International
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January 15, 2025
IRS Mulling Widened Early Application Of Offshore Profit Regs
The Internal Revenue Service is considering expanding the early application option for proposed regulations designed to help U.S. multinational corporations properly account for previously taxed earnings and profits, an agency official said Wednesday.
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January 15, 2025
Chile Must Increase Tax Revenue To Cut Into Debt, OECD Says
With Chile's tax revenues making up just 21% of its gross-domestic product, the country needs to boost its revenue through broad changes to its tax regime if it hopes to keep up with rising spending needs, the Organization for Economic Cooperation and Development said Wednesday.
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January 15, 2025
30 Countries' Minimum Taxes Pass First Review, OECD Says
Policies in about 30 countries passed an initial review for compliance with the 15% global minimum tax system, the first batch to reach that milestone, the Organization for Economic Cooperation and Development said Wednesday.
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January 15, 2025
Netherlands Considering Long-Haul Flight Tax Increase
The Netherlands government is looking for feedback on a plan to replace its flat aviation tax with one that is distance-dependent in hopes of boosting revenue from the tax while encouraging more climate-friendly behaviors, the country's finance ministry said Wednesday.
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January 14, 2025
KPMG, Biz Groups, NY Tax Bar Urge Reg Fixes To Corp. AMT
Energy company and life insurance groups have proposed industry-specific adjustments to the U.S. corporate alternative minimum tax regulations, while the New York State Bar Association and KPMG advocate for simpler accounting methods to assess compliance, according to comment letters to the U.S. Treasury Department.
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January 14, 2025
Orrick Adds Paris Tax Partner From Latham
Orrick Herrington & Sutcliffe LLP added a former counsel at Latham & Watkins LLP as a partner in its Paris office, where she'll advise clients on the tax aspects of French and international transactions, the firm said.
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January 14, 2025
Spain Plans 100% Tax On Foreign-Owned Homes
The Spanish government plans to introduce a 100% tax on foreign-owned homes and stricter rules for holiday rentals to tourists, Prime Minister Pedro Sánchez said.
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January 14, 2025
Trump Announces Plans To Create 'External Revenue Service'
President-elect Donald Trump said Tuesday that he planned to create an "External Revenue Service" that would collect tariffs and revenue from foreign countries.
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January 13, 2025
IRS Puts Out Spinoff Rules, Multiyear Reporting Regime
The Internal Revenue Service released proposed regulations Monday for a narrow set of corporate separation transactions, known as spinoffs, that the agency will approve as tax-free ahead of time, alongside guidance detailing multiyear reporting requirements for those deals.
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January 13, 2025
PepsiCo Created Shell Co. To Avoid Taxes, Ill. Court Says
PepsiCo operated a shell company as part of a scheme that resulted in its Illinois income tax bill for its Frito-Lay unit being deficient nearly $10.9 million, a state circuit court ruled.
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January 13, 2025
AGs, Lobbyists Ask Justices To Keep Shell Co. Law Blocked
The U.S. Supreme Court should deny the federal government's emergency application to stay a Texas district court's injunction on a law aimed at cracking down on crimes committed with shell companies, according to numerous state attorneys general and interest groups and a handful of small businesses.
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January 13, 2025
Tax Firm Asks Court To Ax Final IRS Microcaptive Rules
A global tax services provider asked a Texas federal court to vacate finalized tax rules requiring the reporting of certain transactions involving captive insurance companies deemed as potentially abusive, arguing the guidance goes beyond the agency's authority.
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January 13, 2025
Sen. Warren To Grill Treasury Pick On Trump's Tax Agenda
Sen. Elizabeth Warren, D-Mass., plans to ask Treasury secretary nominee Scott Bessent at his confirmation hearing in front of the Senate Finance Committee on Thursday about President-elect Donald Trump's tax agenda and plans for the Internal Revenue Service, according to a letter she sent the nominee.
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January 13, 2025
The Tax Angle: GOP Lawmakers Grapple With TCJA Renewal
From a look at Congress setting parameters for consideration of legislation to renew the GOP's 2017 tax overhaul law to other upcoming tax action in the House and Senate, here's a peek into a reporter's notebook on a few of the week's developing tax stories.
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January 13, 2025
Norway Seeking Comments On Shareholder Register Plans
The Norway Tax Administration is looking for public comments on plans to introduce a shareholder register that it said would provide authorities with important ownership information, laying out four options for consideration but highlighting its preferred one, it said Monday.
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January 13, 2025
Pillar 2's Effect May Vary Based On Biz Function, Report Says
The global minimum tax deal known as Pillar Two may have a minimal effect on where multinational corporations carry out routine business functions, but companies could eventually change where they perform other operations, according to an OECD paper released Monday.
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January 13, 2025
Still No Unanimous Path Forward On Amount B, OECD Says
The Organization for Economic Cooperation and Development has still not found a path to an agreement on Pillar One's Amount B, which is designed to streamline the pricing of certain baseline marketing and distribution activities, with conversations being held up by possible "inappropriate outcomes," the OECD said Monday.
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January 13, 2025
Tax Hikes Hit Business Confidence, UK Industry Chair Says
The Labour government's decision to raise payroll taxes on employers in last year's budget has hurt business confidence, the chair of an influential British industry group said Monday.
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January 10, 2025
Treasury Finalizes Rules For Disregarded Foreign Payments
The U.S. Treasury Department issued final regulations Friday that are designed to prevent companies from receiving foreign payments in a way that allows them to reduce their overseas taxes without a corresponding increase in U.S. taxable income.
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January 10, 2025
Ga. Law Firm Latest To Fight Corporate Transparency Act
A federal law designed to combat money laundering violates the U.S. Constitution by forcing lawyers to disregard attorney-client privilege, a Georgia lawyer told a federal court, joining a chorus seeking legal action to stop the law.
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January 10, 2025
IRS Finalizes Regulations For Taxing Gifts From Expats
The Internal Revenue Service issued final regulations and guidance Friday for a 2008 tax on gifts and bequests made by current or former U.S. citizens living abroad to U.S. citizens or residents, including through foreign trusts.
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January 10, 2025
IRS OKs New Test For Classifying Digital, Cloud Transactions
Transactions involving digital content and cloud computing will be classified using a new predominant character test, according to final rules issued Friday by the Internal Revenue Service and the U.S. Department of the Treasury.
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January 10, 2025
Taxation With Representation: Kirkland, Davis Polk, Wachtell
In this week's Taxation With Representation, Constellation acquires Calpine, Cintas seeks a deal with UniFirst Corp., Stryker Corp. acquires Inari Medical Inc., and Paychex Inc. buys Paycor.
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January 10, 2025
Group Busted For Dodging $3.6M In Corp. Tax, Poland Says
Poland's tax authority said Friday that it had identified an organized crime group that used several companies as fronts to make transactions that avoided 15 million złoty ($3.6 million) in corporate tax.
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January 10, 2025
Senate Finance Panel To Vet Treasury Nominee Thursday
The Senate Finance Committee will hold a hearing Thursday to consider the nomination of Scott Bessent to serve as the new U.S. Treasury secretary under the incoming administration, Sen. Mike Crapo, R-Idaho, said Friday.
Expert Analysis
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Reimagining Law Firm Culture To Break The Cycle Of Burnout
While attorney burnout remains a perennial issue in the legal profession, shifting post-pandemic expectations mean that law firms must adapt their office cultures to retain talent, say Kevin Henderson and Eric Pacifici at SMB Law Group.
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Cayman Islands Off AML Risk Lists, Signaling Robust Controls
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.
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The Legal Industry Needs A Cybersecurity Paradigm Shift
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.
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As Promised, IRS Is Coming For Crypto Tax Evaders
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.
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5 Reasons Associates Shouldn't Take A Job Just For Money
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.
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The Pop Culture Docket: Judge Djerassi On Super Bowl 52
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.
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Employee Experience Strategy Can Boost Law Firm Success
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.
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6 Practice Pointers For Pro Bono Immigration Practice
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.
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Lessons From Country Singer's Personal Service Saga
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.
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7 E-Discovery Predictions For 2024 And Beyond
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.
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5 Litigation Funding Trends To Note In 2024
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.
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4 Legal Ethics Considerations For The New Year
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.
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What The Law Firm Of The Future Will Look Like
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.