International
-
July 15, 2024
IBM Taps Jones Day To Take NY Royalty Tax Fight To Justices
IBM asked the U.S. Supreme Court for more time to submit a petition for review of a New York high court decision that upheld tax on royalties received from foreign affiliates, saying it recently retained Jones Day to handle the case.
-
July 15, 2024
Aussie Hydrogen Tax Credit Should Be Doubled, Group Says
Australia's proposed hydrogen production tax incentive, which would allow eligible projects to claim a credit worth AU$2 ($1.35) per kilogram of renewable hydrogen, should be doubled, a business group said in a set of recommendations on the plan.
-
July 15, 2024
Akerman Brings On Chamberlain Hrdlicka Tax Pros In Atlanta
Akerman LLP announced Monday that it picked up a pair of new partners for its tax practice group in Atlanta who were previously with Chamberlain Hrdlicka White Williams & Aughtry.
-
July 15, 2024
3 Arrested In German Probes Of €8.6M VAT Fraud Rings
Three suspects have been arrested in German-led investigations of two fraud rings involving the security and surveillance industry that evaded a total of €8.6 million ($9.4 million) in value-added taxes, Hamburg's tax authority announced Monday.
-
July 15, 2024
Bermuda Proposes New Agency For Corp. Taxation
Bermuda's Legislature will consider a proposal to establish a Corporate Income Tax Agency to administer the island nation's corporate income tax regime, including its recently enacted 15% global corporate minimum tax on large multinational corporations.
-
July 15, 2024
Rising Star: Davis Polk's Dominic Foulkes
Dominic Foulkes of Davis Polk & Wardwell LLP has advised companies on several multibillion-dollar transactions, including a technology-maker's $4.9 billion initial public offering, the largest in the United States in the last three years, earning him a spot among the tax law practitioners under age 40 honored by Law360 as Rising Stars.
-
July 15, 2024
German Minister To Study Findings On Simplifying Tax
Germany's finance minister said Monday in a news release that ideas on tax law put forward in two expert reports submitted last week would be looked at in detail, adding that any simplifications to the tax system should reduce the burden on citizens.
-
July 15, 2024
EU's Top Court Asked To Rule On Refund Of VAT In Bulgaria
A Bulgarian court asked the European Union's highest court to determine whether a company in the country can receive a refund of value-added tax paid for devices when the devices did not leave the territory of another EU country, a document published Monday said.
-
July 12, 2024
Rising Star: Quinn Emanuel's Emily Au
Emily Au of Quinn Emanuel Urquhart & Sullivan LLP has been the lead attorney on several high-profile cases, including a key case across the U.K. construction industry in terms of HMRC's Value-Added Tax policy, earning her a spot among the tax law practitioners under age 40 honored by Law360 as Rising Stars.
-
July 12, 2024
Law360 Names 2024's Top Attorneys Under 40
Law360 is pleased to announce the Rising Stars of 2024, our list of 158 attorneys under 40 whose legal accomplishments belie their age.
-
July 12, 2024
Chevron's End Doesn't Bear On 3M's Case, IRS Tells 8th Circ.
The U.S. Supreme Court's recent overturning of Chevron deference doesn't warrant a reversal of a U.S. Tax Court ruling in 3M Co.'s transfer pricing case, the Internal Revenue Service told the Eighth Circuit on Friday.
-
July 12, 2024
Parliament Vote On Von Der Leyen's 2nd Term Coming July 18
The European Parliament will vote July 18 whether to approve current European Commission President Ursula von der Leyen for a second five-year term, according to a document published Friday.
-
July 12, 2024
Switzerland, Hungary Adding Anti-Abuse Clause To Tax Treaty
Switzerland and Hungary moved on Friday to add to their double-taxation treaty an anti-abuse clause that prevents a person who is not a resident of either country from claiming the benefits of the treaty.
-
July 12, 2024
European Tax Policy To Watch In The Second Half Of 2024
Observers of European Union tax policy expect the EU to devote more attention to problems with existing tax legislation in the coming months as the introduction of major policy proposals takes a pause. Specialists also will be watching for progress on EU tax laws that remain stuck, and the bloc is likely to fill roles including tax commissioner. Here, Law360 examines key tax issues to watch for the remaining six months of the year.
-
July 12, 2024
Taxation With Representation: Ropes & Gray, Cravath, Latham
In this Week's Taxation with Representation, Paramount Global merges with Skydance Media, Devon Energy acquires Grayson Mill Energy's Williston Basin oil and gas business, Ryan acquires Altus Group Ltd.'s property tax business, and Bain Capital buys Envestnet Inc.
-
July 12, 2024
Worried Companies Ask For Pillar 2 Simplification
Multinational corporations are worried about what they see as the huge compliance burden imposed by the global 15% minimum tax and are asking for permanent simplifications of the rules, two corporate tax officials said Friday.
-
July 12, 2024
Alvarez & Marsal Appoints Managing Director Of Tax Group
Alvarez & Marsal Tax LLC appointed an experienced negotiator of tax incentives as managing director to the firm's corporate transformation tax group, the firm announced.
-
July 12, 2024
EU Chair Doesn't Expect Energy Tax Deal This Year
The new chair of European Union finance ministers doesn't expect to reach agreement on a landmark energy taxation law in the next half-year, anticipating only exploratory talks, an official from Hungary's EU presidency said Friday.
-
July 11, 2024
House GOP Urges USTR To Probe Canada Digital Services Tax
The U.S. trade representative should immediately launch an investigation into Canada's recently enacted digital services tax and determine if trade actions are necessary to protect American interests, U.S. House Ways and Means Republicans said in a letter Thursday.
-
July 11, 2024
ABA Attys Seek To Avoid Reporting Foreign Trust Loans
The American Bar Association's tax, real estate and trust attorneys are seeking to prevent the U.S. Treasury Department from tightening reporting requirements for the exemption of loans from foreign trusts, which are often used by wealthy families and in succession planning, according to a consultation response.
-
July 11, 2024
Brazilian Tax Agency Probes Refund Fraud Scheme
Brazilian federal tax authorities and police said Thursday they had conducted a search-and-seizure operation related to the investigation of an income tax refund fraud scheme.
-
July 11, 2024
Ex-Leaders Ask Biden For Int'l Coordination On Billionaire Tax
President Joe Biden should get behind Brazil's proposal for the Group of 20 nations to coordinate a minimum tax on billionaires, nearly 20 former presidents and prime ministers from countries such as Canada, France and South Korea said in an open letter.
-
July 11, 2024
IRS Proposes 'Basket Contracts' As Listed Transactions
The Internal Revenue Service proposed rules Thursday that would flag so-called basket option contracts as potentially abusive listed transactions, imposing additional reporting requirements under the threat of penalty for individuals and businesses involved in such arrangements.
-
July 11, 2024
IRS, OECD Officials Detail Expansion Of AI In Tax Work
The Internal Revenue Service and Organization for Economic Cooperation and Development are making great progress in adopting artificial intelligence in tax administration, representatives of both organizations said Thursday.
-
July 11, 2024
Israel Says Resident Hid $5.5M In Offshore Bank Accounts
An Israeli resident was released under restrictive conditions Thursday after the government alleged he failed to report foreign bank accounts that held more than 20 million shekels ($5.5 million), according to a statement from the Israel Tax Authority.
Expert Analysis
-
Participating In Living History Makes Me A Better Lawyer
My role as a baron in a living history group, and my work as volunteer corporate counsel for a book series fan association, has provided me several opportunities to practice in unexpected areas of law — opening doors to experiences that have nurtured invaluable personal and professional skills, says Matthew Parker at the Nebraska Department of Health and Human Services.
-
Private Equity Owners Can Remedy Law Firms' Agency Issues
Nonlawyer, private-equity ownership of law firms can benefit shareholders and others vulnerable to governance issues such as disparate interests, and can in turn help resolve agency problems, says Michael Di Gennaro at The Law Practice Exchange.
-
How Taxpayers Can Prep As Justices Weigh Repatriation Tax
The U.S. Supreme Court might strike down the 2017 federal tax overhaul's corporate repatriation tax in Moore v. U.S., so taxpayers should file protective tax refund claims before the case is decided and repatriate previously taxed earnings that could become entangled in dubious potential Section 965 refunds, say Jenny Austin and Gary Wilcox at Mayer Brown.
-
OFAC Designation Prosecutions Are Constitutionally Suspect
Criminal prosecutions based on the Office of Foreign Assets Control’s sanctions-related listing decisions — made with nearly unfettered discretion through an opaque process — present several constitutional issues, so it is imperative that courts recognize additional rights of review, say Solomon Shinerock and Annika Conrad at Lewis Baach.
-
How The OECD Global Tax Proposal Could Affect M&A
Following agreement on the Organization for Economic Cooperation and Development’s Pillar Two proposal to introduce a global minimum tax, domestic implementation is expected to have a significant impact on international M&A transactions, with financial modeling, deal structuring, risk allocation and joint venture arrangements likely to be affected, say lawyers at Freshfields.
-
UK Shares-Tax Proposals Offer Long-Awaited Modernization
The U.K. government's recent consultation on the introduction of a new tax on transactions in securities raises detailed legal and practical issues, but the prospect of a single digital stamp tax offering both streamlined legislation and administration will be welcomed, say Zoë Arnautov and Mark Sheiham at Simmons & Simmons.
-
IRS Foreign Tax Credit Pause Is Welcome Course Correction
A recent IRS notice temporarily suspending application of 2022 foreign tax credit regulations provides wanted relief for the many U.S. multinational companies and other taxpayers that otherwise face the risk of significant double taxation in their international operations, say attorneys at Mayer Brown.
-
IRS Criminal Probe Spells Uncertainty For Malta Pension Plans
The IRS’ recent scrutiny of Malta pension plan arrangements — and its unusual issuance of criminal administrative summonses — confirms that it views many of these plans as illegal tax evasion schemes, and the road ahead will not be smooth and steady for anyone involved, say attorneys at Kostelanetz.
-
IRS Announcement Will Aid Cos. In Buyback Tax Planning
Recent IRS transitional guidance regarding current requirements for reporting and payment of the stock repurchase excise tax will help corporate taxpayers make decisions about records retention and establishing reserves for future tax payments, say Xenia Garofalo and Kyle Colonna at Eversheds Sutherland.
-
Flawed Analysis Supports Common Law Tax Deficiency Ruling
The Colorado federal district court’s recent decision in Liberty Global, holding that the U.S. Department of Justice may assert a common law tax claim without the notice of tax deficiency required by the Internal Revenue Code, relies on a contorted reading of the statute and irrelevant case law, say Loren Opper and Christie Galinski at Miller Canfield.
-
Review Of Repatriation Tax Sets Justices On Slippery Slope
The U.S. Supreme Court’s recent decision to review the constitutionality of the repatriation tax in Moore v. U.S. has implications for many tax rules involving unrealized amounts and could leave the court on the brink of invalidating large swaths of the Internal Revenue Code, say attorneys at Eversheds Sutherland.
-
What To Make Of IRS' New Advance Pricing Guidance
Recent guidance on the IRS' goals for its advance pricing agreement system provides helpful insight into review and decision-making procedures for advance pricing agreement requests, but it also raises questions about the IRS' objectives, say Richard Slowinski and Stefanie Kavanagh at Alston & Bird.
-
Reserved Investor Fund Would Plug Gap In UK Finance Market
The reserved investor fund recently proposed by HM Treasury has the potential to be a welcome tax-efficient addition to the U.K.’s canon of products for real estate investments, with attractive features for companies and, in particular, large asset managers, say lawyers at Herbert Smith.