International
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August 26, 2024
New Zealand Considers OECD Crypto Reporting Framework
New Zealand would implement the Organization for Economic Cooperation and Development's framework for automatically exchanging financial information regarding crypto-assets under a proposal the country's revenue minister sent to its Legislature on Monday.
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August 26, 2024
Canada Planning 100% Surtax On Chinese EVs, 25% On Steel
Canada plans to implement a 100% surtax on imported Chinese electric vehicles and a 25% surtax on Chinese steel and aluminum as part of a package intended to protect Canadian industry from unfair competition, the country's Department of Finance said Monday.
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August 23, 2024
Chamber Backs Doctor In Tax Court Economic Substance Suit
The U.S. Chamber of Commerce lent its support to an eye doctor and his wife's U.S. Tax Court case disputing accuracy-related penalties that the Internal Revenue Service plans to impose on their microcaptive insurance arrangements for lacking economic substance.
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August 23, 2024
IRS Spinoff Guidance Sparks Worries About Short-Term Debt
Companies that intend to give creditors equity tied to a spinoff transaction won't get early tax-free approval if the exchange involves recently acquired debt under IRS guidance that practitioners say draws an arbitrary line without accounting for ordinary business operations.
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August 23, 2024
Alvarez & Marsal Adds Transfer Pricing Expert From EY
A former EY partner joined Alvarez & Marsal LLC to serve as managing director of its transfer pricing line of services in its New York office, the firm announced.
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August 23, 2024
45% Of US Biz Income Abroad In Tax Havens, Data Shows
U.S. multinational corporations booked about 45% of their $1.33 trillion in net foreign income in 2022 in low-tax jurisdictions where around 1.7% of their employees are located, according to an analysis of data released Friday by the Bureau of Economic Analysis.
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August 23, 2024
German Official Backs Anti-Abuse Tax Rules Roll-Back Review
A German Federal Ministry of Finance official agreed with tax experts' proposal to review the anti-abuse provisions of international tax law in order to potentially roll them back, especially with the global corporate minimum tax going into force across the European Union.
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August 23, 2024
Taxation With Representation: Latham, Wachtell, Paul Weiss
In this week's Taxation With Representation, Arch Resources merges with Consol Energy in a deal worth $5.2 billion, Advanced Micro Devices agrees to purchase ZT Systems for $4.9 billion, and Japanese tobacco company JT Group inks a deal to buy Vector Group for $2.4 billion.
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August 23, 2024
HMRC Can Be Liable For Damage To Biz Shut Over £7.4M Debt
The tax authority cannot lift a court order that requires it to repay a payroll business damages for losses suffered after it was put into provisional liquidation, as a court found on Friday that it had failed to pursue that action for law enforcement purposes.
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August 22, 2024
Switzerland Expects 3.2% Tax Receipt Increase In 2025
Switzerland expects to generate 85.7 billion Swiss francs ($100.6 billion) in tax receipts in 2025, an increase of 3.2% over the 2024 budget, with the biggest growth projected to come from personal income taxes, the country's Federal Finance Administration said Thursday.
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August 22, 2024
Kenya's Justices May Ax Part Of Tax Act That Set Off Unrest
The Supreme Court of Kenya agreed to stay a lower court's ruling declaring unconstitutional the government's entire 2023 tax package, which sparked deadly nationwide protests, but it looks likely to scrap at least part of the law next month, attorneys told Law360 on Thursday.
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August 22, 2024
Australian Legislators Advance Enactment Of Global Min. Tax
Australia would enact the Organization for Economic Cooperation and Development's 15% global corporate minimum tax on large multinational entities, known as Pillar Two, under three bills passed Thursday by the country's House of Representatives.
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August 22, 2024
EU Decision Keeps Tax Relief For UK Investment Schemes
The European Commission will allow U.K. government-backed programs that encourage private investment in small companies to continue offering favorable tax terms for investors, according to a decision published Thursday.
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August 22, 2024
Ryanair Threatens Service Cuts Over German Tax Increase
Irish discount airline Ryanair said it will cut 10% of its German capacity next summer if the country doesn't reverse a recent 24% increase in its aviation tax, calling on Germany to ultimately abolish the tax altogether.
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August 22, 2024
Over 3M UK Pensioners To Be Dragged Into Higher Tax Rates
Government data shows 3.1 million U.K. pensioners will be dragged into paying higher taxes in the next four years due to the freeze on income thresholds, financial firm Quilter PLC said Thursday.
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August 21, 2024
Ariz. Man Should Pay Full $2.7M FBAR Bill, Gov't Says
An Arizona man who failed to report his foreign bank accounts in Switzerland owes approximately $2.7 million in recalculated penalties and interest to the Internal Revenue Service, the U.S. told an Arizona federal court.
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August 21, 2024
UK Tax Collection Rises 5% To £829B
HM Revenue & Customs said Wednesday that the U.K. raised over £829 billion ($1.09 trillion) in taxes in fiscal year 2023-2024, up over 5% from the previous year.
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August 21, 2024
9th Circ. Upholds FBAR Penalty, Imposes Contested Interest
A woman who operates a New Zealand winery must pay $238,000 in penalties and an extra $105,000 in interest and fees for failing to report her New Zealand financial accounts to the U.S. government, the Ninth Circuit ruled Wednesday.
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August 21, 2024
3 Questions Raised By Harris' Support For 28% Corp. Tax Rate
Vice President Kamala Harris has proposed increasing the corporate tax rate to 28% to boost revenue if she's elected president, but the proposed hike raises questions about changes to the corporate tax base, the future of the OECD's global tax deal and the potential impact on workers.
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August 21, 2024
Pros Tell IRS To Ease Off Foreign Gift Reporting Penalties
The Internal Revenue Service should take a more lenient approach when considering penalty abatements for certain individuals who fail to report large foreign gifts under proposed disclosure regulations, practitioners told the agency Wednesday.
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August 21, 2024
New Zealand Seeks Feedback On Future Of Tax System
New Zealand's revenue agency is looking for feedback on plans for a potential broad restructuring of the country's tax system in order to address coming financial pressures, including possibly altering its income and consumption tax regimes, it said Wednesday.
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August 21, 2024
Swiss Council Approves Tax Treaty With Jordan
Switzerland's Federal Council approved a treaty Wednesday to avoid double taxation with Jordan that it says largely follows the Organization for Economic Cooperation and Development's model convention for such agreements.
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August 21, 2024
Swiss Extend Tax Exemptions For 'Too Big To Fail' Instruments
Switzerland's Federal Council decided Wednesday to extend temporary withholding tax exemptions on interest for what it calls too-big-to-fail instruments for banks, such as bail-in or write-off bonds.
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August 21, 2024
Germany Opens Consultation On Min. Tax Reporting Changes
Germany's Federal Ministry of Finance is seeking feedback on a proposal to incorporate updated guidance from the Organization for Economic Cooperation and Development regarding reporting requirements associated with the global corporate minimum tax.
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August 21, 2024
VAT Fraudster Loses Bid To Escape Repaying £1.4M
A man involved in a £40 million ($52 million) criminal tax fraud scheme has lost a bid to avoid repaying £1.4 million as a London court ruled on Wednesday that he had failed to prove he no longer had hidden assets.
Expert Analysis
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.