International
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October 31, 2024
11th Circ. Nixes ERISA Claim To John Hancock's $100M Credit
John Hancock Life Insurance Co. had no fiduciary duty to pass on to retirement plans $100 million in foreign tax credits that it had taken from taxes paid on foreign investments, a three-judge panel of the Eleventh Circuit said in upholding a lower court ruling.
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October 31, 2024
Reeves To Face MPs As Budget Enters Approval Process
Chancellor Rachel Reeves is due to be grilled by senior MPs on Nov. 6 after she presented the Labour government's first Budget for 14 years, which features a £40 billion ($52 billion) tax package that has raised concerns of new pressure on businesses and retirement savers.
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October 30, 2024
Jury Finds Importer Didn't Report $17M On Tax Returns
A Los Angeles jury found an importer of Chinese clothing guilty of skirting more than $8 million in customs duties and failing to report more than $17 million in cash transactions on tax returns, federal prosecutors in California announced Wednesday.
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October 30, 2024
Pillar 2 Likely To Cast Shadow Over US Tax Bill Talks
The international minimum tax agreement known as Pillar Two won't officially factor into upcoming tax bill negotiations in the U.S. Congress, but the global regime's potential grab at U.S. tax revenue could informally influence policy choices.
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October 30, 2024
Tax Court Stands By Couple's Tax Liability After Remand
An investor couple whose case was remanded by the Sixth Circuit is still liable for over $603,000 in deficient taxes tied to $3 million in claimed losses from a complex foreign-exchange derivative arrangement since their actions were not made with legitimate intentions of turning a profit, the U.S. Tax Court said Wednesday.
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October 30, 2024
GOP Lawmakers Criticize Treasury's Start Of Taiwan Tax Talks
The top tax-writing Republicans in Congress said Wednesday that the U.S. Treasury Department's announcement that it would begin negotiations with Taiwan on a double-tax relief agreement risks undermining legislation to address the issue that is stalled in the Senate.
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October 30, 2024
Canadian Can't Claim $15.8M In Losses From Forex Trades
A Canadian businessman can't claim CA$22 million ($15.8 million) in losses as deductions because the foreign exchange trades generating them were not pursued for profit, the Tax Court of Canada ruled.
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October 30, 2024
South African Parliament To Consider Global Minimum Tax
Qualifying businesses in South Africa would be subject to two parts of the OECD's 15% global minimum tax on large multinational entities making more than €750 million ($815 million) annually under legislation sent to the country's Parliament on Wednesday.
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October 30, 2024
UK's VAT Gap Rises £1.4B In 2023-24, Initial Estimate Says
The gap between the amount of value-added tax the U.K. expected to collect in the 2023-24 tax year and the amount actually collected was an estimated £9.5 billion ($12.3 billion), a £1.4 billion increase over the final estimate for the year prior, HM Revenue & Customs said Wednesday.
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October 30, 2024
UK Capital Gains Hike Casts Shadow Over Gov't LSE Aims
The decision by Chancellor Rachel Reeves to raise the tax paid on gains made when shares are sold could hinder the government's work on making the London Stock Exchange more attractive for stock listings and investors, regulatory experts warn.
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October 30, 2024
Last UK Gov't 'Did Not Share' Spending Info With Watchdog
The independent fiscal watchdog said Wednesday that the last Conservative administration had failed to disclose public spending information, adding that it would have resulted in a "materially different" forecast for government spending if it had been given the data.
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October 30, 2024
Pension Pros Say Shutting Inheritance Tax Loophole Overdue
Retirement industry professionals said Wednesday that the budget announcement by the U.K. government that it would remove a loophole that allowed the transfer of more than £1 million ($1.3 million) of inherited pension wealth without paying inheritance tax was overdue.
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October 30, 2024
Labour Gov't Unveils £40B Tax Boost In First Budget
A £40 billion ($52 billion) tax package unveiled on Wednesday by Britain's new Labour government targets business and investors and aims to plug fiscal gaps with plans including higher levies on payrolls and capital gains.
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October 29, 2024
Rimon Adds International Tax Expert In Philadelphia
Rimon PC has added an expert in international tax and trusts and estates who joined the firm's Philadelphia office after working for his own practice.
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October 29, 2024
Croatia, Australia Reach Double Tax Treaty Agreement
Croatia and Australia have agreed on a treaty to avoid double taxation that will take effect when passed by the respective legislatures, the Croatian Ministry of Finance said.
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October 29, 2024
States Should Cede Profit-Shifting Fight To OECD, Atty Says
States should shy away from using mandatory worldwide combined reporting to address profit shifting and instead allow the Organization for Economic Cooperation and Development to police tax avoidance from multinational corporations, a business trade group attorney said Tuesday.
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October 29, 2024
Switzerland Amends Double Tax Treaty With Kuwait
Switzerland said Tuesday it has ratified changes to its double taxation treaty with Kuwait that are due to take effect early next year.
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October 29, 2024
US, Taiwan To Begin Talks On Double-Tax Agreement
The U.S. and Taiwan announced Tuesday that they will begin a first round of negotiations to craft a double-tax avoidance agreement that would provide certain treaty-like benefits.
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October 28, 2024
Russia Says High Court Case May Help Nix $5B Award Suit
Russia has told a D.C. federal court that a case recently accepted for review by the U.S. Supreme Court may provide it a path to argue that the court lacks jurisdiction to decide a case brought against the country by a Yukos Oil Co. unit.
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October 28, 2024
Latin America, Caribbean Must Up Tobacco Taxes, OECD Says
Latin American and Caribbean countries must increase their tobacco excise tax levels, among other changes, to reduce the overall affordability of tobacco products to drive people to quit using them, the Organization for Economic Cooperation and Development said Monday.
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October 28, 2024
UK Construction Co. Due £3.2M In R&D Credits, Refunds
A construction contractor is entitled to tax credits and refunds totaling over £3.2 million ($4.2 million) after the U.K.'s First-tier Tribunal ruled that its expenditures for research and development were not subsidized or contracted out by another party.
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October 28, 2024
European Commission Backs Simplified Minimum Tax Filing
Multinational corporations could file returns for the 15% global minimum tax with a single country in the European Union that they would share with the others only where necessary under a proposal approved Monday by the bloc's executive branch, according to officials.
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October 28, 2024
Labour Budget Expected To Target Taxes At Biz, Investors
The U.K. government is set to unveil its budget statement Wednesday after months of hinting at higher taxes, and experts say businesses and investors are bracing to bear the brunt of the possible tax changes, such as through increases to capital gains and payroll taxes.
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October 28, 2024
Chile Provides Guidance For Voluntary Disclosure Program
Chile's tax agency provided guidance Monday for taxpayers interested in voluntarily disclosing their previously undeclared foreign assets in order to take advantage of a temporarily available tax rate.
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October 28, 2024
IRS Extends Relief For FATCA Filings Without ID Numbers
Foreign financial institutions that report information on U.S. account holders to the Internal Revenue Service without including the taxpayer identification numbers associated with those accounts won't be flagged for noncompliance for the next three years, the agency said Monday.
Expert Analysis
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How Associates Can Build A Professional Image
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.
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Firms Must Rethink How They Train New Lawyers In AI Age
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.
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Think Like A Lawyer: Always Be Closing
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.
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Litigation Inspiration: Attys Can Be Heroic Like Olympians
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.
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Lean Into The 'Great Restoration' To Retain Legal Talent
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.
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Fishing Makes Me A Better Lawyer
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.
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A Healthier Legal Industry Starts With Emotional Intelligence
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.
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To Make Your Legal Writing Clear, Emulate A Master Chef
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.
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Circuit Judge Writes An Opinion, AI Helps: What Now?
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.
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Trauma-Informed Legal Approaches For Pro Bono Attorneys
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.
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How Attys Can Avoid Pitfalls When Withdrawing From A Case
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.
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Using A Children's Book Approach In Firm Marketing Content
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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New Crypto Reporting Will Require Rigorous Recordkeeping
The release of a form for reporting digital asset transactions is a pivotal moment in the Internal Revenue Service's efforts to track cryptocurrency activities that increases oversight by requiring brokers to report investor sales and exchanges, say Shaina Kamen and Max Angel at Holland & Knight.