International

  • August 29, 2024

    Brazil Seeks Comments On Transfer Pricing Guidelines

    Brazil is seeking public comments on proposed regulations related to its 2023 adoption of new transfer pricing rules, including the application of the international arm's-length standard, the country's revenue agency said Thursday.

  • August 29, 2024

    UK Reports £300M Rise In Tax Relief To Creative Industries

    Creative industries received £2.2 billion ($2.9 billion) in tax relief from the U.K. in the 2022-23 tax year, an increase of £300 million over the prior year largely driven by more claims from high-end TV and theater productions, HM Revenue & Customs said Thursday.

  • August 29, 2024

    Sky Sports Rugby Pundit Loses Bid To Duck £700K Tax Bill

    Rugby commentator Stuart Barnes has lost his attempt to escape a tax bill of almost £700,000 ($921,000) as a tribunal ruled that he owed the money because a contract between his company and Sky was equivalent to an employer-employee relationship.

  • August 28, 2024

    IRS Declines Watchdog's Ask For Attys In Talks With Big Cos.

    The IRS declined a recommendation by its internal watchdog to require the agency's counsel to attend talks held with large multinational corporations by its appellate division, which agents say thwarts their ability to correctly enforce the economic substance doctrine, according to a report.

  • August 28, 2024

    Feds Looks To Toss Ex-Citizens' Renunciation Fee Challenge

    The federal government asked a D.C. federal judge to throw out a lawsuit brought by former U.S. citizens who want their $2,350 citizenship renunciation fee refunded, arguing during a Wednesday hearing that the United States is immune from the litigation and the plaintiffs can't relitigate claims that they already lost.

  • August 28, 2024

    IRS Corrects Proposed Foreign Currency Accounting Regs

    The Internal Revenue Service issued corrections Wednesday to proposed rules that would adjust the timing for when companies could opt to use what is known as the mark-to-market accounting method for gains or losses that arise from foreign currency transactions.

  • August 28, 2024

    Jury Justified In Dismissing $2.2M FBAR Case, Court Rules

    A financial adviser will not face a new trial after an Arizona federal court ruled there was sufficient evidence for a jury to clear him in January of failing to report foreign bank accounts, sparing him at least $2.2 million in penalties.

  • August 28, 2024

    Sysco, IRS Asked To Address Varian's Foreign Dividend Win

    The U.S. Tax Court asked food services giant Sysco and the IRS to address how a tax dispute between them is affected by a recent ruling in a similar case that found medical device company Varian can claim a deduction for foreign dividends.

  • August 28, 2024

    Treasury To Require Reports On All-Cash Real Estate Deals

    Anyone who transfers real estate to a legal entity in an all-cash transaction, including attorneys, will be required starting Dec. 1, 2025, to inform the U.S. Treasury Department about that entity's beneficial owners and their identification numbers under a final rule issued Wednesday. 

  • August 28, 2024

    Greenberg Traurig Builds PE Team With Kirkland Hires

    Greenberg Traurig LLP has brought on two fund formation partners from Kirkland & Ellis LLP to continue its growth into the private equity space, according to an announcement this week by the firm.

  • August 28, 2024

    Taiwan Considering OECD's Global Minimum Tax

    Taiwan is looking to implement the Organization for Economic Cooperation and Development's 15% global corporate minimum tax on large multinational entities starting in 2026, the country's Ministry of Finance said Wednesday.

  • August 28, 2024

    Ireland May Add Timing Flexibility To Dividend Exemption

    The Irish government floated more timing flexibility for companies seeking to opt into the country's planned tax exemption for foreign-sourced earnings, but it declined to widen the system's geographical scope.

  • August 28, 2024

    Atty Can't Escape Danish Tax Agency's $2.1B Tax Fraud Suit

    An attorney in a $2.1 billion tax fraud case brought by the Danish tax authority cannot argue that a suit filed against him as an individual should be dismissed because it was filed late, a New York federal court ruled.

  • August 27, 2024

    Gov't Says Doctor Can't Escape Contempt Fine In FBAR Case

    A doctor challenging his $20,000 civil contempt fine for failing to follow a court order to repatriate money from his foreign bank account to cover $1.1 million in tax liabilities shouldn't be allowed to escape the penalty, the U.S. government argued Tuesday.

  • August 27, 2024

    Canadian Grocery Giant's Bank Wins Appeal Over Tax Credits

    The Tax Court of Canada incorrectly decided that a bank owned by the country's largest supermarket chain, Loblaw, couldn't claim tax credits aimed at exempting commercial purchases for payments the bank made in a customer rewards program, a Federal Court of Appeal panel ruled.

  • August 27, 2024

    OECD Says Malaysia Should Resume GST, End Fuel Subsidies

    With spending pressures rising, Malaysia should look to increase its tax revenues through measures including a reintroduction of its goods and services tax, as well as push to minimize its climate impact by eliminating fuel subsidies, the Organization for Economic Cooperation and Development said Tuesday.

  • August 27, 2024

    Treasury Asked To Scrap Stock Buyback Tax's Funding Rule

    Business groups urged the U.S. Treasury Department on Tuesday to remove what's known as the funding rule in forthcoming final regulations on the stock buyback tax, saying the provision would go beyond Congress' intentions for the levy, which aims to deter companies from giving outsize rewards to shareholders.

  • August 27, 2024

    Croatia, HK, Others Address Hurtful Tax Regimes, OECD Says

    Five tax jurisdictions, including Croatia and Hong Kong, have made progress to address various harmful tax practices, the Organization for Economic Cooperation and Development said Tuesday.

  • August 27, 2024

    Germany Proposes Investment Tax Changes To Attract VC

    Germany would adjust its tax laws in an attempt to better attract venture capital and investments into renewable energies under a proposal published Tuesday by the country's finance ministry as part of a planned "growth initiative."

  • August 27, 2024

    Starmer Warns Of 'Painful' Budget As UK Braces For Tax Hikes

    U.K. Prime Minister Keir Starmer warned Tuesday of "painful" decisions to plug budget gaps, including tax increases and spending cuts, looming in the Oct. 30 budget statement.

  • August 27, 2024

    Gov't Urged To Reform Pension Tax To Fill Budget Gaps

    The Labour government should reform £66 billion ($87 billion) worth of pension tax relief to raise extra revenue to help plug the black hole in public finances, a think tank affiliated to the party has said.

  • August 26, 2024

    Varian Entitled To Foreign Dividend Break, Tax Court Says

    California-based medical device company Varian Medical Systems is entitled to a deduction for dividends received from its foreign subsidiaries, the U.S. Tax Court ruled Monday in a unanimous opinion.

  • August 26, 2024

    US Should Extend Expiring TCJA Tax Cuts, Chamber Says

    The expiration of the 2017 Tax Cuts and Jobs Act in 2025 gives the next Congress an opportunity to pass pro-growth tax policies, the U.S. Chamber of Commerce said Monday.

  • August 26, 2024

    Kyocera's Gross-Up Doesn't Grant $143M Tax Break, US Says

    Electronics maker Kyocera cannot be allowed to take a $143 million tax deduction for distributions received under a 2017 tax law based on a separate statute's gross-up for paid foreign tax credits, the government told a South Carolina federal court.

  • 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.

Expert Analysis

  • What Recent Study Shows About AI's Promise For Legal Tasks

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    Amid both skepticism and excitement about the promise of generative artificial intelligence in legal contexts, the first randomized controlled trial studying its impact on basic lawyering tasks shows mixed but promising results, and underscores the need for attorneys to proactively engage with AI, says Daniel Schwarcz at University of Minnesota Law School.

  • How FinCEN Proposal Expands RE Transaction Obligations

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    Against a regulatory backdrop foreshadowing anti-money laundering efforts in the real estate sector, the Financial Crimes Enforcement Network's proposed rule significantly expands reporting requirements for certain nonfinanced residential real estate transfers and necessitates careful review, say attorneys at Fried Frank.

  • Litigation Inspiration: A Source Of Untapped Fulfillment

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    As increasing numbers of attorneys struggle with stress and mental health issues, business litigators can find protection against burnout by remembering their important role in society — because fulfillment in one’s work isn’t just reserved for public interest lawyers, say Bennett Rawicki and Peter Bigelow at Hilgers Graben.

  • Unpacking FinCEN's Proposed Real Estate Transaction Rule

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    Phil Jelsma and Ulrick Matsunaga at Crosbie Gliner take a close look at the Financial Crimes Enforcement Network's recently proposed rulemaking — which mandates new disclosures for professionals involved in all-cash real estate deals — and discuss best next steps for the broad range of businesses that could be affected.

  • Think Like A Lawyer: Forget Everything You Know About IRAC

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    The mode of legal reasoning most students learn in law school, often called “Issue, Rule, Application, Conclusion,” or IRAC, erroneously frames analysis as a separate, discrete step, resulting in disorganized briefs and untold obfuscation — but the fix is pretty simple, says Luke Andrews at Poole Huffman.

  • How New EU Tax And Transfer Pricing Rules May Affect M&A

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    Companies involved in mergers and acquisitions may need to adjust fiscal due diligence procedures to ensure they consider potential far-reaching effects of newly implemented transfer pricing measures, such as newly implemented global minimum tax and European Union anti-tax avoidance directives and proposals, says Patrick Tijhuis at BDO.

  • How Firms Can Ensure Associate Gender Parity Lasts

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    Among associates, women now outnumber men for the first time, but progress toward gender equality at the top of the legal profession remains glacially slow, and firms must implement time-tested solutions to ensure associates’ gender parity lasts throughout their careers, say Kelly Culhane and Nicole Joseph at Culhane Meadows.

  • 7 Common Myths About Lateral Partner Moves

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    As lateral recruiting remains a key factor for law firm growth, partners considering a lateral move should be aware of a few commonly held myths — some of which contain a kernel of truth, and some of which are flat out wrong, says Dave Maurer at Major Lindsey.

  • 6 Pointers For Attys To Build Trust, Credibility On Social Media

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    In an era of information overload, attorneys can use social media strategically — from making infographics to leveraging targeted advertising — to cut through the noise and establish a reputation among current and potential clients, says Marly Broudie at SocialEyes Communications.

  • US-Chile Tax Treaty May Encourage Cross-Border Investment

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    Provisions in the recently effective U.S.-Chile bilateral income tax treaty should encourage business between the two countries, as they reduce U.S. withholding tax on investment income for Chilean taxpayers, exempt certain U.S. taxpayers from Chilean capital gains tax, and clarify U.S. foreign tax credit rules, say attorneys at Kramer Levin.

  • A Post-Mortem Analysis Of Stroock's Demise

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    After the dissolution of 147-year-old firm Stroock late last year shook up the legal world, a post-mortem analysis of the data reveals a long list of warning signs preceding the firm’s collapse — and provides some insight into how other firms might avoid the same disastrous fate, says Craig Savitzky at Leopard Solutions.

  • SG's Office Is Case Study To Help Close Legal Gender Gap

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    As women continue to be underrepresented in the upper echelons of the legal profession, law firms could learn from the example set by the Office of the Solicitor General, where culture and workplace policies have helped foster greater gender equality, say attorneys at Ocean Tomo.

  • Reimagining Law Firm Culture To Break The Cycle Of Burnout

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    While attorney burnout remains a perennial issue in the legal profession, shifting post-pandemic expectations mean that law firms must adapt their office cultures to retain talent, say Kevin Henderson and Eric Pacifici at SMB Law Group.

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