International

  • August 20, 2024

    Temple Law Prof, Kostelanetz Atty To Lead ABA Tax Section

    A longtime professor at the Temple University Beasley School of Law and a seasoned tax controversy partner at Kostelanetz LLP will together helm the American Bar Association Section of Taxation for the 2025-2026 term, the firm announced Tuesday.

  • August 20, 2024

    IRS Tax-Exempt Compliance Unit Work Too Slow, TIGTA Says

    A decision to expand the scope of checks made by the Internal Revenue Service's Tax-Exempt Compliance Unit resulted in cases taking three times as long to close and a decrease in taxpayers reached by more than half, the Treasury Inspector General for Tax Administration said Tuesday.

  • August 20, 2024

    Allen Matkins Tax Group Leader Jumps To Covington In LA

    Covington & Burling LLP has added to its Los Angeles office a partner with more than 20 years of experience who most recently led Allen Matkins Leck Gamble Mallory & Natsis LLP's tax group, describing the new hire as "one of the country's leading authorities on partnership tax."

  • August 20, 2024

    Trade Group Urges Consistency In Pillar 2 Reporting Standard

    The Organization for Economic Cooperation and Development should focus on making sure there is a standardized approach to acquiring the cross-jurisdiction information required for Pillar Two global minimum tax returns while also minimizing the compliance burden, the National Foreign Trade Council said Tuesday.

  • August 20, 2024

    A Deep Dive Into Law360 Pulse's 2024 Women In Law Report

    The legal industry continues to see incremental gains for female lawyers in private practice in the U.S., according to a Law360 Pulse analysis, with women now representing 40.6% of all attorneys and 51% of all associates.

  • August 20, 2024

    These Firms Have The Most Women In Equity Partnerships

    The legal industry still has a long way to go before it can achieve gender parity at its upper levels. But these law firms are performing better than others in breaking the proverbial glass ceiling that prevents women from attaining leadership roles.

  • August 20, 2024

    Aussie Capital Gains Tax Edit May Hit Green Energy, Pros Say

    An Australian proposal to generally broaden the scope of the country's foreign resident capital gains tax regime could end up restricting foreign investment in the renewable energy sector, a group representing accounting professionals in the country said Tuesday.

  • August 20, 2024

    IRS Proposes Update To Qualified Domestic Trust Regs

    The Internal Revenue Service proposed regulations Tuesday that would update federal estate tax rules for estates of decedents passing property to or for the benefit of a noncitizen spouse in a domestic trust in cases where the executor has made an election to be a qualified domestic trust.

  • August 20, 2024

    EU Tweaks Anti-Subsidy Duties On Chinese EVs

    The European Commission said Tuesday that it is adjusting the anti-subsidy duties that it will charge Chinese exporters of electric vehicles, a move that it had provisionally announced at the beginning of July.

  • August 19, 2024

    Eaton Ordered To Give Int'l Employee Records To IRS

    Eaton Corp. must disclose employment records for some European workers in its transfer pricing dispute with the U.S. government because public interest in curtailing tax avoidance outweighs the interest in protecting the workers' privacy, an Ohio federal judge ruled Monday.

  • August 19, 2024

    Danish Gov't Wants Evidence Excluded In $2B Tax Fraud Case

    A New York federal court should exclude some evidence presented by U.S. pension plans accused in what the Danish tax agency is calling a $2.1 billion tax fraud scheme, the agency said.

  • August 19, 2024

    Chile Senate Panel OKs Bank Secrecy, Whistleblower Plans

    Chile's Senate Finance Committee approved changes to a larger tax compliance bill's proposals for lifting the country's bank secrecy laws in certain situations and for creating an anonymous whistleblower process for reporting tax crimes.

  • August 19, 2024

    Treasury Floats Timing Shift For Foreign Currency Accounting

    The U.S. Treasury Department proposed regulations Monday that would adjust the timing for when companies could opt to use the so-called mark-to-market accounting method for gains or losses that arise from foreign currency transactions.

  • August 19, 2024

    Swedish Advisory Body Considering Pillar 2 Updates

    A Swedish advisory council is considering a proposal that would add administrative and other clarifications to the country's implementation of the Organization for Economic Cooperation and Development's global minimum tax on large multinational corporations.

  • August 16, 2024

    Kyocera Says It Doesn't Need Records For R&D Credits

    Multinational electronics maker Kyocera said Friday that it wasn't required to keep any specific paperwork to back up its claim to research tax credits, contrary to the U.S. government's claims, according to a filing in South Carolina federal court.

  • August 16, 2024

    UK Dependency Considering Global Minimum Tax Bills

    Jersey is considering draft legislation that would implement the Organization for Economic Cooperation and Development's 15% minimum tax on multinational entities making over €750 million ($828 million) annually, in line with a declaration from it and other U.K. crown dependencies to do so starting next year.

  • August 16, 2024

    Democratic Gov't Control Could Bolster US' Pillar 2 Plans

    Vice President Kamala Harris and congressional Democrats would likely double down on plans to align the U.S. tax code with the global minimum tax designed by the Organization for Economic Cooperation and Development if they win total control of the federal government in the November elections.

  • August 16, 2024

    UN Votes For Global Services As First Priority Under Tax Pact

    The United Nations voted Friday to make taxation of cross-border services the most prioritized topic for a legally binding agreement to be finalized by late 2027 alongside the organization's framework convention on international tax cooperation.

  • August 16, 2024

    IRS To Let Private Cos. Into Real-Time Biz Audit Program

    The Internal Revenue Service is opening its compliance assurance process real-time audit program to privately held C corporations, including foreign-owned ones, for 2025, the agency announced.

  • August 16, 2024

    Taxation With Representation: Cleary, Kirkland, Skadden

    In this week's Taxation with Representation, Mars Inc. sets a 2024 record with its $36 billion acquisition of Kellanova, Carlyle inks a $3.8 billion purchase with Baxter International Inc., and Performance Food Group Co. agrees to a $2.1 billion cash deal with Cheney Bros. Inc.

  • August 15, 2024

    Doctor Wants Contempt Fine Dropped In Foreign Asset Case

    A doctor who incurred $1.1 million in liabilities for failing to report his foreign bank accounts is asking a Michigan federal court to waive his $20,000 civil contempt fine because the court restricted his only financial assets to paying the liabilities.

  • August 15, 2024

    Tax Pros Navigate Chaos, Rewards In Climate Law's 2nd Year

    Energy tax attorneys have been knee-deep in project finance deals for the past year since the Inflation Reduction Act of 2022 triggered a flurry of clean energy investments, but the work, they say, has been fulfilling as part of broader efforts to save the environment.

  • August 15, 2024

    Taxes Could Be Key To Cutting Crypto Emissions, IMF Says

    The growing environmental impact of crypto-asset mining and related data centers could be mitigated with tax measures aimed directly at such facilities, the International Monetary Fund said Thursday.

  • August 15, 2024

    Germany Seeks Input On Tightened Transfer Pricing Rules

    Germany is poised to make multinational corporations responsible for showing the economic necessity of intra-group, cross-border debt relationships when they deduct expenses for financing with borrowed capital, according to a consultation by the federal government.

  • August 15, 2024

    Finland To Have EU's 2nd-Highest VAT Rate Starting Sept. 1

    Finland's general value-added tax rate will jump to 25.5% from 24% starting Sept. 1, the country's tax agency said Thursday, putting it behind only Hungary for the highest VAT rate in the European Union.

Expert Analysis

  • Unpacking The Proposed Production Tax Credit Regulations

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    Recently proposed tax regulations for claiming the U.S. clean-energy manufacturers' production credit under Internal Revenue Code Section 45X are less stringent than many had feared but fail to define a fundamental eligibility requirement, say Casey August and Jared Sanders at Morgan Lewis.

  • 10 Considerations For Litigating A New York Tax Case

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    While some of New York’s recently adopted corporate tax regulations are likely to face legal challenges, aggrieved taxpayers should answer certain questions before deciding to embark on the tax litigation process, say Cyavash Ahmadi and Jeffrey Friedman at Eversheds Sutherland.

  • Law Firm Strategies For Successfully Navigating 2024 Trends

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    Though law firms face the dual challenge of external and internal pressures as they enter 2024, firms willing to pivot will be able to stand out by adapting to stakeholder needs and reimagining their infrastructure, says Shireen Hilal at Maior Consultants.

  • Attorneys' Busiest Times Can Be Business Opportunities

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    Attorneys who resolve to grow their revenue and client base in 2024 should be careful not to abandon their goals when they get too busy with client work, because these periods of zero bandwidth can actually be a catalyst for future growth, says Amy Drysdale at Alchemy Consulting.

  • How Attorneys Can Be More Efficient This Holiday Season

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    Attorneys should consider a few key tips to speed up their work during the holidays so they can join the festivities — from streamlining the document review process to creating similar folder structures, says Bennett Rawicki at Hilgers Graben.

  • 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.

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