International
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July 18, 2024
Treasury Starting To Address Amount B, Official Says
The U.S. Department of the Treasury is just starting to decide how to handle a transfer pricing regime under a prong of the OECD-led global tax overhaul, a Treasury official said Thursday.
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July 18, 2024
Tax Pros Say Gov'ts Stretching 'Realistic Alternative' Analysis
Tax authorities including the Internal Revenue Service are overstepping in their use of "realistic alternative" arguments, substituting their own judgment for that of businesses, transfer pricing specialists said Thursday.
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July 18, 2024
Ex-Venable Trusts And Estates Partner Joins Stradling In LA
Stradling Yocca Carlson & Rauth PC announced that it launched a trusts and estates practice with the hiring of an experienced Los Angeles-based partner from Venable LLP.
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July 18, 2024
Most Top US Cos. To Report Tax Under Aussie Bill, Study Says
Australia's Senate is expected to consider adoption next month of the world's most extensive public country-by-country reporting rules, which would require 51% of large U.S. multinational corporations to disclose tax arrangements retroactively from July 1, according to a study published Thursday.
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July 18, 2024
UK Brothers Sentenced For £3.2M Offshore Tax Evasion
A pair of brothers each received suspended two-year prison sentences for charges related to a tax evasion scheme where they hid more than £3.2 million ($4.1 million) using companies in Gibraltar and the British Virgin Islands, HM Revenue & Customs said Thursday.
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July 18, 2024
Rising Star: Latham's Eric Kamerman
Eric Kamerman of Latham & Watkins LLP in recent years handled the tax aspects of several multibillion-dollar acquisitions of powerhouses in British soccer and American fashion, earning him recognition as one of the tax attorneys under age 40 honored by Law360 as Rising Stars.
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July 18, 2024
GE Can't Claim Credit For £189M In Double Tax, Court Says
A U.K.-registered subsidiary of General Electric does not qualify for at least £189 million ($245 million) in double tax relief under a U.S.-U.K. treaty because it lacks a U.S. presence akin to a domicile, a London appellate court ruled.
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July 17, 2024
Much Of Pillar 1 Treaty Agreed On, OECD Official Says
Agreement has been reached on the bulk of a multilateral pact to implement new taxing rights that are part of a revamp of the international tax system and on expansions to a part of the taxing rights plan, an OECD official said Wednesday.
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July 17, 2024
Gov't Views On OECD Risk Guidance Vary, Economists Say
In allocating risk among different components of a business for transfer pricing purposes, analysts need to consider governments' varying interpretations of guidance from the Organization for Economic Cooperation and Development, a panel of economists said Wednesday.
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July 17, 2024
Aussie Gov't Seeks Tighter Promoter Penalties After PwC Leak
Australia is poised to penalize a wider range of advisers who promote tax schemes to multinational corporations and beef up its Tax Practitioners Board's ability to investigate cases after it uncovered PwC sharing confidential draft laws with clients, according to a consultation that began Wednesday.
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July 17, 2024
Germany Sends Budget With €23B In Tax Cuts To Parliament
Germany's executive body approved a legislative package Wednesday that includes €23 billion ($25.2 billion) in tax cuts for citizens and companies across the next two years, sending it to the country's parliament for consideration.
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July 17, 2024
Disney To Join IBM's Bid To Bring NY Tax Fight To Justices
The Walt Disney Co. joined IBM in asking the U.S. Supreme Court for more time to file a petition for review of a New York high court decision that upheld tax on royalties received from foreign affiliates.
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July 17, 2024
Connell Foley Adds Wilson Elser Tax Pro In Group Upgrade
Connell Foley LLP strengthened its tax and estate team this week with the promotion of several attorneys up to partner and the addition of a mergers and acquisitions and corporate restructuring tax expert previously of counsel at Wilson Elser Moskowitz Edelman & Dicker LLP.
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July 17, 2024
2 Arrested In €7.6M Italian VAT Fraud Scheme
Financial police in Italy arrested who authorities said were two main suspects in a scheme involving sales of luxury cars that evaded €7.6 million ($8.3 million) in value-added taxes, the European Public Prosecutor's Office said Wednesday.
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July 17, 2024
IRS Plans August Hearing On Stock Buyback Tax Rules
The Internal Revenue Service will hold a public hearing Aug. 27 on proposed regulations governing a new excise tax on repurchases of corporate stock, the agency said Wednesday.
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July 17, 2024
Rising Star: Cravath's Kiran Sheffrin
Kiran Sheffrin of Cravath Swaine & Moore LLP has advised companies from Anheuser-Busch InBev to Valvoline on multibillion-dollar deals, including a $50 billion combination resulting in the formation of pharmaceutical giant Viatris, earning her a spot among the tax law practitioners under age 40 honored by Law360 as Rising Stars.
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July 17, 2024
Woman Can't Escape Suit Over Partner's $1.1M FBAR Debt
A woman whose late romantic partner owed $1.1 million in reporting penalties on hidden financial accounts in France and Switzerland can't stop the government from pursuing a suit against her for half the value of her home, a New York federal court ruled.
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July 17, 2024
Baker McKenzie Adds EY Partner To Mexico City Office
Baker McKenzie has appointed a new partner from EY Mexico to its North American tax practice group in Mexico City.
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July 17, 2024
Estonia Expects Solutions From EU Chair On VAT Law
Estonia said Wednesday that it expects "constructive solutions" from the current chair of European Union meetings regarding changes to value-added tax law, which Estonia blocked during meetings of EU finance ministers in May and June.
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July 17, 2024
Labour Gov't To Make Fiscal Rules Law, Empower OBR
The new Labour government will legislate to write into law the Treasury's long-held fiscal rules and grant new powers to the Office for Budget Responsibility to scrutinize policy, according to plans confirmed in the King's Speech on Wednesday.
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July 16, 2024
Intracompany Prices Should Reflect Acquired IP, Panelists Say
When one company buys another for its intellectual property, the subsequent pricing of that asset between the now-related entities should reflect the value of what was acquired, transfer pricing specialists said Tuesday at a conference in Washington, D.C.
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July 16, 2024
More Geographic Adjustments 'On The Table' For Amount B
Countries' ability to make further adjustments for geographic differences in the streamlined transfer pricing approach known as Amount B — part of the OECD's plan for reallocating taxing rights among jurisdictions — is "still on the table," an official from the organization said Tuesday.
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July 16, 2024
Va. Tax Head Nixes Assessment On Man For Work In India
A Virginia man was wrongly assessed income tax for services he conducted while living in India, the state's tax commissioner said in a letter ruling published Tuesday.
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July 16, 2024
Tax Transparency Neglected In Latin America, Ex-Officials Say
The international tax transparency system is failing to produce results for Latin American governments, whose scant information requests are too often met with resistance and whose prosecutions generally lack a cross-cutting approach to tax, former officials from the region said Tuesday.
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July 16, 2024
DC Circ. Upholds Dismissal Of Tax Whistleblower Award Case
The D.C. Circuit upheld Tuesday the U.S. Tax Court's dismissal of a Mississippi man's case seeking review of the denial of his whistleblower claim for 30% of the revenue collected by an Internal Revenue Service offshore voluntary disclosure program.
Top International Tax Cases To Watch In The 2nd Half Of 2024
Tax attorneys will be tracking several high-stakes cases in the second half of 2024 that could define the bounds of the IRS' ability to craft regulations or lodge direct challenges aimed at what it sees as the tax avoidance maneuvers of multinational corporations. Here, Law360 looks at key international tax cases to follow during the rest of the year.
Von Der Leyen Confirmed For New Term Leading EU Executive
The European Parliament reelected Ursula von der Leyen to a second five-year term as the head of the European Commission on Thursday after a speech in which she advocated cutting red tape for businesses.
Treasury Finalizes Rules To Target 'Killer B' Transactions
The U.S. Treasury Department published final regulations Wednesday aimed at so-called Killer B transactions, which involve certain corporate reorganizations with at least one foreign affiliate that ultimately allow U.S. companies to avoid domestic taxes.
Featured Stories
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Top International Tax Cases To Watch In The 2nd Half Of 2024
Tax attorneys will be tracking several high-stakes cases in the second half of 2024 that could define the bounds of the IRS' ability to craft regulations or lodge direct challenges aimed at what it sees as the tax avoidance maneuvers of multinational corporations. Here, Law360 looks at key international tax cases to follow during the rest of the year.
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3 Tax Reg Groups That May Be Shaky After High Court Rulings
The U.S. Supreme Court issued two rulings that, when combined, open up long-standing federal regulations to challenges without judicial deference to agencies — a pairing that could weaken several categories of tax rules, including guidance issued under the 2017 federal overhaul. Here, Law360 looks at three batches of tax regulations that may be vulnerable in the aftermath of the high court's decisions.
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French Left's Tax Pledges May Go Unfulfilled
The tax policy pledges put forward by the leftist bloc of parties that won the most seats in France's legislative election may not be fulfilled given the bloc's failure to win an outright majority.
Expert Analysis
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Now More Than Ever, Lawyers Must Exhibit Professionalism
As society becomes increasingly fractured and workplace incivility is on the rise, attorneys must champion professionalism and lead by example, demonstrating how lawyers can respectfully disagree without being disagreeable, says Edward Casmere at Norton Rose.
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Reading Between The Lines Of Justices' Moore Ruling
The U.S. Supreme Court's recent Moore v. U.S. decision, that the Internal Revenue Code Section 965 did not violate the 16th Amendment, was narrowly tailored to minimally disrupt existing tax regimes, but the justices' various opinions leave the door open to future tax challenges and provide clues for what the battles may look like, say Caroline Ngo and Le Chen at McDermott.
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A Midyear Forecast: Tailwinds Expected For Atty Hourly Rates
Hourly rates for partners, associates and support staff continued to rise in the first half of this year, and this growth shows no signs of slowing for the rest of 2024 and into next year, driven in part by the return of mergers and acquisitions and the widespread adoption of artificial intelligence, says Chuck Chandler at Valeo Partners.
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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.