International
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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August 15, 2024
Aussie Senate Economics Committee OKs 15% Min. Tax Bill
The Australian Senate's Economics Legislation Committee said it supports the passage of a three-bill package that would implement the OECD's 15% global corporate minimum tax on large multinational entities, sending it to the entire Senate for approval.
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August 15, 2024
UK Plastic Packaging Tax Revenue Dipped By 6%
The U.K. collected £268 million ($344 million) from its tax on certain plastic packaging manufactured in or imported into the country in the 2023-2024 fiscal year, down 6% from the £285 million the year prior, HM Revenue & Customs said Thursday.
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August 14, 2024
PwC Owes $11M For Tax Errors, Real Estate Group Says
PwC should pay £8.9 million ($11.4 million) in damages to a real estate group for miscalculating its tax liabilities and mispricing its properties, which prompted several additional assessments and penalties, according to a claim in a London court.
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August 14, 2024
Baker McKenzie Adds Tax Expert To Monterrey Office
Baker McKenzie has added a partner from Turanzas Bravo & Ambrosi to its Monterrey, Mexico, office who brings more than 15 years of experience practicing international trade law with a focus on taxation and customs-related litigation.
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August 14, 2024
Kenya Tax Court Finds Chinese Firm Dodged $7.8M VAT
A Kenyan tax court affirmed an assessment that found a China-based firm used a series of shell companies to dodge over 1 billion Kenyan shillings ($7.8 million) in value-added tax payments, the Kenya Revenue Authority said Wednesday.
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August 14, 2024
Swiss Seeking Input On Delays Of Crypto-Asset Info Exchange
Switzerland's executive body, the Federal Council, is looking for public input on when it should begin automatically exchanging financial information regarding crypto-assets with countries with which it already has set up general automatic exchange of information agreements, its finance ministry said.
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August 14, 2024
EU General Court Jurisdiction Expanded To VAT Cases
The General Court of the European Union will be able to make preliminary rulings in cases involving the EU's common system of value-added taxes starting Oct. 1, following an expansion of the court's jurisdiction.
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August 14, 2024
Pros Lament Lack Of Ownership Clarity In New EU Law
The lack of a clear beneficial ownership definition in new European Union legislation designed to speed up the repayment of withholding taxes represents a missed opportunity — and could cause confusion for investors about whether they are in fact eligible for a refund, tax professionals say.
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August 14, 2024
Other Price Rises Offset German Tampon VAT Cut, Study Says
Germany's reduction in the value-added tax on female sanitary products, such as tampons, has led to higher prices on panty liners, a Munich-based think tank said in a news release Wednesday.
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August 13, 2024
Walz Backed Tax Hikes Funding Plans For Children, Families
As Minnesota's governor, Democrat Tim Walz, now the presumed vice presidential nominee of his party, separated himself from most other governors by signing into law numerous tax increases funding progressive priorities such as a paid family leave plan and the nation's largest child tax credit.
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August 13, 2024
Treasury's Loss Rules Take Broad Approach To Min. Tax Deal
The U.S. Treasury Department recently dashed the hopes of multinational corporations seeking regulations that would have carved out an international minimum tax agreement from interacting with long-standing domestic rules aimed at preventing companies from using the same economic loss twice.
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August 13, 2024
Firm Asks Court To Reconsider $1.5M Freeze In Tax Dispute
A Baltimore law firm that sued the IRS for freezing $1.5 million in its operating account to satisfy a client's tax debts told a Maryland federal court it was "dead wrong" in denying the firm's request to release the money without going to trial.
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August 13, 2024
Developing Countries Defend 3-Year Deadline For UN Tax Pact
Three years is enough time to finish writing a United Nations framework convention on international tax cooperation, Brazil, India, Nigeria and other developing countries said Tuesday in defense of a proposed timeline that was criticized by Canada, the U.S. and France.
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August 13, 2024
Canada Seeking Comments On Global Min. Tax, Capital Gains
Canada's government is seeking comments from the public on a wide range of tax proposals included in its 2024 budget, including the introduction of the OECD's global minimum tax on large multinational corporations and adjustments to the country's taxation of capital gains, the government announced.
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August 13, 2024
HMRC Collected £384M In Soccer Tax Crackdowns, Firm Says
HM Revenue & Customs has recovered £384 million ($494 million) in taxes through investigations into soccer clubs, players and agents over the past five years, including £67.5 million in the past year alone, a U.K. accounting firm said.
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August 13, 2024
Finland Seeking Input On Global Min. Tax Changes
Finland's Ministry of Finance is seeking input on proposed changes to the country's implementation of the OECD's 15% global minimum tax on large multinational corporations, including clarifications, though it said the changes wouldn't impact the core principles of the law.
Expert Analysis
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A Look At New IRS Rules For Domestically Controlled REITs
The Internal Revenue Services' finalized Treasury Regulations addressing whether real estate investment trusts qualify as domestically controlled adopt the basic structure of previous proposals, but certain new and modified rules may mitigate the regulations' impact, say attorneys at Simpson Thacher.
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E-Discovery Quarterly: Recent Rulings On Text Message Data
Electronically stored information on cellphones, and in particular text messages, can present unique litigation challenges, and recent court decisions demonstrate that counsel must carefully balance what data should be preserved, collected, reviewed and produced, say attorneys at Sidley.
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Don't Use The Same Template For Every Client Alert
As the old marketing adage goes, consistency is key, but law firm style guides need consistency that contemplates variety when it comes to client alert formats, allowing attorneys to tailor alerts to best fit the audience and subject matter, says Jessica Kaplan at Legally Penned.
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Think Like A Lawyer: Follow The Iron Rule Of Trial Logic
Many diligent and eager attorneys include every good fact, point and rule in their trial narratives — spurred by the gnawing fear they’ll be second-guessed for leaving something out — but this approach ignores a fundamental principle of successful trial lawyering, says Luke Andrews at Poole Huffman.
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The Art Of Asking: Leveraging Your Contacts For Referrals
Though attorneys may hesitate to ask for referral recommendations to generate new business, research shows that people want to help others they know, like and trust, so consider who in your network you should approach and how to make the ask, says Rebecca Hnatowski at Edwards Advisory.
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Unpacking The Bill To Extend TCJA's Biz-Friendly Tax Breaks
Attorneys at Skadden examine how a bipartisan bill currently being considered by the U.S. Senate to save the Tax Cuts and Jobs Act's tax breaks for research and development costs, and other expiring business-friendly provisions, would affect taxpayers.
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Deciding What Comes At The End Of WTO's Digital Tariff Ban
Companies that feel empowered by the World Trade Organization’s recent two-year extension of the ban on e-commerce tariffs should pay attention to current negotiations over what comes after the moratorium expires, as these agreements will define standards in international e-commerce for years to come, say Jan Walter, Hannes Sigurgeirsson and Kulsum Gulamhusein at Akin Gump.
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4 Ways To Refresh Your Law Firm's Marketing Strategy
With many BigLaw firms relying on an increasingly obsolete marketing approach that prioritizes stiff professionalism over authentic connection, adopting a few key communications strategies to better connect with today's clients and prospects can make all the difference, say Eric Pacifici and Kevin Henderson at SMB Law.
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This Earth Day, Consider How Your Firm Can Go Greener
As Earth Day approaches, law firms and attorneys should consider adopting more sustainable practices to reduce their carbon footprint — from minimizing single-use plastics to purchasing carbon offsets for air travel — which ultimately can also reduce costs for clients, say M’Lynn Phillips and Lisa Walters at IMS Legal Strategies.
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Cum-Ex Prosecutions Storm Shows No Sign Of Abating
The ongoing trial of Sanjay Shah in Denmark is a clear indicator that efforts remain focused on holding to account the alleged architects and beneficiaries of cum-ex trading, and with these prosecutions making their way across Europe, it is a more turbulent time now than ever, says Niall Hearty at Rahman Ravelli.
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Practicing Law With Parkinson's Disease
This Parkinson’s Awareness Month, Adam Siegler at Greenberg Traurig discusses his experience working as a lawyer with Parkinson’s disease, sharing both lessons on how to cope with a diagnosis and advice for supporting colleagues who live with the disease.
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Why Supreme Court Should Allow Repatriation Tax To Stand
If the U.S. Supreme Court doesn't reject the taxpayers' misguided claims in Moore v. U.S. that the mandatory repatriation tax is unconstitutional, it could wreak havoc on our system of taxation and result in a catastrophic loss of revenue for the government, say Christina Mason and Theresa Balducci at Herrick Feinstein.
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For Lawyers, Pessimism Should Be A Job Skill, Not A Life Skill
A pessimistic mindset allows attorneys to be effective advocates for their clients, but it can come with serious costs for their personal well-being, so it’s crucial to exercise strategies that produce flexible optimism and connect lawyers with their core values, says Krista Larson at Stinson.