International

  • August 02, 2024

    Coca-Cola Poised To Appeal $2.7B Tax Bill With 11th Circ.

    The U.S. Tax Court signed off Friday on Coca-Cola's $2.7 billion tax bill, setting the stage for the beverage giant to appeal the liabilities and related rulings in its long-running dispute over the IRS' reallocation of the company's foreign income.

  • August 02, 2024

    IRS Tells Tax Court AbbVie's $1.6B Break Fee Is A Capital Loss

    The Internal Revenue Service correctly reclassified AbbVie's $1.6 billion break fee to an Irish biotechnology company as a capital loss, the agency told the U.S. Tax Court, arguing that the failed merger is tantamount to disposing of property.

  • August 02, 2024

    Taxation With Representation: Sullivan, Dechert, Kirkland

    In this week's Taxation With Representation, BNP Parabis SA acquires an investment management subsidiary for €5.1 billion, Cleveland accounting firm CBIZ merges with competitor Marcum for $2.3 billion, and Arcosa Inc. inks a deal with a family-owned construction materials business for $1.2 billion.

  • August 02, 2024

    Liberty Global's $110M Tax Refund Kosher, 10th Circ. Told

    The IRS is trying to block Liberty Global's bid for a $110 million tax refund by improperly using a legal doctrine requiring transactions to have economic substance, the telecommunications giant told the Tenth Circuit, arguing it was allowed to make tax-driven choices in the transactions at issue.

  • August 02, 2024

    Top UK Court To Hear HMRC Car Park Tax Dispute With NHS

    HM Revenue and Customs has been granted permission by Britain's highest court to challenge a ruling that a National Health Service trust qualified for value-added tax exemption for hospital car parking, a decision that could affect appeals brought by NHS entities.

  • August 01, 2024

    Divided Tax Court Says Treaty Bars Collections Hearing

    A divided U.S. Tax Court ruled Thursday that it lacked authority to review an Internal Revenue Service decision preventing a woman from challenging a federal tax lien the agency issued on behalf of the Canadian government to secure her tax debt to that country.

  • August 01, 2024

    Coca-Cola, IRS Enter $2.7B Tax Bill In Transfer Pricing Dispute

    Coca-Cola and the IRS submitted tax liability calculations totaling $2.73 billion to the U.S. Tax Court, reflecting the latest step in the company's long-running transfer pricing dispute over the agency's reallocation of the company's foreign affiliate income.

  • August 01, 2024

    EU Seeking Input On Electronic Country-By-Country Reporting

    The European Commission is looking for feedback on draft regulations creating a common template and electronic format for country-by-country reporting forms that large multinational corporations operating in the European Union will be required to use to disclose their corporate taxes, the EU's executive arm said Thursday.

  • August 01, 2024

    Airbnb's $1.3B Bill From IRS Overvalues IP, Tax Court Told

    Airbnb is challenging a $1.3 billion tax bill tied to income the IRS allocated from overseas, telling the U.S. Tax Court the agency overvalued intellectual property the home-rental giant licensed to its Irish affiliate before going public.

  • August 01, 2024

    Australia Seeking Feedback On Nonresident Trust Guidance

    The Australian Taxation Office is soliciting input on draft guidelines for compliance with the country's income tax obligations in cases where property of a nonresident trust is paid to or applied for the benefit of a resident beneficiary.

  • August 01, 2024

    3rd Circ. Affirms Nix Of Discovery Ask On GM In Brazil Case

    A Delaware federal court didn't abuse its discretion by declining to begin discovery on General Motors to aid ongoing litigation in Brazil for a group that is entitled to receive dozens of car dealerships' tax credits from the early 1990s, the Third Circuit found.

  • August 01, 2024

    15 Arrested In Albanian Ring Involving Money Laundering

    A "prominent money launderer" was among 15 members of what was called a high-profile Albanian organized crime group arrested by authorities under suspicion of crimes including contract killings and money laundering using cryptocurrency transactions, Europol said Thursday.

  • August 01, 2024

    Australia Slows Tax Pro Conduct Code Update After Blowback

    The Australian government is delaying the start of its newly passed changes to the country's code of conduct for tax agent services, which were supposed to enter into force this month, following pushback from industry groups, a minister said Thursday.

  • August 01, 2024

    Taxpayers Find Belgian Pillar 2 Request Sudden, Intrusive

    Belgian demands for detailed information that must be supplied within a short deadline are troubling taxpayers within the scope of the global minimum corporate tax, who said the country's quest for information is more challenging than that imposed by other governments.

  • August 01, 2024

    UK Capital Gains Tax Liabilities Decline, HMRC Says

    Capital gains tax liability in the U.K. declined in the 2022-2023 tax year, HM Revenue & Customs said in a news release Thursday.

  • July 31, 2024

    Treasury's New 'Killer B' Rules May Revive Controversies

    Recent U.S. Treasury Department regulations centered on contentious 2011 guidance aimed at so-called Killer B transactions have revived long-standing questions about how much authority rule writers have to target what they perceive as corporate tax avoidance in these maneuvers.

  • July 31, 2024

    'Tax Avoidance' Fuels Global Reporting Pushback, Pro Says

    A lobbying effort from multinational corporations to dissuade states from adopting mandatory worldwide combined reporting aims to keep billions of dollars in profits that were shifted into tax-friendly jurisdictions beyond the reach of tax administrators, a retired researcher from a progressive think tank said Wednesday.

  • July 31, 2024

    Cos. Insist Chevron Ruling Doesn't Change Deduction Claims

    A medical device company and a food services firm that are each challenging Internal Revenue Service denials of dividend deduction claims told the U.S. Tax Court that the recent U.S. Supreme Court decision overturning Chevron deference doesn't change the validity of their arguments.

  • July 31, 2024

    SEC Asked For Public Tax Reporting By Group With $2.3T

    The U.S. Securities and Exchange Commission was asked Wednesday to begin a rulemaking procedure to require public country-by-country reporting of tax by nearly 90 investment funds, labor unions, activists and others with combined assets over $2.3 trillion.

  • July 31, 2024

    Americans Overseas Launch Residence Taxation Lobby Group

    An advocacy group representing U.S. citizens living abroad announced it has officially registered as a lobbyist to continue to push Congress to pass residence-based taxation laws for the benefit of individuals comparable to those for corporations.

  • July 31, 2024

    Senators Ask Treasury To Limit Biofuel Tax Credit Eligibility

    The U.S. Treasury Department shouldn't grant biofuel production tax credits to companies that use foreign-sourced feedstocks, a coalition of Republican and Democratic senators said in a letter published Wednesday.

  • July 31, 2024

    DMH Stallard Adds Tax Atty To London Practice

    DMH Stallard LLP hired a tax attorney for its London office who spent more than a decade at HM Revenue & Customs working on compliance and policy, according to a news release.

  • July 31, 2024

    Large UK Cos. Expect Major Pillar 2 Administrative Burden

    While businesses largely reported they expect the U.K.'s implementation of the OECD's corporate global minimum tax to have little to no impact on the amount of tax they pay, they also are concerned about the law's administrative burden, HM Revenue & Customs said.

  • July 31, 2024

    Australia Seeking Members For Pillar 2 Working Group

    The Australian Taxation Office said it is seeking members to join a working group focused on the country's implementation of the Organization for Economic Cooperation and Development's Pillar Two global minimum tax.

  • July 31, 2024

    EU Seeks Feedback On Effectiveness Of Anti-Avoidance Law

    The European Commission said Wednesday that it is looking for feedback on how the European Union's anti-tax avoidance directive has fared since going into force in 2020, in particular concerning the bloc-wide implementation of the OECD's global minimum corporate tax standards.

Expert Analysis

  • What Recent Study Shows About AI's Promise For Legal Tasks

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    Amid both skepticism and excitement about the promise of generative artificial intelligence in legal contexts, the first randomized controlled trial studying its impact on basic lawyering tasks shows mixed but promising results, and underscores the need for attorneys to proactively engage with AI, says Daniel Schwarcz at University of Minnesota Law School.

  • How FinCEN Proposal Expands RE Transaction Obligations

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    Against a regulatory backdrop foreshadowing anti-money laundering efforts in the real estate sector, the Financial Crimes Enforcement Network's proposed rule significantly expands reporting requirements for certain nonfinanced residential real estate transfers and necessitates careful review, say attorneys at Fried Frank.

  • Litigation Inspiration: A Source Of Untapped Fulfillment

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    As increasing numbers of attorneys struggle with stress and mental health issues, business litigators can find protection against burnout by remembering their important role in society — because fulfillment in one’s work isn’t just reserved for public interest lawyers, say Bennett Rawicki and Peter Bigelow at Hilgers Graben.

  • Unpacking FinCEN's Proposed Real Estate Transaction Rule

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    Phil Jelsma and Ulrick Matsunaga at Crosbie Gliner take a close look at the Financial Crimes Enforcement Network's recently proposed rulemaking — which mandates new disclosures for professionals involved in all-cash real estate deals — and discuss best next steps for the broad range of businesses that could be affected.

  • Think Like A Lawyer: Forget Everything You Know About IRAC

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    The mode of legal reasoning most students learn in law school, often called “Issue, Rule, Application, Conclusion,” or IRAC, erroneously frames analysis as a separate, discrete step, resulting in disorganized briefs and untold obfuscation — but the fix is pretty simple, says Luke Andrews at Poole Huffman.

  • How New EU Tax And Transfer Pricing Rules May Affect M&A

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    Companies involved in mergers and acquisitions may need to adjust fiscal due diligence procedures to ensure they consider potential far-reaching effects of newly implemented transfer pricing measures, such as newly implemented global minimum tax and European Union anti-tax avoidance directives and proposals, says Patrick Tijhuis at BDO.

  • How Firms Can Ensure Associate Gender Parity Lasts

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    Among associates, women now outnumber men for the first time, but progress toward gender equality at the top of the legal profession remains glacially slow, and firms must implement time-tested solutions to ensure associates’ gender parity lasts throughout their careers, say Kelly Culhane and Nicole Joseph at Culhane Meadows.

  • 7 Common Myths About Lateral Partner Moves

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    As lateral recruiting remains a key factor for law firm growth, partners considering a lateral move should be aware of a few commonly held myths — some of which contain a kernel of truth, and some of which are flat out wrong, says Dave Maurer at Major Lindsey.

  • 6 Pointers For Attys To Build Trust, Credibility On Social Media

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    In an era of information overload, attorneys can use social media strategically — from making infographics to leveraging targeted advertising — to cut through the noise and establish a reputation among current and potential clients, says Marly Broudie at SocialEyes Communications.

  • US-Chile Tax Treaty May Encourage Cross-Border Investment

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    Provisions in the recently effective U.S.-Chile bilateral income tax treaty should encourage business between the two countries, as they reduce U.S. withholding tax on investment income for Chilean taxpayers, exempt certain U.S. taxpayers from Chilean capital gains tax, and clarify U.S. foreign tax credit rules, say attorneys at Kramer Levin.

  • A Post-Mortem Analysis Of Stroock's Demise

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    After the dissolution of 147-year-old firm Stroock late last year shook up the legal world, a post-mortem analysis of the data reveals a long list of warning signs preceding the firm’s collapse — and provides some insight into how other firms might avoid the same disastrous fate, says Craig Savitzky at Leopard Solutions.

  • SG's Office Is Case Study To Help Close Legal Gender Gap

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    As women continue to be underrepresented in the upper echelons of the legal profession, law firms could learn from the example set by the Office of the Solicitor General, where culture and workplace policies have helped foster greater gender equality, say attorneys at Ocean Tomo.

  • Reimagining Law Firm Culture To Break The Cycle Of Burnout

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    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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