting.
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December 05, 2024
Authorities Say €38M Greece VAT Fraud Tied To Larger Ring
Authorities in Greece carried out searches in Athens as part of an investigation into a scheme estimated to have caused €38 million ($40 million) in value-added tax losses, which the European Public Prosecutor's Office said Thursday had connections to a larger €2.2 billion scheme.
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December 05, 2024
Dutch Gov't Will Not Adopt Amount B Pricing Framework
The Dutch government announced that it will not apply a new international tax framework known as Amount B that is designed to streamline the pricing of certain cross-border operations, but it will accept the outcome when other countries apply it.
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December 05, 2024
Australia To Limit Access To Beneficial Ownership Registry
Australia's government intends to limit public access to a registry of beneficial owners for unlisted entities so that only law enforcement, regulators, journalists and academics can request files initially based on its solicitor's privacy recommendations, the Treasury said Wednesday.
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December 05, 2024
Watchdog Urges Ireland To Stash More Of €84B Tax Surplus
The Irish government should put aside more than the €31 billion ($32.7 billion) it has planned to reserve of the €84 billion tax surplus it expects to have between 2026 and 2030, a budget watchdog said Thursday, citing concerns about U.S. policy changes.
Expert Analysis
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Don't Use The Same Template For Every Client Alert
As the old marketing adage goes, consistency is key, but law firm style guides need consistency that contemplates variety when it comes to client alert formats, allowing attorneys to tailor alerts to best fit the audience and subject matter, says Jessica Kaplan at Legally Penned.
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Think Like A Lawyer: Follow The Iron Rule Of Trial Logic
Many diligent and eager attorneys include every good fact, point and rule in their trial narratives — spurred by the gnawing fear they’ll be second-guessed for leaving something out — but this approach ignores a fundamental principle of successful trial lawyering, says Luke Andrews at Poole Huffman.
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The Art Of Asking: Leveraging Your Contacts For Referrals
Though attorneys may hesitate to ask for referral recommendations to generate new business, research shows that people want to help others they know, like and trust, so consider who in your network you should approach and how to make the ask, says Rebecca Hnatowski at Edwards Advisory.
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Unpacking The Bill To Extend TCJA's Biz-Friendly Tax Breaks
Attorneys at Skadden examine how a bipartisan bill currently being considered by the U.S. Senate to save the Tax Cuts and Jobs Act's tax breaks for research and development costs, and other expiring business-friendly provisions, would affect taxpayers.
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Deciding What Comes At The End Of WTO's Digital Tariff Ban
Companies that feel empowered by the World Trade Organization’s recent two-year extension of the ban on e-commerce tariffs should pay attention to current negotiations over what comes after the moratorium expires, as these agreements will define standards in international e-commerce for years to come, say Jan Walter, Hannes Sigurgeirsson and Kulsum Gulamhusein at Akin Gump.
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4 Ways To Refresh Your Law Firm's Marketing Strategy
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.
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This Earth Day, Consider How Your Firm Can Go Greener
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.
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Cum-Ex Prosecutions Storm Shows No Sign Of Abating
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.
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Practicing Law With Parkinson's Disease
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.
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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.
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For Lawyers, Pessimism Should Be A Job Skill, Not A Life Skill
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.
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Requiring Leave To File Amicus Briefs Is A Bad Idea
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.
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4 Ways To Motivate Junior Attorneys To Bring Their Best
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.