International

  • January 17, 2025

    Law360 Names Practice Groups Of The Year

    Law360 would like to congratulate the winners of its Practice Groups of the Year awards for 2024, which honor the attorney teams behind litigation wins and significant transaction work that resonated throughout the legal industry this past year.

  • January 17, 2025

    Law360 Names Firms Of The Year

    Eight law firms have earned spots as Law360's Firms of the Year, with 54 Practice Group of the Year awards among them, steering some of the largest deals of 2024 and securing high-profile litigation wins, including at the U.S. Supreme Court.

  • January 20, 2025

    Gov't Gets Mixed Reception On Inheritance Tax Pension Plans

    Proposals by the U.K. government to bring pension assets within the scope of inheritance tax will result in "numerous problems" and raise concerns in their current form, a trade body and consultants warned on Monday.

  • January 17, 2025

    UK Parliament Calls New Treasury Unit 'Poorly Defined'

    A new HM Treasury office set up to scrutinize fiscal policy lacks staff and its purpose is poorly defined, which means it could duplicate the work of other organizations, the U.K. Parliament's Treasury Select Committee said in a report Sunday.

  • January 17, 2025

    US Guidance On Amount B Carries Potential For Disputes

    Recent IRS guidance on a simplified and streamlined transfer pricing method for certain cross-border transactions, known as Amount B, suggests rulemakers want feedback on how it would work if it were made mandatory, but that approach could lead to controversy without global cooperation.

  • January 17, 2025

    Case Dismissed Against Man Accused Of Concealing Location

    A former healthcare executive whose employer had accused him of avoiding CA$1.2 million ($828,000) in Canadian taxes by lying about his location no longer faces legal action, as the parties agreed to dismiss the action.

  • January 17, 2025

    Hawaii House Bill Seeks Worldwide Combined Reporting

    Hawaii would impose a mandatory worldwide combined reporting system for corporations effective next year under a bill filed in the state House of Representatives.

  • January 17, 2025

    Taxation With Representation: Simpson Thacher, Covington

    In this week's Taxation With Representation, Eli Lilly and Co. buys a precision breast cancer program, Applied Digital Corp. enters a financing agreement for its high-performance computing business, Clearwater Analytics buys Enfusion, and Lantheus Holdings Inc. buys Life Molecular Imaging Ltd.

  • January 17, 2025

    UAE, Russia Reach Agreement On Double-Tax Treaty

    Representatives of the United Arab Emirates and Russia signed a draft treaty to prevent double taxation on income and capital, the UAE's state news agency said Friday, despite ongoing international tensions over Russia's war with Ukraine.

  • January 17, 2025

    Scottish Power Loses £28M Redress Case Against HMRC

    Scottish Power lost its appeal against HM Revenue and Customs on Friday, as a tribunal ruled that the energy company was wrong to argue that just over £28 million ($34 million) in redress payments it made after being investigated for regulatory failures was tax-deductible.

  • January 16, 2025

    Canadian Conservatives Pledge To Kill Capital Gains Hike

    The Conservative Party of Canada promised Thursday to ax a capital gains tax increase secured by the administration of outgoing Prime Minister Justin Trudeau, according to a news release shared on social media Thursday by the party's leader and its candidate for Trudeau's position, Pierre Poilievre.

  • January 16, 2025

    OECD's Global Minimum Tax Takes Effect In Indonesia

    Indonesia began implementing the OECD's global minimum tax on multinational entities making over €750 million ($773 million) annually at the start of this year, the country's Ministry of Finance said Thursday.

  • January 16, 2025

    OECD To Release List Of Abusive Transactions Under Pillar 2

    The Organization for Economic Cooperation and Development is putting together a list of intercompany transactions that may raise red flags as attempts to undermine an international minimum tax agreement known as Pillar Two, an OECD official said Thursday.  

  • January 16, 2025

    Madeira Loses EU State Aid Case Over Tax Breaks

    Portugal will have to recover money from companies granted reduced tax rates by its autonomous territory Madeira because the taxpayers failed to meet the terms of two European Commission decisions allowing state aid, the European Court of Justice ruled Thursday.

  • January 16, 2025

    Morrison Foerster Adds Tax Group Co-Chair From Jones Day

    Morrison Foerster LLP announced it has added a partner from Jones Day to serve as co-chair of the firm's global tax group in its New York office.

  • January 16, 2025

    HMRC Cuts Response Time To Tax Info Exchange Requests

    HM Revenue & Customs dropped its average response time to international information exchange requests to 127 days from 175 days, well below the international average of 180 days, the U.K. revenue agency said.

  • January 16, 2025

    IRS Corrects Simplified Foreign Currency Rules

    The Internal Revenue Service issued corrections Thursday to finalized regulations that aim to simplify aspects of how corporations determine taxable income or loss with respect to certain affiliates that conduct business in a foreign currency.

  • January 16, 2025

    Treasury Updates Bonus Energy Tax Credit Safe Harbors

    The U.S. Treasury Department provided updates Thursday to safe harbors that clean energy project developers can use to qualify for bonus tax credits for domestically sourcing steel and aluminum parts in response to new trade restrictions on solar products from China by President Joe Biden's administration.

  • January 15, 2025

    Dems, GOP Willing To Work On Certain Tax Issues, Aides Say

    Democrats are willing to work with Republicans on bipartisan issues, such as providing certain treaty-like benefits to Taiwanese residents, retirement issues, and tax administration issues, Democratic and GOP aides for the House Ways and Means and Senate Finance committees said Wednesday.

  • January 15, 2025

    Former IRS Litigator Joins Jones Day In Boston

    Jones Day announced it added an experienced IRS litigator to its Boston office who will work as of counsel in the firm's tax practice.

  • January 15, 2025

    Legislators Say Transparency Act Defies First Amendment

    The Corporate Transparency Act is an unnecessary intrusion into the First Amendment rights of Americans, U.S. Sen. Thom Tillis, R-N.C., and 13 House members told the Supreme Court in seeking to maintain an injunction issued in December.

  • January 15, 2025

    House Clears US-Taiwan Double Tax Relief Bill

    The U.S. House of Representatives overwhelmingly approved legislation Wednesday that would provide Taiwanese businesses in the United States with tax-treaty-like benefits and authorize the White House to negotiate a tax agreement with Taiwan.

  • January 15, 2025

    Australia Gives Guidance On Foreign-Funded Construction

    The Australian Taxation Office laid out a number of key areas that private companies receiving foreign funding from a related party for property or construction projects need to be aware of in order to not run afoul of the country's transfer pricing rules.

  • January 15, 2025

    HMRC Board Chair Calls Fiscal Rules Nonnegotiable

    The U.K. government will not change course on its fiscal rules despite higher borrowing costs from worsening market conditions, the chair of the board of Britain's tax authority told Parliament's Treasury Committee on Wednesday.

  • January 15, 2025

    Sweden Should Expand, Simplify R&D Tax Credit, Report Says

    A government report said Sweden should simplify and expand its research and development tax credit regime and make changes to what is known as its expert tax incentives in order to improve the country's competition and productivity, its Ministry of Finance said Wednesday.

Expert Analysis

  • Spartan Arbitration Tactics Against Well-Funded Opponents

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    Like the ancient Spartans who held off a numerically superior Persian army at the Battle of Thermopylae, trial attorneys and clients faced with arbitration against an opponent with a bigger war chest can take a strategic approach to create a pass to victory, say Kostas Katsiris and Benjamin Argyle at Venable.

  • What Recent Study Shows About AI's Promise For Legal Tasks

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    Amid both skepticism and excitement about the promise of generative artificial intelligence in legal contexts, the first randomized controlled trial studying its impact on basic lawyering tasks shows mixed but promising results, and underscores the need for attorneys to proactively engage with AI, says Daniel Schwarcz at University of Minnesota Law School.

  • How FinCEN Proposal Expands RE Transaction Obligations

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    Against a regulatory backdrop foreshadowing anti-money laundering efforts in the real estate sector, the Financial Crimes Enforcement Network's proposed rule significantly expands reporting requirements for certain nonfinanced residential real estate transfers and necessitates careful review, say attorneys at Fried Frank.

  • Litigation Inspiration: A Source Of Untapped Fulfillment

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    As increasing numbers of attorneys struggle with stress and mental health issues, business litigators can find protection against burnout by remembering their important role in society — because fulfillment in one’s work isn’t just reserved for public interest lawyers, say Bennett Rawicki and Peter Bigelow at Hilgers Graben.

  • Unpacking FinCEN's Proposed Real Estate Transaction Rule

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    Phil Jelsma and Ulrick Matsunaga at Crosbie Gliner take a close look at the Financial Crimes Enforcement Network's recently proposed rulemaking — which mandates new disclosures for professionals involved in all-cash real estate deals — and discuss best next steps for the broad range of businesses that could be affected.

  • Think Like A Lawyer: Forget Everything You Know About IRAC

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    The mode of legal reasoning most students learn in law school, often called “Issue, Rule, Application, Conclusion,” or IRAC, erroneously frames analysis as a separate, discrete step, resulting in disorganized briefs and untold obfuscation — but the fix is pretty simple, says Luke Andrews at Poole Huffman.

  • How New EU Tax And Transfer Pricing Rules May Affect M&A

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    Companies involved in mergers and acquisitions may need to adjust fiscal due diligence procedures to ensure they consider potential far-reaching effects of newly implemented transfer pricing measures, such as newly implemented global minimum tax and European Union anti-tax avoidance directives and proposals, says Patrick Tijhuis at BDO.

  • How Firms Can Ensure Associate Gender Parity Lasts

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    Among associates, women now outnumber men for the first time, but progress toward gender equality at the top of the legal profession remains glacially slow, and firms must implement time-tested solutions to ensure associates’ gender parity lasts throughout their careers, say Kelly Culhane and Nicole Joseph at Culhane Meadows.

  • 7 Common Myths About Lateral Partner Moves

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    As lateral recruiting remains a key factor for law firm growth, partners considering a lateral move should be aware of a few commonly held myths — some of which contain a kernel of truth, and some of which are flat out wrong, says Dave Maurer at Major Lindsey.

  • 6 Pointers For Attys To Build Trust, Credibility On Social Media

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    In an era of information overload, attorneys can use social media strategically — from making infographics to leveraging targeted advertising — to cut through the noise and establish a reputation among current and potential clients, says Marly Broudie at SocialEyes Communications.

  • US-Chile Tax Treaty May Encourage Cross-Border Investment

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    Provisions in the recently effective U.S.-Chile bilateral income tax treaty should encourage business between the two countries, as they reduce U.S. withholding tax on investment income for Chilean taxpayers, exempt certain U.S. taxpayers from Chilean capital gains tax, and clarify U.S. foreign tax credit rules, say attorneys at Kramer Levin.

  • A Post-Mortem Analysis Of Stroock's Demise

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    After the dissolution of 147-year-old firm Stroock late last year shook up the legal world, a post-mortem analysis of the data reveals a long list of warning signs preceding the firm’s collapse — and provides some insight into how other firms might avoid the same disastrous fate, says Craig Savitzky at Leopard Solutions.

  • SG's Office Is Case Study To Help Close Legal Gender Gap

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    As women continue to be underrepresented in the upper echelons of the legal profession, law firms could learn from the example set by the Office of the Solicitor General, where culture and workplace policies have helped foster greater gender equality, say attorneys at Ocean Tomo.

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