International
-
July 12, 2024
Chevron's End Doesn't Bear On 3M's Case, IRS Tells 8th Circ.
The U.S. Supreme Court's recent overturning of Chevron deference doesn't warrant a reversal of a U.S. Tax Court ruling in 3M Co.'s transfer pricing case, the Internal Revenue Service told the Eighth Circuit on Friday.
-
July 12, 2024
Parliament Vote On Von Der Leyen's 2nd Term Coming July 18
The European Parliament will vote July 18 whether to approve current European Commission President Ursula von der Leyen for a second five-year term, according to a document published Friday.
-
July 12, 2024
Switzerland, Hungary Adding Anti-Abuse Clause To Tax Treaty
Switzerland and Hungary moved on Friday to add to their double-taxation treaty an anti-abuse clause that prevents a person who is not a resident of either country from claiming the benefits of the treaty.
-
July 12, 2024
Taxation With Representation: Ropes & Gray, Cravath, Latham
In this Week's Taxation with Representation, Paramount Global merges with Skydance Media, Devon Energy acquires Grayson Mill Energy's Williston Basin oil and gas business, Ryan acquires Altus Group Ltd.'s property tax business, and Bain Capital buys Envestnet Inc.
-
July 12, 2024
Alvarez & Marsal Appoints Managing Director Of Tax Group
Alvarez & Marsal Tax LLC appointed an experienced negotiator of tax incentives as managing director to the firm's corporate transformation tax group, the firm announced.
-
July 12, 2024
EU Chair Doesn't Expect Energy Tax Deal This Year
The new chair of European Union finance ministers doesn't expect to reach agreement on a landmark energy taxation law in the next half-year, anticipating only exploratory talks, an official from Hungary's EU presidency said Friday.
-
July 11, 2024
ABA Attys Seek To Avoid Reporting Foreign Trust Loans
The American Bar Association's tax, real estate and trust attorneys are seeking to prevent the U.S. Treasury Department from tightening reporting requirements for the exemption of loans from foreign trusts, which are often used by wealthy families and in succession planning, according to a consultation response.
-
July 11, 2024
Brazilian Tax Agency Probes Refund Fraud Scheme
Brazilian federal tax authorities and police said Thursday they had conducted a search-and-seizure operation related to the investigation of an income tax refund fraud scheme.
-
July 11, 2024
Ex-Leaders Ask Biden For Int'l Coordination On Billionaire Tax
President Joe Biden should get behind Brazil's proposal for the Group of 20 nations to coordinate a minimum tax on billionaires, nearly 20 former presidents and prime ministers from countries such as Canada, France and South Korea said in an open letter.
-
July 11, 2024
IRS Proposes 'Basket Contracts' As Listed Transactions
The Internal Revenue Service proposed rules Thursday that would flag so-called basket option contracts as potentially abusive listed transactions, imposing additional reporting requirements under the threat of penalty for individuals and businesses involved in such arrangements.
-
July 11, 2024
IRS, OECD Officials Detail Expansion Of AI In Tax Work
The Internal Revenue Service and Organization for Economic Cooperation and Development are making great progress in adopting artificial intelligence in tax administration, representatives of both organizations said Thursday.
-
July 11, 2024
Israel Says Resident Hid $5.5M In Offshore Bank Accounts
An Israeli resident was released under restrictive conditions Thursday after the government alleged he failed to report foreign bank accounts that held more than 20 million shekels ($5.5 million), according to a statement from the Israel Tax Authority.
-
July 11, 2024
Tax Haven Biz Revenues Per Worker Still Far Outpace Norm
Companies recorded median revenues per employee of $1.6 million in low-tax jurisdictions like Ireland, the Cayman Islands and Hong Kong and around $300,000 in all other jurisdictions in 2021, a difference that has narrowed since 2017, the OECD said Thursday.
-
July 11, 2024
Biz Officials Call For Simpler Tax Rules In Light Of Pillar 2
Business representatives said Thursday that tax compliance rules need to be simplified as new minimum tax rules, known as Pillar Two, are added to the existing regime.
-
July 11, 2024
Failure Of Pillar 1 Would Yield Worse Alternatives, Panel Says
A failure of the Pillar One agreement to reallocate corporate taxing rights would lead to alternatives that are worse, with the return of national digital services taxes worldwide, tax officials and academics said Thursday.
-
July 10, 2024
Engineer Who Faced Export Charges Cops To Tax Counts
A Chinese-born engineer has pled guilty to two counts of filing a false tax return related to allegations that he and his wife omitted gross income from their tax returns between 2015 and 2019, after Texas federal prosecutors initially charged the couple with export violations and fraud.
-
July 10, 2024
Portugal Enacts Pillar 2 As Part Of Economic, Tax Package
Portugal's Council of Ministers approved the minimum tax provision known as Pillar Two in a package of economic and tax measures designed to boost the country's economic growth, the council announced.
-
July 10, 2024
OECD Publishes Pillar 2 Technical Reporting Language Draft
The Organization for Economic Cooperation and Development published a draft of technical details required to digitally input and disseminate information required for Pillar Two global minimum tax returns Wednesday.
-
July 10, 2024
Americans Overseas Ask for Clarity In Foreign Trust Regs
An advocacy group representing U.S. citizens living abroad urged the U.S. Treasury Department to clarify proposed rules for reporting transactions with foreign trusts, contending that guidance should explain which common pension arrangements are exempt from disclosure obligations.
-
July 10, 2024
Curtis Mallet-Prevost To Open Law Office In Saudi Arabia
Curtis Mallet-Prevost Colt & Mosle LLP has obtained a license to practice law in the Kingdom of Saudi Arabia, the firm announced this week.
-
July 10, 2024
HMRC, CPS Beat Financier's Claim Over Botched Prosecution
HM Revenue and Customs and the Crown Prosecution Service have beaten claims of malicious prosecution and misfeasance in public office by a corporate financier following a failed criminal fraud case, with a judge finding that they had enough evidence to pursue him.
-
July 10, 2024
French Left's Tax Pledges May Go Unfulfilled
The tax policy pledges put forward by the leftist bloc of parties that won the most seats in France's legislative election may not be fulfilled given the bloc's failure to win an outright majority.
-
July 10, 2024
India's High Court Nixes Challenge To Taxing Of Tour Vehicles
The Indian Supreme Court dismissed a group of petitions challenging border taxes imposed by state governments on tour company vehicles because it said the litigation should have begun in a different court.
-
July 10, 2024
Attempts To Scrap EU Tax Veto Are Useless, Hungary Says
Attempts by European Union countries to try to remove the requirement of unanimity for delicate policy decisions such as tax law and adding new EU member states are futile, Hungary's minister for European affairs said Wednesday.
-
July 09, 2024
House Panel OKs Tax Breaks For More Education Expenses
The House Ways and Means Committee sent several education-related tax bills to the full House of Representatives on Tuesday, including legislation that would make additional elementary and secondary school expenses eligible for tax-advantaged education savings accounts.
European Tax Policy To Watch In The Second Half Of 2024
Observers of European Union tax policy expect the EU to devote more attention to problems with existing tax legislation in the coming months as the introduction of major policy proposals takes a pause. Specialists also will be watching for progress on EU tax laws that remain stuck, and the bloc is likely to fill roles including tax commissioner. Here, Law360 examines key tax issues to watch for the remaining six months of the year.
Worried Companies Ask For Pillar 2 Simplification
Multinational corporations are worried about what they see as the huge compliance burden imposed by the global 15% minimum tax and are asking for permanent simplifications of the rules, two corporate tax officials said Friday.
House GOP Urges USTR To Probe Canada Digital Services Tax
The U.S. trade representative should immediately launch an investigation into Canada's recently enacted digital services tax and determine if trade actions are necessary to protect American interests, U.S. House Ways and Means Republicans said in a letter Thursday.
Featured Stories
-
French Left's Tax Pledges May Go Unfulfilled
The tax policy pledges put forward by the leftist bloc of parties that won the most seats in France's legislative election may not be fulfilled given the bloc's failure to win an outright majority.
-
Top International Tax Cases Of 2024: Midyear Report
With a U.S. Supreme Court decision affirming a key 2017 tax provision on repatriation, millions of dollars in FBAR penalties upheld and a French ruling confirming the U.S. government's access to foreign bank accounts, the IRS stacked up important court victories on international enforcement in the first half of 2024. Here, Law360 reviews those and other significant rulings from the past six months.
-
How Reshaped Circuit Courts Are Faring At The High Court
Seminal rulings from the U.S. Supreme Court's latest term will reshape many facets of American society in the coming years. Already, however, the rulings offer glimpses of how the justices view specific circuit courts, which have themselves been reshaped by an abundance of new judges.
Expert Analysis
-
States Should Loosen Law Firm Ownership Restrictions
Despite growing buzz, normalized nonlawyer ownership of law firms is a distant prospect, so the legal community should focus first on liberalizing state restrictions on attorney and firm purchases of practices, which would bolster succession planning and improve access to justice, says Michael Di Gennaro at The Law Practice Exchange.
-
After Chevron: Uniform Tax Law Interpretation Not Guaranteed
The loss of Chevron deference will significantly alter the relationship between the IRS, courts and Congress when it comes to tax law, potentially precipitating more transparent rulemaking, but also provoking greater uncertainty due to variability in judicial interpretation, say Michelle Levin and Carneil Wilson at Dentons.
-
Texas Ethics Opinion Flags Hazards Of Unauthorized Practice
The Texas Professional Ethics Committee's recently issued proposed opinion finding that in-house counsel providing legal services to the company's clients constitutes the unauthorized practice of law is a valuable clarification given that a UPL violation — a misdemeanor in most states — carries high stakes, say Hilary Gerzhoy and Julienne Pasichow at HWG.
-
How To Clean Up Your Generative AI-Produced Legal Drafts
As law firms increasingly rely on generative artificial intelligence tools to produce legal text, attorneys should be on guard for the overuse of cohesive devices in initial drafts, and consider a few editing pointers to clean up AI’s repetitive and choppy outputs, says Ivy Grey at WordRake.
-
Industry Self-Regulation Will Shine Post-Chevron
The U.S. Supreme Court's Loper decision will shape the contours of industry self-regulation in the years to come, providing opportunities for this often-misunderstood practice, says Eric Reicin at BBB National Programs.
-
3 Ways Agencies Will Keep Making Law After Chevron
The U.S. Supreme Court clearly thinks it has done something big in overturning the Chevron precedent that had given deference to agencies' statutory interpretations, but regulated parties have to consider how agencies retain significant power to shape the law and its meaning, say attorneys at K&L Gates.
-
Atty Well-Being Efforts Ignore Root Causes Of The Problem
The legal industry is engaged in a critical conversation about lawyers' mental health, but current attorney well-being programs primarily focus on helping lawyers cope with the stress of excessive workloads, instead of examining whether this work culture is even fundamentally compatible with lawyer well-being, says Jonathan Baum at Avenir Guild.
-
Unpacking The Circuit Split Over A Federal Atty Fee Rule
Federal circuit courts that have addressed Rule 41(d) of the Federal Rules of Civil Procedure are split as to whether attorney fees are included as part of the costs of a previously dismissed action, so practitioners aiming to recover or avoid fees should tailor arguments to the appropriate court, says Joseph Myles and Lionel Lavenue at Finnegan.
-
After A Brief Hiccup, The 'Rocket Docket' Soars Back To No. 1
The Eastern District of Virginia’s precipitous 2022 fall from its storied rocket docket status appears to have been a temporary aberration, as recent statistics reveal that the court is once again back on top as the fastest federal civil trial court in the nation, says Robert Tata at Hunton.
-
Recruitment Trends In Emerging Law Firm Frontiers
BigLaw firms are facing local recruitment challenges as they increasingly establish offices in cities outside of the major legal hubs, requiring them to weigh various strategies for attracting talent that present different risks and benefits, says Tom Hanlon at Buchanan Law.
-
How Associates Can Build A Professional Image
As hybrid work arrangements become the norm in the legal industry, early-career attorneys must be proactive in building and maintaining a professional presence in both physical and digital settings, ensuring that their image aligns with their long-term career goals, say Lana Manganiello at Equinox Strategy Partners and Estelle Winsett at Estelle Winsett Professional Image Consulting.
-
Firms Must Rethink How They Train New Lawyers In AI Age
As law firms begin to use generative artificial intelligence to complete lower-level legal tasks, they’ll need to consider new ways to train summer associates and early-career attorneys, keeping in mind the five stages of skill acquisition, says Liisa Thomas at Sheppard Mullin.
-
Think Like A Lawyer: Always Be Closing
When a lawyer presents their case with the right propulsive structure throughout trial, there is little need for further argument after the close of evidence — and in fact, rehashing it all may test jurors’ patience — so attorneys should consider other strategies for closing arguments, says Luke Andrews at Poole Huffman.