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International

October 10, 2024
UK Exit Taxes OK When Paid Over Time, Upper Tribunal Says

An exit tax on U.K. trusts leaving the country pre-Brexit interfered with their European Union right to free movement of capital, but is brought into compliance if trusts can pay the tax over at least a five-year period, the Upper Tribunal ruled.
October 10, 2024
Switzerland Reports Info Exchanges With 108 Jurisdictions

Switzerland's Federal Tax Administration has exchanged information on roughly 3.7 million financial accounts with 108 jurisdictions so far in 2024, the government said Thursday.
October 10, 2024
Ireland's Finance Bill Sets Out Foreign Dividend Exemption

The Irish government set out its plans for a new participation tax exemption for foreign dividends as part of a finance bill published Thursday.
October 10, 2024
Algeria Joins OECD Tax Transparency Treaty

Algeria formally joined the Organization for Economic Cooperation and Development's global tax transparency agreement on combating tax avoidance and evasion by multinational corporations, the OECD announced Thursday.
October 09, 2024
Australia Floats Debt Reduction Creation Rules Guidance

The Australian Taxation Office published draft guidance Wednesday for the country's new debt deduction creation rules, including the planned compliance approach and a framework for risk assessment.
October 09, 2024
European Parliament Backs Brazil's G20 Wealth Tax Plan

A majority of the European Parliament supports a 2% minimum tax on billionaires presented by Brazil at the Group of 20 nations meeting, asking the European Union to pursue the topic at the group's November summit, according to joint statements by members of Parliament on Wednesday.
October 09, 2024
Swiss Council Rejects Funding Pensions With Transaction Tax

Switzerland should not use the revenue generated by its two taxes on financial market transactions to fund the country's pension fund, nor should it create new ones for that purpose, the Swiss Federal Council said Wednesday.
October 09, 2024
OECD Should Clarify Pillar 2 Safe Harbor Timing, CPAs Say

The OECD should clarify when exactly multinational corporations need to determine whether they qualify for a transitional safe harbor under an international minimum tax agreement, the American Institute of Certified Public Accountants recommended in a letter.
October 09, 2024
UK Gov't Greenlights Film Industry Tax Credit

U.K. film companies will be able to gain over 50% tax relief for their films' costs from a tax credit approved Wednesday by the Labour government.
October 09, 2024
3M Tax Ruling Must Fall Post-Chevron, Chamber Tells 8th Circ.

The U.S. Supreme Court's ending of the Chevron doctrine calls for overturning a U.S. Tax Court ruling that let the IRS allocate $24 million of income to multinational conglomerate 3M from a Brazilian affiliate, the U.S. Chamber of Commerce told the Eighth Circuit on Wednesday.
October 09, 2024
Starmer Refuses To Rule Out Payroll Tax Hike

Prime Minister Keir Starmer didn't rule out raising employers' National Insurance contributions, a payroll tax used to fund healthcare and state pensions, during Wednesday's question time.
October 09, 2024
Election Uncertainty Hampers Companies' Tax Planning

With the November election approaching, businesses are bracing for the potential impact of two very different sets of tax policies, with the resulting uncertainty making long-term tax planning increasingly difficult.
October 09, 2024
Australia Seeking Large Cos.'s Tax Execs For Advisory Board

The Australian Taxation Office is looking for executives in charge of taxes for the country's largest businesses to join an advisory group focused on improving the Australian taxation systems, the ATO said Wednesday.
October 09, 2024
Final Treasury Rules Shut Off Inclusion For Repatriated IP

The U.S. Treasury Department adopted final rules Wednesday that shut off an annual income inclusion associated with intangibles for companies in certain situations that have transferred intellectual property back to the U.S. from overseas.
October 09, 2024
Gov't Warned Over National Insurance Levy On Pensions

About half of U.K. employers would scale back the amount they pay into staff pensions to regulatory minimums if a new tax was applied to contributions, according to a survey by a trade group published Wednesday.
October 08, 2024
Germany May Offer Tax Break For 'E-Fuel' Cars, Ministry Says

The German government will consider a motor vehicle tax exemption for cars running only on fuels manufactured with renewable energy, known as e-fuels-only vehicles, the German Ministry of Finance announced Tuesday.
October 08, 2024
China Pushes Back On Turkish EV Tariffs, Targets EU Brandy

China said Tuesday that it is appealing to the World Trade Organization to halt Turkish tariffs on electric and hybrid vehicles made in the country, and it announced a temporary anti-dumping measure on European Union brandy that follows the bloc's own EV tariffs.
October 08, 2024
Tire Seller Counts As Importer, Owes $2M Tax, 5th Circ. Says

A Houston truck sales company owes nearly $2 million in excise taxes because it qualifies as the importer of tires that it bought from a Chinese manufacturer, the Fifth Circuit ruled Tuesday in overturning the decision of a Texas federal judge.
October 08, 2024
Loss Rule Carveouts Raise Challenges In Pillar 2, Official Says

An IRS official flagged administrability concerns Tuesday with potential safe harbors that would, in some cases, carve out an international minimum tax agreement from interacting with long-standing domestic rules aimed at preventing companies from using the same economic loss twice.
October 08, 2024
Australia Makes Additional Changes To Tax Pro Conduct Code

After industry pushback, delays and further tweaks, Australia's minister for financial services signed into law Tuesday further amendments to the nation's tax professional code of conduct as part of the country's reaction to the PwC document leak scandal.
October 08, 2024
Eversheds Recruits Tax Disputes Partner From RPC

Eversheds Sutherland announced it has added a regulatory and tax disputes partner to its London office from Reynolds Porter Chamberlain LLP.
October 08, 2024
UK Gov't Should Impose Exit Tax, Economists Say

The U.K. should follow the example of Australia and Canada and enact a tax on business owners leaving the country, according to a report published Tuesday by a research group.
October 08, 2024
EU Removes Antigua And Barbuda From Tax Blacklist

The Council of the European Union removed Antigua and Barbuda from its blacklist of noncooperation jurisdictions on global tax standards, the EU's Economic and Financial Affairs Council announced Tuesday.
October 08, 2024
Gov't Urged To Commit To Pension Tax 'Lock' In Budget

The government must commit to a long-term pact on pension tax policy, experts said, warning that prolonged uncertainty is damaging consumer confidence.
October 07, 2024
Justices Won't Hear Man's FBAR Constitutionality Challenge

The U.S. Supreme Court let stand Monday a Seventh Circuit decision dismissing a man's challenge to the constitutionality of the Bank Secrecy Act's requirement to report his foreign bank accounts, effectively ending the man's claim that the filings were an invasion of privacy.

Expert Analysis

How Attorneys Can Be More Efficient This Holiday Season

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

Excerpt from Practical Guidance

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

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

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

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

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

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

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

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.
Preparing Law Students For A New, AI-Assisted Legal World

As artificial intelligence rapidly transforms the legal landscape, law schools must integrate technology and curricula that address AI’s innate challenges — from ethics to data security — to help students stay ahead of the curve, say Daniel Garrie at Law & Forensics, Ryan Abbott at JAMS and Karen Silverman at Cantellus Group.
General Counsel Need Data Literacy To Keep Up With AI

With the rise of accessible and powerful generative artificial intelligence solutions, it is imperative for general counsel to understand the use and application of data for myriad important activities, from evaluating the e-discovery process to monitoring compliance analytics and more, says Colin Levy at Malbek.
Navigating Discovery Of Generative AI Information

As generative artificial intelligence tools become increasingly ubiquitous, companies must make sure to preserve generative AI data when there is reasonable expectation of litigation, and to include transcripts in litigation hold notices, as they may be relevant to discovery requests, say Nick Peterson and Corey Hauser at Wiley.
Finding Focus: Strategies For Attorneys With ADHD

Given the prevalence of ADHD among attorneys, it is imperative that the legal community gain a better understanding of how ADHD affects well-being, and that resources and strategies exist for attorneys with this disability to manage their symptoms and achieve success, say Casey Dixon at Dixon Life Coaching and Krista Larson at Stinson.