International

  • November 05, 2024

    Australia Clarifies Thin Capitalization Rules Interactions

    The Australian Taxation Office clarified that the country's new thin capitalization rules must be applied after both transfer pricing and debt deduction creation rules following amendments to the country's tax rules.

  • November 05, 2024

    Crypto Council Seeks Delay In Digital Asset Broker Regs

    The IRS should delay the effective date of a requirement in the digital assets broker regulations that calls for identifying units of the assets in the broker's custody until the agency clarifies the provision, a global council of cryptocurrency companies said in a letter released Tuesday.

  • November 05, 2024

    2nd Circ. Urged To Rethink Dual Citizen's FBAR Penalties

    A dual U.S.-French citizen found liable for tax penalties by the Second Circuit for hiding millions of dollars in foreign accounts asked the court Tuesday to reconsider, saying American authorities demanded she participate in a deposition that would have put her in legal jeopardy abroad.

  • November 05, 2024

    Sweden Exploring Tax Incentive For R&D

    Sweden is hoping to craft an internationally competitive research and development tax incentive and is looking to other countries in the European Union and the Organization for Economic Cooperation and Development for inspiration, its Ministry of Finance said.

  • November 05, 2024

    Japan, Greece Tax Treaty To Take Effect In December

    The Japanese and Greek governments agreed Tuesday in Athens that their tax treaty will enter into force in 30 days and will impact taxes levied on financial accounting years beginning next year, the Japanese Ministry of Finance said in a news release.

  • November 05, 2024

    On The Ground: How Attorneys Safeguarded The Election

    Attorneys worked tirelessly Tuesday to support citizens and election workers on the final day of voting in one of history's most contentious presidential contests.

  • November 05, 2024

    EU Secures VAT Reform Deal To Fit Digital Economy

    The European Union is preparing to adapt the bloc's value-added tax rules for the growing digital economy, including e-invoicing on cross-border transactions, after a long-awaited agreement announced Tuesday.

  • November 04, 2024

    2nd Circ. Rejects Man's Challenge To IRS Lien For $4.2M

    The U.S. Tax Court correctly found that the IRS appeals office didn't abuse its powers by approving the agency's federal tax lien to collect $4.2 million from a man with a court-ordered payment plan, the Second Circuit said.

  • November 04, 2024

    Kenya Eyes 300% Tax Increase In Digital Tax Expansion

    Kenya is looking at replacing its 1.5% digital services tax with a 6% levy aimed at the country-sourced revenue of a wider set of nonresident digital service providers, including apps for ride-hailing and food delivery, according to a report by the country's Finance Ministry.

  • November 04, 2024

    Ukrainian Pleads To $11M Tax Fraud, Immigration Scheme

    A Ukrainian national charged for immigration fraud and money laundering has pled guilty and could face 20 years in prison, the U.S. Justice Department announced.  

  • November 04, 2024

    Man Loses Extradition Fight Over $9M Romanian Tax Fraud

    A man convicted twice of tax fraud in Romania can be extradited despite the fact that a warrant was missing details about his second conviction because those details were later supplied, a London court has ruled.

  • November 04, 2024

    Justices Won't Hear UBS Suit Over Disclosed Account Info

    The U.S. Supreme Court declined Monday to hear a couple's suit accusing UBS of fraudulently flagging an account to the Internal Revenue Service in violation of civil provisions under the Racketeer Influenced and Corrupt Organizations Act.

  • November 04, 2024

    Hedge Fund Lawyer Denies Role In £1.4B Cum-Ex Fraud

    The former top lawyer at a hedge fund accused of defrauding Denmark's tax authority of £1.4 billion ($1.8 billion) told a London trial Monday he had no knowledge of cum-ex trading fraud at the business.

  • November 01, 2024

    Previously Taxed Profit Rules Due By Year's End, Official Says

    The Internal Revenue Service will publish the first tranche of long-awaited regulations on offshore earnings and profits previously taxed in the U.S. before the end of the year, an agency counsel said Thursday.

  • November 01, 2024

    NOL Rules May Retain Favorable Approach, IRS Counsel Says

    New proposed regulations governing business net operating losses that could retain a popular provision allowing some businesses expanded use of those losses are a priority to be published next year, a top Internal Revenue Service lawyer said.

  • November 01, 2024

    Brazil Should Adopt Latest Pillar 2 Safe Harbor, NFTC Says

    Brazil should include the latest updates to globally agreed-upon safe harbors in its legislation to enact an international minimum tax agreement known as Pillar Two, according to the National Foreign Trade Council, which said these measures help prevent double taxation.

  • November 01, 2024

    Couple Tries To Block IRS Summons Issued For Spain

    A couple asked a California federal court to block an IRS summons for their financial information issued on behalf of Spain, saying the demand is tantamount to a fishing expedition meant to help the foreign government prosecute them.

  • November 01, 2024

    Taxation With Representation: Kirkland, Davis Polk, Wachtell

    In this week's Taxation with Representation, BC Partners sells its majority equity interest in GardaWorld, Lone Star Funds sells specialty chemicals company AOC to Nippon Paint Holdings, Crescent Biopharma takes GlycoMimetics private, and Francisco Partners buys AdvancedMD from Global Payments.

  • November 01, 2024

    Danish Tax Agency To Settle With Atty In $2.1B Tax Fraud Suit

    Denmark's tax authority has agreed to settle with an attorney whom it has accused of helping clients claim fraudulent tax refunds in a sprawling $2.1 billion case, according to a letter by its attorney in New York federal court.

  • November 01, 2024

    CFC Dividend Tax Issue Brewing In Exams, IRS Official Says

    A memorandum from the IRS chief counsel explaining why a controlled foreign corporation cannot claim a 100% deduction for certain foreign-based earnings was necessary to inform field agents dealing with the issue in the exam process, an agency official said Thursday.

  • November 01, 2024

    Australia Takes In Record AU$98B In Taxes From Big Cos.

    Large corporate entities paid a record of nearly AU$98 billion ($64 billion) in income taxes to Australia in the 2022-23 tax year, a 16.7% increase from the previous year, the Australian Taxation Office said.

  • November 01, 2024

    UK Private Schools Challenging Plan To Charge VAT On Fees

    The Independent Schools Council said Friday it plans to contest the government's decision to levy value-added tax on private school fees beginning in January.

  • October 31, 2024

    Treasury Using Help To Clear Pillar 1 'Logjam,' Official Says

    Other executive agencies in President Joe Biden's administration have backed the U.S. Treasury Department in urging negotiators at the Organization for Economic Cooperation and Development to reach a final deal on the international taxing rights overhaul known as Pillar One, a top Treasury official said Thursday.

  • October 31, 2024

    Australian Tax Collection Up 6% To Nearly AU$611B In 2023-24

    Australia collected AU$610.6 billion ($402 billion) in taxes in the 2023-24 tax year, a 6% increase over the year prior and AU$19.4 billion above projections, the Australian Taxation Office said.

  • October 31, 2024

    OECD Starts Process Of Integrating Thailand As Full Member

    The Organization for Economic Cooperation and Development has formally begun the accession process for Thailand to become a full member of the Paris-based body.

Expert Analysis

  • Recruitment Trends In Emerging Law Firm Frontiers

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    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.

  • How Associates Can Build A Professional Image

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    As hybrid work arrangements become the norm in the legal industry, early-career attorneys must be proactive in building and maintaining a professional presence in both physical and digital settings, ensuring that their image aligns with their long-term career goals, say Lana Manganiello at Equinox Strategy Partners and Estelle Winsett at Estelle Winsett Professional Image Consulting.

  • Firms Must Rethink How They Train New Lawyers In AI Age

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    As law firms begin to use generative artificial intelligence to complete lower-level legal tasks, they’ll need to consider new ways to train summer associates and early-career attorneys, keeping in mind the five stages of skill acquisition, says Liisa Thomas at Sheppard Mullin.

  • Think Like A Lawyer: Always Be Closing

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    When a lawyer presents their case with the right propulsive structure throughout trial, there is little need for further argument after the close of evidence — and in fact, rehashing it all may test jurors’ patience — so attorneys should consider other strategies for closing arguments, says Luke Andrews at Poole Huffman.

  • Litigation Inspiration: Attys Can Be Heroic Like Olympians

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    Although litigation won’t earn anyone an Olympic medal in Paris this summer, it can be worthy of the same lasting honor if attorneys exercise focused restraint — seeking both their clients’ interests and those of the court — instead of merely pursuing every advantage short of sanctionable conduct, says Bennett Rawicki at Hilgers Graben.

  • Lean Into The 'Great Restoration' To Retain Legal Talent

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    As the “great resignation,” in which employees voluntarily left their jobs in droves, has largely dissipated, legal employers should now work toward the idea of a “great restoration,” adopting strategies to effectively hire, onboard and retain top legal talent, says Molly McGrath at Hiring & Empowering Solutions.

  • Fishing Makes Me A Better Lawyer

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    Atop the list of ways fishing makes me a better lawyer is the relief it offers from the chronic stress of a demanding caseload, but it has also improved my listening skills and patience, and has served as an exceptional setting for building earnest relationships, says Steven DeGeorge​​​​​​​ at Robinson Bradshaw.

  • A Healthier Legal Industry Starts With Emotional Intelligence

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    The legal profession has long been plagued by high rates of mental health issues, in part due to attorneys’ early training and broader societal stereotypes — but developing one’s emotional intelligence is one way to foster positive change, collectively and individually, says attorney Esperanza Franco.

  • To Make Your Legal Writing Clear, Emulate A Master Chef

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    To deliver clear and effective written advocacy, lawyers should follow the model of a fine dining chef — seasoning a foundation of pure facts with punchy descriptors, spicing it up with analogies, refining the recipe and trimming the fat — thus catering to a sophisticated audience of decision-makers, says Reuben Guttman at Guttman Buschner.

  • Circuit Judge Writes An Opinion, AI Helps: What Now?

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    Last week's Eleventh Circuit opinion in Snell v. United Specialty Insurance, notable for a concurrence outlining the use of artificial intelligence to evaluate a term's common meaning, is hopefully the first step toward developing a coherent basis for the judiciary's generative AI use, says David Zaslowsky at Baker McKenzie.

  • Trauma-Informed Legal Approaches For Pro Bono Attorneys

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    As National Trauma Awareness Month ends, pro bono attorneys should nevertheless continue to acknowledge the mental and physical effects of trauma, allowing them to better represent clients, and protect themselves from compassion fatigue and burnout, say Katherine Cronin at Stinson and Katharine Manning at Blackbird.

  • How Attys Can Avoid Pitfalls When Withdrawing From A Case

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    The Trump campaign's recent scuffle over its bid to replace its counsel in a pregnancy retaliation suit offers a chance to remind attorneys that many troubles inherent in withdrawing from a case can be mitigated or entirely avoided by communicating with clients openly and frequently, says Christopher Konneker at Orsinger Nelson.

  • Using A Children's Book Approach In Firm Marketing Content

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    From “The Giving Tree” to “Where the Wild Things Are,” most children’s books are easy to remember because they use simple words and numbers to tell stories with a human impact — a formula law firms should emulate in their marketing content to stay front of mind for potential clients, says Seema Desai Maglio at The Found Word.

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