International
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July 26, 2024
Taxation With Representation: Wachtell, Polsinelli, Kirkland
In this week's Taxation With Representation, T-Mobile partners with KKR to acquire Metronet, Exclusive Networks gets a takeover offer, KKR buys Instructure Holdings Inc., and Bally's Corp. merges with The Queen Casino & Entertainment Inc.
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July 26, 2024
Australia Clarifies Tax Treatment Of Exploration, Land Rights
The Australian government has amended its petroleum resource rent tax to clarify what is considered "exploration for petroleum" for tax purposes, and changes are coming soon regarding the depreciation of mining, quarrying and prospecting rights, the Australian Taxation Office said.
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July 26, 2024
EU Closes Investigation Into Repealed Hungarian Ad Tax
The European Commission said Friday it has closed its nearly decadelong investigation into a Hungarian advertisement tax that it said violated the European Union's state aid rules, noting that the country has repealed the law in question.
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July 26, 2024
EU Frees Up €1.5B Of Frozen Russian Assets To Aid Ukraine
The European Union's executive branch said Friday that it is freeing up €1.5 billion ($1.6 billion) of revenue generated from immobilized Russian assets to aid Ukraine in defending itself against the Russian invasion.
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July 25, 2024
Global Tax Revamp Continues To Progress, OECD Tells G20
Implementation of the Pillar Two minimum tax portion of the OECD's international plan to address tax base erosion and profit shifting is well underway, while an agreement is close on the Pillar One taxing rights overhaul, the organization told the Group of 20 nations Thursday.
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July 25, 2024
UK Telecom Co. Owes VAT For Phone Plans In £51M Dispute
A U.K. telecommunications provider will not recover £51.1 million ($65.7 million) in value-added tax payments after the First-tier Tribunal ruled that VAT is chargeable on phone plans from the point of sale, not when the services are used.
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July 25, 2024
Global Tax Police Unit Probes More Than 30 Cybercrime Cases
The Joint Chiefs of Global Tax Enforcement, an intergovernmental tax enforcement group, is investigating more than 30 active cybercrime cases tied to financial and tax criminal activities all over the world, the group announced Thursday in its first report.
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July 25, 2024
Income Inequality Calls For Stronger Tax Policies, OECD Says
More focus is being drawn to stronger tax policies as a way to solve persistent income inequality, especially in light of the continually increasing concentration of wealth by the top 0.001% of earners, the Organization for Economic Cooperation and Development said Thursday.
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July 25, 2024
Mixed Progress Made On Beneficial Ownership, OECD Says
The U.S., Japan and the European Union now have wide-reaching beneficial ownership registries in place, but many jurisdictions worldwide aren't effectively exchanging data on the owners of legal entities, the OECD said Thursday in a report based on peer reviews.
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July 25, 2024
Australian Officials Defend Basis for Tax Reporting Framework
Australia's public corporate tax disclosure legislation builds on global standards that could provide more insights into profit shifting risks than European Union reporting rules, Australian government officials said Thursday in response to calls for closer alignment between the two regimes.
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July 25, 2024
Billionaire Tax Not Fit For Global Agreement, Yellen Says
The U.S. government doesn't think it's appropriate to seek a global agreement on taxing billionaires, Treasury Secretary Janet Yellen said Thursday ahead of a discussion by the Group of 20 nations on coordinating wealth taxes.
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July 25, 2024
58 Jurisdictions Plan For Crypto Info Swaps By 2027
Fifty-eight tax jurisdictions have pledged to implement the Organization for Economic Cooperation and Development's crypto-asset information exchange system by 2027, the OECD said Thursday.
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July 25, 2024
Wyden Seeks Swiss Bank Info On Indicted Defense Contractor
Senate Finance Committee Chairman Ron Wyden asked Swiss bank UBS in a letter published Thursday for information about a former U.S. defense contractor who the Department of Justice says avoided taxes on more than $350 million in income.
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July 25, 2024
Clark Hill Adds Tax And Estate Atty From Plunk Smith In Texas
A former Plunk Smith PLLC senior associate jumped to Clark Hill in Collin County, Texas, to serve as a member in the tax and estate planning practice, the firm announced Thursday.
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July 25, 2024
GOP Control Could Muddle Tax Picture For Multinationals
Republican lawmakers and former President Donald Trump could create more confusion for multinationals with their tax and trade policies if they sweep the U.S. elections in November, because they are likely to pursue retaliatory measures in opposition to the OECD's global tax rewrite.
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July 25, 2024
Cyprus Consents To Pillar 2 Safe Harbor Rules
Cyprus has formally consented to the Organization for Economic Cooperation and Development's Pillar Two safe harbor rules, continuing its support for the organization's push against tax base erosion and profit shifting despite not being a full member, the Cypriot finance ministry said.
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July 25, 2024
Gov'ts Seek Info On Foreign Real Estate Holdings, OECD Says
Governments are keen to receive information on their residents' foreign real estate holdings, especially related to disposals and regular income from owning properties, which could be achieved with a new treaty under the existing tax transparency framework, the OECD said Thursday.
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July 25, 2024
Belgium Taken To EU Court Over Deposit Exemption Rules
The European Union's executive branch said Thursday that it is taking Belgium to court alleging that the country's system of exempting remuneration of savings deposits from tax violates EU law.
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July 24, 2024
Int'l Firm Garrigues Merges With Full-Service Mexican Firm
International legal and tax services firm Garrigues will create one of the largest law firms in Mexico by integrating a full-service Mexican firm into the group by the end of 2024, both firms announced.
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July 24, 2024
Nigerian Parliament Passes 70% Bank Windfall Levy
The upper house of Nigeria's Parliament passed an amendment to its finance bill that included a 70% one-time levy on banks' foreign exchange gains, an increase over the 50% rate originally proposed by the country's president.
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July 24, 2024
IRS' $15M Jeopardy Assessment OK'd In Offshore Tax Fight
A Florida federal court has upheld a $15 million immediate tax assessment against a man who transferred his father's estate into trusts for himself and his mother and refused to pay what the IRS claimed was tax debt on his father's undisclosed offshore accounts.
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July 24, 2024
Affordable Housing Pro Moves Practice To Nelson Mullins
An attorney who specializes in advising clients on completing affordable housing development projects has recently moved her practice to Nelson Mullins Riley & Scarborough's Pittsburgh office.
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July 24, 2024
HMRC Wins Battle Over Candy Maker's Holiday Fund Scheme
HM Revenue & Customs has convinced an appeals tribunal that a Scottish sweet maker must compensate its employees for salary deductions it put aside in "holiday funds," with the judge finding the scheme ran afoul of national minimum wage regulations.
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July 24, 2024
Germany Failing To Address Nonprofits' Tax Status, EU Says
Germany has failed to make any progress addressing uncertainty surrounding the tax-exempt status of nonprofit organizations a year after the European Commission recommended it do so, the commission said Wednesday.
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July 24, 2024
Dentons Brings On Former Big 4 Exec As New Global CEO
Global law firm Dentons, which has made a name for itself by aggressive growth through combinations, has tapped a new global chief executive officer with leadership experience at accounting giant EY, the firm's first change at the top in over a decade.
Expert Analysis
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What Large Language Models Mean For Document Review
Courts often subject parties using technology assisted review to greater scrutiny than parties conducting linear, manual document review, so parties using large language models for document review should expect even more attention, along with a corresponding need for quality control and validation, say attorneys at Sidley.
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Participating In Living History Makes Me A Better Lawyer
My role as a baron in a living history group, and my work as volunteer corporate counsel for a book series fan association, has provided me several opportunities to practice in unexpected areas of law — opening doors to experiences that have nurtured invaluable personal and professional skills, says Matthew Parker at the Nebraska Department of Health and Human Services.
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Private Equity Owners Can Remedy Law Firms' Agency Issues
Nonlawyer, private-equity ownership of law firms can benefit shareholders and others vulnerable to governance issues such as disparate interests, and can in turn help resolve agency problems, says Michael Di Gennaro at The Law Practice Exchange.
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How Taxpayers Can Prep As Justices Weigh Repatriation Tax
The U.S. Supreme Court might strike down the 2017 federal tax overhaul's corporate repatriation tax in Moore v. U.S., so taxpayers should file protective tax refund claims before the case is decided and repatriate previously taxed earnings that could become entangled in dubious potential Section 965 refunds, say Jenny Austin and Gary Wilcox at Mayer Brown.
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OFAC Designation Prosecutions Are Constitutionally Suspect
Criminal prosecutions based on the Office of Foreign Assets Control’s sanctions-related listing decisions — made with nearly unfettered discretion through an opaque process — present several constitutional issues, so it is imperative that courts recognize additional rights of review, say Solomon Shinerock and Annika Conrad at Lewis Baach.
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How The OECD Global Tax Proposal Could Affect M&A
Following agreement on the Organization for Economic Cooperation and Development’s Pillar Two proposal to introduce a global minimum tax, domestic implementation is expected to have a significant impact on international M&A transactions, with financial modeling, deal structuring, risk allocation and joint venture arrangements likely to be affected, say lawyers at Freshfields.
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UK Shares-Tax Proposals Offer Long-Awaited Modernization
The U.K. government's recent consultation on the introduction of a new tax on transactions in securities raises detailed legal and practical issues, but the prospect of a single digital stamp tax offering both streamlined legislation and administration will be welcomed, say Zoë Arnautov and Mark Sheiham at Simmons & Simmons.
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IRS Foreign Tax Credit Pause Is Welcome Course Correction
A recent IRS notice temporarily suspending application of 2022 foreign tax credit regulations provides wanted relief for the many U.S. multinational companies and other taxpayers that otherwise face the risk of significant double taxation in their international operations, say attorneys at Mayer Brown.
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IRS Criminal Probe Spells Uncertainty For Malta Pension Plans
The IRS’ recent scrutiny of Malta pension plan arrangements — and its unusual issuance of criminal administrative summonses — confirms that it views many of these plans as illegal tax evasion schemes, and the road ahead will not be smooth and steady for anyone involved, say attorneys at Kostelanetz.
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IRS Announcement Will Aid Cos. In Buyback Tax Planning
Recent IRS transitional guidance regarding current requirements for reporting and payment of the stock repurchase excise tax will help corporate taxpayers make decisions about records retention and establishing reserves for future tax payments, say Xenia Garofalo and Kyle Colonna at Eversheds Sutherland.
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Flawed Analysis Supports Common Law Tax Deficiency Ruling
The Colorado federal district court’s recent decision in Liberty Global, holding that the U.S. Department of Justice may assert a common law tax claim without the notice of tax deficiency required by the Internal Revenue Code, relies on a contorted reading of the statute and irrelevant case law, say Loren Opper and Christie Galinski at Miller Canfield.
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Review Of Repatriation Tax Sets Justices On Slippery Slope
The U.S. Supreme Court’s recent decision to review the constitutionality of the repatriation tax in Moore v. U.S. has implications for many tax rules involving unrealized amounts and could leave the court on the brink of invalidating large swaths of the Internal Revenue Code, say attorneys at Eversheds Sutherland.
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What To Make Of IRS' New Advance Pricing Guidance
Recent guidance on the IRS' goals for its advance pricing agreement system provides helpful insight into review and decision-making procedures for advance pricing agreement requests, but it also raises questions about the IRS' objectives, say Richard Slowinski and Stefanie Kavanagh at Alston & Bird.