International
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October 15, 2024
Starmer Hints At National Insurance Hike Over Capital Gains
British Prime Minister Keir Starmer on Tuesday again refused to rule out raising employers' National Insurance, a payroll levy used to fund social programs, after downplaying claims that his government is planning to raise the capital gains tax.
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October 15, 2024
Law Firms Diverge As Anti-ESG Pushback Continues
A continuing onslaught of legislation and litigation opposing corporate environmental, social and governance actions has created a fork in the road for law firms, with some choosing to scale back efforts and others pushing ahead with their internal ESG and diversity, equity and inclusion goals.
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October 15, 2024
The 2024 Law360 Pulse Social Impact Leaders
Check out our Social Impact Leaders ranking, analysis and interactive graphics to see which firms stand out for their engagement with social responsibility and commitment to pro bono service.
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October 11, 2024
Danish Tax Agency Sniffs Out $367M In VAT Fraud
The Danish Tax Agency said it has issued collections for roughly 2.5 billion Danish kroner ($367 million) since 2018 against companies it discovered were carrying out cross-border value-added tax fraud schemes known as VAT carousels.
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October 11, 2024
France Targets Largest Cos. With Tax In Austerity Budget
The French government said it plans to implement a temporary tax targeting the country's biggest companies as part of a budget of €61.3 billion ($67 billion) of fiscal changes intended to help bring the deficit in line with European Union rules.
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October 11, 2024
Italian Police Freeze €12.3M In Textile VAT Fraud Investigation
The Italian Financial Police carried out two freezing orders totaling €12.3 million ($13.5 million) against suspects in an ongoing investigation into a value-added tax fraud involving the illegal importation of textiles from China, the European Public Prosecutor's Office said.
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October 11, 2024
Bird & Bird Adds DLA Piper Legal Director To London Office
Bird & Bird LLP has added a former DLA Piper legal director as a partner to its London tax team.
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October 11, 2024
Disputes May Loom Over Dividend Deductions For CFCs
U.S. multinational corporations are concerned that rulemakers' interpretation of a law allowing tax-free repatriation of certain overseas earnings could lead to controversy after the Internal Revenue Service published a memo indicating the break is unavailable for controlled foreign corporations.
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October 11, 2024
Fla. Businessman's Estate Faces $2.6M In FBAR Penalties
A Florida businessman's estate owes the federal government $2.6 million in penalties plus interest for his failure to report his Swiss bank account from 2013 to 2017, the government told a federal court.
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October 11, 2024
Taxation With Representation: Davis Polk, Latham, Kirkland
In this week's Taxation With Representation, Rio Tinto agrees to acquire Arcadium Lithium for roughly $6.7 billion, Ares Management Corp. and GCP International reach a $3.7 billion deal, and Butterfly Equity announces plans to buy The Duckhorn Portfolio for $2 billion.
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October 10, 2024
Ukraine's Parliament Hikes Taxes To Fund War With Russia
Ukraine's Parliament announced that it approved several amendments to the country's tax code Thursday that will raise revenues for its war with Russia.
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October 10, 2024
Pillar 2 Carveout Should Cover Some Mobile Items, NFTC Says
The exemption for tangible investments from the global minimum tax known as Pillar Two should include certain mobile assets, such as ships and aircraft, the National Foreign Trade Council recommended.
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October 10, 2024
Ryanair To Scale Back German Flights After Tax Hike
Irish discount airline Ryanair announced plans Thursday to follow through on its threat to cut back service to Germany next summer over tax issues, saying it will cut 12% of its total capacity in the country — equal to 1.8 million seats — and close three bases of operation.
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October 10, 2024
Pfizer Lone Holdout In Senate Pharma Tax Probe, Wyden Says
Pfizer Inc. is the only company to withhold a country-by-country breakdown of its tax planning in the Senate Finance Committee's probe into how Republicans' 2017 tax package reduced the pharmaceutical industry's U.S. liabilities, according to a letter Chairman Ron Wyden released Thursday.
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October 10, 2024
UK Exit Taxes OK When Paid Over Time, Upper Tribunal Says
An exit tax on U.K. trusts leaving the country pre-Brexit interfered with their European Union right to free movement of capital, but is brought into compliance if trusts can pay the tax over at least a five-year period, the Upper Tribunal ruled.
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October 10, 2024
Switzerland Reports Info Exchanges With 108 Jurisdictions
Switzerland's Federal Tax Administration has exchanged information on roughly 3.7 million financial accounts with 108 jurisdictions so far in 2024, the government said Thursday.
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October 10, 2024
Ireland's Finance Bill Sets Out Foreign Dividend Exemption
The Irish government set out its plans for a new participation tax exemption for foreign dividends as part of a finance bill published Thursday.
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October 10, 2024
Algeria Joins OECD Tax Transparency Treaty
Algeria formally joined the Organization for Economic Cooperation and Development's global tax transparency agreement on combating tax avoidance and evasion by multinational corporations, the OECD announced Thursday.
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October 09, 2024
Australia Floats Debt Reduction Creation Rules Guidance
The Australian Taxation Office published draft guidance Wednesday for the country's new debt deduction creation rules, including the planned compliance approach and a framework for risk assessment.
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October 09, 2024
European Parliament Backs Brazil's G20 Wealth Tax Plan
A majority of the European Parliament supports a 2% minimum tax on billionaires presented by Brazil at the Group of 20 nations meeting, asking the European Union to pursue the topic at the group's November summit, according to joint statements by members of Parliament on Wednesday.
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October 09, 2024
Swiss Council Rejects Funding Pensions With Transaction Tax
Switzerland should not use the revenue generated by its two taxes on financial market transactions to fund the country's pension fund, nor should it create new ones for that purpose, the Swiss Federal Council said Wednesday.
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October 09, 2024
OECD Should Clarify Pillar 2 Safe Harbor Timing, CPAs Say
The OECD should clarify when exactly multinational corporations need to determine whether they qualify for a transitional safe harbor under an international minimum tax agreement, the American Institute of Certified Public Accountants recommended in a letter.
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October 09, 2024
UK Gov't Greenlights Film Industry Tax Credit
U.K. film companies will be able to gain over 50% tax relief for their films' costs from a tax credit approved Wednesday by the Labour government.
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October 09, 2024
3M Tax Ruling Must Fall Post-Chevron, Chamber Tells 8th Circ.
The U.S. Supreme Court's ending of the Chevron doctrine calls for overturning a U.S. Tax Court ruling that let the IRS allocate $24 million of income to multinational conglomerate 3M from a Brazilian affiliate, the U.S. Chamber of Commerce told the Eighth Circuit on Wednesday.
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October 09, 2024
Starmer Refuses To Rule Out Payroll Tax Hike
Prime Minister Keir Starmer didn't rule out raising employers' National Insurance contributions, a payroll tax used to fund healthcare and state pensions, during Wednesday's question time.
Expert Analysis
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Why Now Is The Time For Law Firms To Hire Lateral Partners
Partner and associate mobility data from the second quarter of this year suggest that there's never been a better time in recent years for law firms to hire lateral candidates, particularly experienced partners — though this necessitates an understanding of potential red flags, say Julie Henson and Greg Hamman at Decipher Investigative Intelligence.
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Considering Possible PR Risks Of Certain Legal Tactics
Disney and American Airlines recently abandoned certain litigation tactics in two lawsuits after fierce public backlash, illustrating why corporate counsel should consider the reputational implications of any legal strategy and partner with their communications teams to preempt public relations concerns, says Chris Gidez at G7 Reputation Advisory.
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It's No Longer Enough For Firms To Be Trusted Advisers
Amid fierce competition for business, the transactional “trusted adviser” paradigm from which most firms operate is no longer sufficient — they should instead aim to become trusted partners with their most valuable clients, says Stuart Maister at Strategic Narrative.
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Navigating A Potpourri Of Possible Transparency Act Pitfalls
Despite the Financial Crimes Enforcement Network's continued release of guidance for complying with the Corporate Transparency Act, its interpretation remains in flux, making it important for companies to understand potentially problematic areas of ambiguity in the practical application of the law, say attorneys at Sidley.
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How Methods Are Evolving In Textualist Interpretations
Textualists at the U.S. Supreme Court are increasingly considering new methods such as corpus linguistics and surveys to evaluate what a statute's text communicates to an ordinary reader, while lower courts even mull large language models like ChatGPT as supplements, says Kevin Tobia at Georgetown Law.
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Why Attorneys Should Consider Community Leadership Roles
Volunteering and nonprofit board service are complementary to, but distinct from, traditional pro bono work, and taking on these community leadership roles can produce dividends for lawyers, their firms and the nonprofit causes they support, says Katie Beacham at Kilpatrick.
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Firms Must Offer A Trifecta Of Services In Post-Chevron World
After the U.S. Supreme Court’s Loper Bright Enterprises v. Raimondo decision overturning Chevron deference, law firms will need to integrate litigation, lobbying and communications functions to keep up with the ramifications of the ruling and provide adequate counsel quickly, says Neil Hare at Dentons.
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5 Tips To Succeed In A Master Of Laws Program And Beyond
As lawyers and recent law school graduates begin their Master of Laws coursework across the country, they should keep a few pointers in mind to get the most out of their programs and kick-start successful careers in their practice areas, says Kelley Miller at Reed Smith.
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How Law Firms Can Avoid 'Collaboration Drag'
Law firm decision making can be stifled by “collaboration drag” — characterized by too many pointless meetings, too much peer feedback and too little dissent — but a few strategies can help stakeholders improve decision-making processes and build consensus, says Steve Groom at Miles Mediation.
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Litigation Funding Disclosure Key To Open, Impartial Process
Blanket investor and funding agreement disclosures should be required in all civil cases where the investor has a financial interest in the outcome in order to address issues ranging from potential conflicts of interest to national security concerns, says Bob Goodlatte, former U.S. House Representative for Virginia.
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What NFL Draft Picks Have In Common With Lateral Law Hires
Nearly half of law firm lateral hires leave within a few years — a failure rate that is strikingly similar to the performance of NFL quarterbacks drafted in the first round — in part because evaluators focus too heavily on quantifiable metrics and not enough on a prospect's character traits, says Howard Rosenberg at Baretz+Brunelle.
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Replacing The Stigma Of Menopause With Law Firm Support
A large proportion of the workforce is forced to pull the brakes on their career aspirations because of the taboo surrounding menopause and a lack of consistent support, but law firms can initiate the cultural shift needed by formulating thoughtful workplace policies, says Barbara Hamilton-Bruce at Simmons & Simmons.
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Planning Law Firm Content Calendars: What, When, Where
During the slower month of August, law firms should begin working on their 2025 content calendars, planning out a content creation and distribution framework that aligns with the firm’s objectives and maintains audience engagement throughout the year, says Jessica Kaplan at Legally Penned.