International

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • August 20, 2024

    UN Dives Into Murky Waters Of Taxing Digital Services

    The United Nations has its sights set on cross-border services in the digital economy as its framework convention on tax takes shape, but it remains unclear how countries will define that broad and hotly contested topic as they work toward a treaty.

Expert Analysis

  • Cayman Islands Off AML Risk Lists, Signaling Robust Controls

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    As a world-leading jurisdiction for securitization special purpose entities, the removal of the Cayman Islands from increased anti-money laundering monitoring lists is a significant milestone that will benefit new and existing financial services customers conducting business in the territory, say lawyers at Walkers Global.

  • The Legal Industry Needs A Cybersecurity Paradigm Shift

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    As law firms face ever-increasing risks of cyberattacks and ransomware incidents, the legal industry must implement robust cybersecurity measures and privacy-centric practices to preserve attorney-client privilege, safeguard client trust and uphold the profession’s integrity, says Ryan Paterson at Unplugged.

  • As Promised, IRS Is Coming For Crypto Tax Evaders

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    The IRS is fulfilling its promise to crack down on those who have neglected to pay taxes on cryptocurrency earnings, as demonstrated by recently imposed prison sentences, enforcement initiatives and meetings with international counterparts — suggesting a few key takeaways for taxpayer compliance, say attorneys at BakerHostetler.

  • 5 Reasons Associates Shouldn't Take A Job Just For Money

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    As a number of BigLaw firms increase salary scales for early-career attorneys, law students and lateral associates considering new job offers should weigh several key factors that may matter more than financial compensation, say Albert Tawil at Lateral Hub and Ruvin Levavi at Power Forward.

  • The Pop Culture Docket: Judge Djerassi On Super Bowl 52

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    Philadelphia Court of Common Pleas Judge Ramy Djerassi discusses how Super Bowl 52, in which the Philadelphia Eagles prevailed over the New England Patriots, provides an apt metaphor for alternative dispute resolution processes in commercial business cases.

  • Employee Experience Strategy Can Boost Law Firm Success

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    Amid continuing business uncertainty, law firms should consider adopting a holistic employee experience strategy — prioritizing consistency, targeting signature moments and leveraging measurement tools — to maximize productivity and profitability, says Haley Revel at Calibrate Consulting.

  • 6 Practice Pointers For Pro Bono Immigration Practice

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    An attorney taking on their first pro bono immigration matter may find the law and procedures beguiling, but understanding key deadlines, the significance of individual immigration judges' rules and specialized aspects of the practice can help avoid common missteps, says Steven Malm at Haynes Boone.

  • Lessons From Country Singer's Personal Service Saga

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    Recent reports that country singer Luke Combs won a judgment against a Florida woman who didn’t receive notice of the counterfeit suit against her should serve as a reminder for attorneys on best practices for effectuating service by electronic means, say attorneys at Jenner & Block.

  • 7 E-Discovery Predictions For 2024 And Beyond

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    The legal and technical issues of e-discovery now affect virtually every lawsuit, and in the year to come, practitioners can expect practices and policies to evolve in a number of ways, from the expanded use of relevancy redactions to mandated information security provisions in protective orders, say attorneys at Littler.

  • 5 Litigation Funding Trends To Note In 2024

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    Over the next year and beyond, litigation funding will continue to evolve in ways that affect attorneys and the larger litigation landscape, from the growth of a secondary market for funded claims, to rising interest rates restricting the availability of capital, says Jeffery Lula at GLS Capital.

  • 4 Legal Ethics Considerations For The New Year

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    As attorneys and clients reset for a new year, now is a good time to take a step back and review some core ethical issues that attorneys should keep front of mind in 2024, including approaching generative artificial intelligence with caution and care, and avoiding pitfalls in outside counsel guidelines, say attorneys at HWG.

  • What The Law Firm Of The Future Will Look Like

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    As the legal landscape shifts, it’s become increasingly clear that the BigLaw business model must adapt in four key ways to remain viable, from fostering workplace flexibility to embracing technology, say Kevin Henderson and Eric Pacifici at SMB Law Group.

  • 4 PR Pointers When Your Case Is In The News

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    Media coverage of new lawsuits exploded last year, demonstrating why defense attorneys should devise a public relations plan that complements their legal strategy, incorporating several objectives to balance ethical obligations and advocacy, say Nathan Burchfiel at Pinkston and Ryan June at Castañeda + Heidelman.

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