International
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November 25, 2024
Feds Violated Atty-Client Rules, Tax Evasion Defendant Says
A Brazilian-American businessman accused of using Swiss bank accounts to hide $20 million from the Internal Revenue Service asked a Florida federal court to dismiss all the charges against him, saying federal prosecutors improperly gained access to information protected by attorney-client privilege.
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November 25, 2024
IRS Corrects Advanced Manufacturing Production Credit Regs
The Internal Revenue Service issued a correction notice Monday concerning final rules for the advanced manufacturing production credit.
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November 25, 2024
Tax Hikes Will Make It Harder To Hire, UK Industry Chief Says
Businesses will hire fewer workers as a result of raising employers' National Insurance contributions, a payroll levy, that was introduced in the autumn budget, the chief of one of Britain's most influential industry groups said Monday.
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November 22, 2024
Trump Taps Hedge Fund Billionaire Bessent To Head Treasury
President-elect Donald Trump on Friday announced that he's selected Scott Bessent, a billionaire hedge fund manager and the founder of Key Square Group, to serve as secretary of the Treasury in his upcoming administration.
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November 22, 2024
IRS Extends Domestic Content Relief For Energy Credits
Nonprofits, tribal governments, public utilities and other tax-exempt groups eligible for a direct cash payment of their clean energy tax credits can get relief from meeting the domestic content requirements tied to those incentives for 2025 and 2026 under IRS guidance released Friday.
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November 22, 2024
Canada Proposing 2-Month GST Holiday For Groceries, Gifts
Canada's government is sending a proposal to its Parliament that would implement a two-month goods-and-services tax holiday starting in mid-December on goods ranging from certain groceries to Christmas trees.
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November 22, 2024
Isle Of Man Parliament Passes OECD's Global Minimum Tax
The Isle of Man's Parliament approved a bill implementing two portions of the Organization for Economic Cooperation and Development's 15% global minimum tax on large multinational entities making at least €750 million ($781 million) annually, starting in 2025.
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November 22, 2024
IRS Ignores Text In $248M Fight, Liberty Global Tells 10th Circ.
The Internal Revenue Service is incorrectly applying the U.S. tax code in denying Liberty Global's claim for $248 million in foreign tax credits tied to its sale of a Japanese affiliate, the telecommunications company told the Tenth Circuit.
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November 22, 2024
Halliburton Omitted Grounds From $35M Refund Suit, US Says
A Texas federal court must dismiss parts of Halliburton's $35 million tax refund lawsuit because the company failed to raise two grounds of relief in its administrative claim for a refund, the U.S. argued.
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November 22, 2024
Taxation With Representation: Stradley Ronon, Davis Polk
In this week's Taxation With Representation, Amcor PLC buys Berry Global Group Inc., AeroVironment buys BlueHalo, Robinhood Markets Inc. acquires TradePMR, and Comcast Corp. spins off a suite of NBCUniversal cable television networks.
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November 22, 2024
2 Convicted In €3.7M EU VAT Fraud Scheme
A German court convicted two people for their roles in a value-added tax fraud scheme involving small electronic goods that caused an estimated €3.7 million ($3.86 million) in lost tax revenue, the European Public Prosecutor's Office said.
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November 22, 2024
Spain Raises Bank Windfall Levy, Enacts Minimum Tax
The Spanish government is set to increase its windfall tax on banks with more than €5 billion ($5.2 billion) in income as well as implement a minimum corporate tax on multinational companies following a vote by lawmakers.
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November 21, 2024
EU Official Says GILTI Changes Could Nullify Pillar 2 Backstop
The U.S. has an opportunity to shield multinationals from the Pillar Two 15% global minimum tax backstop rule in other jurisdictions by revising its tax on global intangible low-taxed income next year, a European Union tax official said Thursday.
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November 21, 2024
Australia Floats Paths For Adopting Crypto Disclosure Rules
The Australian government floated two options Thursday for implementing a global crypto-asset reporting framework: adopt a standardized model or take a "bespoke approach" that would offer more flexibility but may also increase compliance costs.
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November 21, 2024
Breach Of VAT Rules Can Block €385K Refund, ECJ Rules
Bulgarian tax authorities can deny a value-added tax refund of approximately €385,000 ($403,000) to a domestic company that did not have the tax itemized on invoices, the European Court of Justice ruled Thursday.
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November 21, 2024
6 Nations Must Improve Transparency Framework, OECD Says
Six countries that have generally complied with global standards for exchanging financial information for tax purposes could nevertheless improve their mechanisms for accessing data about entity owners, according to reports released Thursday by the Organization for Economic Cooperation and Development.
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November 21, 2024
VAT Stays King Of Consumption Taxes Across OECD
Value-added tax revenue continued to be the largest category of consumption taxes across the Organization for Economic Cooperation and Development in 2022, it said Thursday, generating an average of 20.8% of total revenue in 2022, a 0.1 percentage point increase.
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November 21, 2024
Tax Revenue Ratio Remained Steady In 2023, OECD Says
The average tax-to-gross domestic product ratio across Organization for Economic Cooperation and Development countries remained relatively steady in 2023 compared with the year prior, the OECD said Thursday, even as they deal with challenges such as the increasing cost of living and climate change.
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November 21, 2024
Israel-Hamas War Tax Relief Needed More Notice, TIGTA Says
While the Internal Revenue Service did well to proactively identify taxpayers likely affected by the Israel-Hamas war that it sought to grant tax relief, it failed to directly notify these taxpayers, the Treasury Inspector General for Tax Administration said Thursday.
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November 21, 2024
11th Circ. Asked To Rethink $100M Credit For John Hancock
The Eleventh Circuit should reverse its decision allowing John Hancock Life Insurance Co. to keep $100 million in foreign tax credits that rightfully belong to the company's investors, trustees of a retirement plan said in arguing that the court overlooked a key U.S. Treasury regulation.
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November 21, 2024
Ryanair Threatens To Cut France Flights Over Ticket Tax
Irish budget airline Ryanair warned it would suspend flights to and from 10 regional airports in France if the country goes through with its proposed tax on plane tickets, which would take effect in January.
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November 20, 2024
India's Top Court Allows Tax Credits For Excise Duties Paid
Excise duties that India's mobile telecommunication providers pay when building the infrastructure for their networks — such as transmission towers — can be used as tax credits, the Supreme Court of India ruled Wednesday.
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November 20, 2024
NY Says Changes To Fed. Tax Return Reset Refund Timeline
A couple living in Switzerland for part of each year timely filed their claim for overpaid New York state income taxes dating back to 2011 soon after winning double-taxation relief under the Swiss-U.S. tax treaty in 2018, the state's tax department said.
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November 20, 2024
NY Tax Withholding Not Needed For Foreign Board Member
A New York company that appointed an Italian citizen to its board of directors does not have to withhold state income tax for payments made to that board member, the state's tax department said.
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November 20, 2024
Irish Social Democrats Run On Wealth Tax For Millionaires
Ireland's Social Democrats are campaigning for this month's general election on a 0.5% tax on individuals' assets over €1 million ($1.1 million) — excluding homes, family businesses, art and pensions — and 1% for assets over €2 million, according to its manifesto.
Expert Analysis
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7 E-Discovery Predictions For 2024 And Beyond
The legal and technical issues of e-discovery now affect virtually every lawsuit, and in the year to come, practitioners can expect practices and policies to evolve in a number of ways, from the expanded use of relevancy redactions to mandated information security provisions in protective orders, say attorneys at Littler.
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5 Litigation Funding Trends To Note In 2024
Over the next year and beyond, litigation funding will continue to evolve in ways that affect attorneys and the larger litigation landscape, from the growth of a secondary market for funded claims, to rising interest rates restricting the availability of capital, says Jeffery Lula at GLS Capital.
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4 Legal Ethics Considerations For The New Year
As attorneys and clients reset for a new year, now is a good time to take a step back and review some core ethical issues that attorneys should keep front of mind in 2024, including approaching generative artificial intelligence with caution and care, and avoiding pitfalls in outside counsel guidelines, say attorneys at HWG.
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What The Law Firm Of The Future Will Look Like
As the legal landscape shifts, it’s become increasingly clear that the BigLaw business model must adapt in four key ways to remain viable, from fostering workplace flexibility to embracing technology, say Kevin Henderson and Eric Pacifici at SMB Law Group.
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4 PR Pointers When Your Case Is In The News
Media coverage of new lawsuits exploded last year, demonstrating why defense attorneys should devise a public relations plan that complements their legal strategy, incorporating several objectives to balance ethical obligations and advocacy, say Nathan Burchfiel at Pinkston and Ryan June at Castañeda + Heidelman.
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Unpacking The Proposed Production Tax Credit Regulations
Recently proposed tax regulations for claiming the U.S. clean-energy manufacturers' production credit under Internal Revenue Code Section 45X are less stringent than many had feared but fail to define a fundamental eligibility requirement, say Casey August and Jared Sanders at Morgan Lewis.
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10 Considerations For Litigating A New York Tax Case
While some of New York’s recently adopted corporate tax regulations are likely to face legal challenges, aggrieved taxpayers should answer certain questions before deciding to embark on the tax litigation process, say Cyavash Ahmadi and Jeffrey Friedman at Eversheds Sutherland.
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Law Firm Strategies For Successfully Navigating 2024 Trends
Though law firms face the dual challenge of external and internal pressures as they enter 2024, firms willing to pivot will be able to stand out by adapting to stakeholder needs and reimagining their infrastructure, says Shireen Hilal at Maior Consultants.
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Attorneys' Busiest Times Can Be Business Opportunities
Attorneys who resolve to grow their revenue and client base in 2024 should be careful not to abandon their goals when they get too busy with client work, because these periods of zero bandwidth can actually be a catalyst for future growth, says Amy Drysdale at Alchemy Consulting.
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How Attorneys Can Be More Efficient This Holiday Season
Attorneys should consider a few key tips to speed up their work during the holidays so they can join the festivities — from streamlining the document review process to creating similar folder structures, says Bennett Rawicki at Hilgers Graben.
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How Clients May Use AI To Monitor Attorneys
Excerpt from Practical Guidance
Artificial intelligence tools will increasingly enable clients to monitor and evaluate their counsel’s activities, so attorneys must clearly define the terms of engagement and likewise take advantage of the efficiencies offered by AI, says Ronald Levine at Herrick Feinstein.
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The Pop Culture Docket: Judge D'Emic On Moby Grape
The 1968 Moby Grape song "Murder in My Heart for the Judge" tells the tale of a fictional defendant treated with scorn by the judge, illustrating how much the legal system has evolved in the past 50 years, largely due to problem-solving courts and the principles of procedural justice, says Kings County Supreme Court Administrative Judge Matthew D'Emic.
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Breaking Down High Court's New Code Of Conduct
The U.S. Supreme Court recently adopted its first-ever code of conduct, and counsel will need to work closely with clients in navigating its provisions, from gift-giving to recusal bids, say Phillip Gordon and Mateo Forero at Holtzman Vogel.