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International

September 09, 2024
Tax Compliance Costs Keeps EU Firms Small, Report Says

The high cost of tax compliance and the challenges presented by differing regulatory environments encourage European companies to stay small, potentially harming the European Union's competitiveness, according to a report by a former European Central Bank head published on Monday.
September 09, 2024
HMRC Fails To Nab £4B In Small-Biz Tax Evasion, Report Says

HM Revenue & Customs has failed to stop small businesses from dodging more than £4.4 billion ($5.8 billion) in taxes because it lacks a focused strategy to tackle different tax evasion schemes, the U.K.'s National Audit Office reported Monday.
September 06, 2024
Federal Tax Policies To Watch In The Rest Of The Year

As Congress returns to Washington, D.C., after the August recess, proposals including disaster tax relief and an agreement to provide tax treaty-like benefits to Taiwanese residents could be readied to be included in year-end legislation. Here, Law360 examines federal tax policies to watch during the last four months of 2024.
September 06, 2024
FDII Covers Overseas Services For US Gov't, Memo Says

Government contractors that provide services to U.S. operations overseas are allowed to claim the deduction for foreign-derived intangible income, the IRS said in one of two internal memos released Friday that address foreign income issues.
September 06, 2024
Broaden Tax Bases For Cleaner Energy Transition, EU Says

The impact on government revenues from the transition to cleaner energy, including diminishing fossil fuel tax receipts and increased spending on subsidies supporting green technology, necessitates that countries develop broader tax bases, the European Commission said.
September 06, 2024
4 Key Complications 3 Years After Pillar 2

Three years ago, countries around the world outlined an agreed-upon minimum corporate tax system in an eight-page document that couldn't have foreseen the full scope of complications that later emerged during implementation, including frictions with existing tax laws. Here, Law360 looks at four key issues that countries and multinational corporations are grappling with as Pillar Two turns three.
September 06, 2024
China Complains To WTO About Canada EV Surtaxes

China is looking for the World Trade Organization to step in to address proposed Canadian surtaxes on imported Chinese electric vehicles, steel and aluminum, taxes that a spokesperson for China's Ministry of Commerce said Friday violate the organization's rules.
September 06, 2024
Taxation With Representation: Debevoise, Bennett, Orrick

In this week's Taxation With Representation, Verizon reaches a deal to absorb Frontier in a deal worth $20 billion, First Majestic agrees to buy Gatos Silver for $970 million, and Epam Systems inks a $630 million purchase of Neoris.
September 06, 2024
Vialto Partners Member Joins Baker McKenzie As Partner

Baker McKenzie has hired a tax partner in Washington, D.C., from Vialto Partners, a business consulting firm, the firm announced Thursday.
September 06, 2024
EU Should Align Disclosure Standards, Industry Group Says

The European Union should align its forthcoming public tax reporting rules with the same systems in use under the Organization for Economic Cooperation and Development's non-public reporting system, the American Chamber of Commerce in the EU said.
September 05, 2024
Unconstitutionality Of Transparency Act Clear, 11th Circ. Told

A small business group and one of its members have told the Eleventh Circuit that an Alabama federal judge correctly ruled that the Corporate Transparency Act is unconstitutional, so there was no need for them to demonstrate that the law fails to pass constitutional muster.
September 05, 2024
Liberty Global Urges 10th Circ. To Grant $248M Tax Credit

The U.S. Tax Court improperly applied an Internal Revenue Code provision to some of the $2.8 billion gain from Liberty Global's sale of a Japanese entity, the telecommunications company said in urging the Tenth Circuit to overturn the resulting rejection of a $248 million tax credit.
September 05, 2024
Holland & Knight Appoints Former Perkins Coie Tax Partner

Holland & Knight LLP appointed a partner to its Portland, Oregon, office who previously served as a partner in energy tax law for Perkins Coie LLP, the firm announced.
September 05, 2024
Sen. Finance Panel To Hold Hearing On Tax Policy, Avoidance

The Senate Finance Committee will hold a hearing Sept. 12 covering the 2025 tax policy debate and tax avoidance strategies, it announced Thursday.
September 05, 2024
Broad, Low-Rate DST May Placate US, Ex-OECD Chief Tells EU

The European Union might be able to break an impasse with the U.S. in negotiations on taxing the digital economy by proposing a digital services tax with a wide base and a low rate, former OECD tax chief Pascal Saint-Amans told Paolo Gentiloni, the bloc's economics commissioner.
September 05, 2024
UK Extends Startup Investment Tax Incentives Through 2035

Two U.K. tax incentives that encourage private investment in small companies in order to boost innovation and otherwise stimulate economic growth have been extended for 10 years, HM Treasury said.
September 05, 2024
Tax Pros Want Aussie PM To Halt Code Of Conduct Changes

Six groups representing Australian tax professionals and accountants called on the country's prime minister to step in to stop an "unfair" bill updating the code of conduct for tax agent services if discussions with the country's Treasury don't produce what they say are needed changes.
September 04, 2024
IRS' Economic Substance Authority Has Limits, Tax Court Told

The U.S. Tax Court and other federal courts have the authority to conduct an initial analysis of a transaction in cases where the Internal Revenue Service is challenging the economic substance of the transaction, a manufacturers advocacy group said Wednesday in an amicus brief.
September 04, 2024
New Zealand Looking To Nearly Triple Its Tourist Levy

New Zealand's government is planning to increase a levy on tourists to NZ$100 ($62) per visit, nearly tripling the current rate, according to a joint statement from the country's conservation and tourism ministries.
September 04, 2024
Irish Tax Surplus Too Reliant On Few Cos., Watchdog Says

It's dangerous for the Irish government to fund long-term plans with corporate tax windfalls pouring into its coffers for over a decade, as three foreign-owned multinational corporations are providing a growing share, risking volatility in an otherwise healthy economy, a parliamentary watchdog said.
September 04, 2024
Singapore's Annual Corporate Tax Revenue Climbs 26%

Singapore collected SG$80.3 billion ($61.6 billion) in tax revenue in fiscal year 2023-24, a 17% increase over the prior year, thanks in large part to a 25.6% increase in corporate income tax receipts, pushing that total to SG$29 billion, the country's revenue agency said Wednesday.
September 04, 2024
Swiss To Impose Second Portion Of Pillar 2 Starting In 2025

Switzerland will implement the income inclusion rule portion of the OECD's Pillar Two standards to fight tax base erosion and profit shifting starting in 2025, its Federal Council said Wednesday, complementing its establishment of the 15% global minimum corporate income tax this year.
September 03, 2024
11th Circ. Trims $12.6M FBAR Fine In 8th Amendment Split

Some of the $12.6 million in penalties the IRS on imposed a man for willfully failing to report foreign bank accounts were in violation of the Eighth Amendment's bar on excessive fines, the Eleventh Circuit ruled, creating an apparent circuit split.
September 03, 2024
Bahrain Adopting Global Minimum Tax In 2025

Multinational corporations making more than €750 million ($828 million) annually operating in Bahrain will be subject to the OECD's 15% global minimum corporate income tax starting in 2025, the country's tax agency said.
September 03, 2024
UN Tax Rule On Payments Best For Many Gov'ts, Group Says

Developing countries should seek to add the United Nations' version of a minimum tax rule on payments to their bilateral tax treaties and to adopt corresponding laws domestically while approaching the OECD's more restrictive multilateral version with caution, an advocacy group said Tuesday.

Expert Analysis

Law Firm Strategies For Successfully Navigating 2024 Trends

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

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

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.