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

  • How Clients May Use AI To Monitor Attorneys

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    Artificial intelligence tools will increasingly enable clients to monitor and evaluate their counsel’s activities, so attorneys must clearly define the terms of engagement and likewise take advantage of the efficiencies offered by AI, says Ronald Levine at Herrick Feinstein.

  • The Pop Culture Docket: Judge D'Emic On Moby Grape

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    The 1968 Moby Grape song "Murder in My Heart for the Judge" tells the tale of a fictional defendant treated with scorn by the judge, illustrating how much the legal system has evolved in the past 50 years, largely due to problem-solving courts and the principles of procedural justice, says Kings County Supreme Court Administrative Judge Matthew D'Emic.

  • Breaking Down High Court's New Code Of Conduct

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    The U.S. Supreme Court recently adopted its first-ever code of conduct, and counsel will need to work closely with clients in navigating its provisions, from gift-giving to recusal bids, say Phillip Gordon and Mateo Forero at Holtzman Vogel.

  • Legal Profession Gender Parity Requires Equal Parental Leave

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    To truly foster equity in the legal profession and to promote attorney retention, workplaces need to better support all parents, regardless of gender — starting by offering equal and robust parental leave to both birthing and non-birthing parents, says Ali Spindler at Irwin Fritchie.

  • A Year-End Look At Florida's Capital Investment Tax Credit

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    Notwithstanding the Walt Disney Co.’s feud with Gov. Ron DeSantis this year, Florida's capital investment tax credit will continue to make the state a favored destination for large corporations, particularly in light of the new federal alternative minimum tax and the Pillar Two top-up tax, says Alan Lederman at Gunster.

  • Understanding Discovery Obligations In Era Of Generative AI

    Excerpt from Practical Guidance
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    Attorneys and businesses must adapt to the unique discovery challenges presented by generative artificial intelligence, such as chatbot content and prompts, while upholding the principles of fairness, transparency and compliance with legal obligations in federal civil litigation, say attorneys at King & Spalding.

  • The Case For Post-Bar Clerk Training Programs At Law Firms

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    In today's competitive legal hiring market, an intentionally designed training program for law school graduates awaiting bar admission can be an effective way of creating a pipeline of qualified candidates, says Brent Daub at Gilson Daub.

  • AI Can Help Lawyers Overcome The Programming Barrier

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    Legal professionals without programming expertise can use generative artificial intelligence to harness the power of automation and other technology solutions to streamline their work, without the steep learning curve traditionally associated with coding, says George Zalepa at Greenberg Traurig.

  • Preparing Law Students For A New, AI-Assisted Legal World

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    As artificial intelligence rapidly transforms the legal landscape, law schools must integrate technology and curricula that address AI’s innate challenges — from ethics to data security — to help students stay ahead of the curve, say Daniel Garrie at Law & Forensics, Ryan Abbott at JAMS and Karen Silverman at Cantellus Group.

  • General Counsel Need Data Literacy To Keep Up With AI

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    With the rise of accessible and powerful generative artificial intelligence solutions, it is imperative for general counsel to understand the use and application of data for myriad important activities, from evaluating the e-discovery process to monitoring compliance analytics and more, says Colin Levy at Malbek.

  • Navigating Discovery Of Generative AI Information

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    As generative artificial intelligence tools become increasingly ubiquitous, companies must make sure to preserve generative AI data when there is reasonable expectation of litigation, and to include transcripts in litigation hold notices, as they may be relevant to discovery requests, say Nick Peterson and Corey Hauser at Wiley.

  • Finding Focus: Strategies For Attorneys With ADHD

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    Given the prevalence of ADHD among attorneys, it is imperative that the legal community gain a better understanding of how ADHD affects well-being, and that resources and strategies exist for attorneys with this disability to manage their symptoms and achieve success, say Casey Dixon at Dixon Life Coaching and Krista Larson at Stinson.

  • Attorneys, Law Schools Must Adapt To New Era Of Evidence

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    Technological advancements mean more direct evidence is being created than ever before, and attorneys as well as law schools must modify their methods to account for new challenges in how this evidence is collected and used to try cases, says Reuben Guttman at Guttman Buschner.

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