International

  • August 16, 2024

    IRS To Let Private Cos. Into Real-Time Biz Audit Program

    The Internal Revenue Service is opening its compliance assurance process real-time audit program to privately held C corporations, including foreign-owned ones, for 2025, the agency announced.

  • August 16, 2024

    Taxation With Representation: Cleary, Kirkland, Skadden

    In this week's Taxation with Representation, Mars Inc. sets a 2024 record with its $36 billion acquisition of Kellanova, Carlyle inks a $3.8 billion purchase with Baxter International Inc., and Performance Food Group Co. agrees to a $2.1 billion cash deal with Cheney Bros. Inc.

  • August 15, 2024

    Doctor Wants Contempt Fine Dropped In Foreign Asset Case

    A doctor who incurred $1.1 million in liabilities for failing to report his foreign bank accounts is asking a Michigan federal court to waive his $20,000 civil contempt fine because the court restricted his only financial assets to paying the liabilities.

  • August 15, 2024

    Tax Pros Navigate Chaos, Rewards In Climate Law's 2nd Year

    Energy tax attorneys have been knee-deep in project finance deals for the past year since the Inflation Reduction Act of 2022 triggered a flurry of clean energy investments, but the work, they say, has been fulfilling as part of broader efforts to save the environment.

  • August 15, 2024

    Taxes Could Be Key To Cutting Crypto Emissions, IMF Says

    The growing environmental impact of crypto-asset mining and related data centers could be mitigated with tax measures aimed directly at such facilities, the International Monetary Fund said Thursday.

  • August 15, 2024

    Germany Seeks Input On Tightened Transfer Pricing Rules

    Germany is poised to make multinational corporations responsible for showing the economic necessity of intra-group, cross-border debt relationships when they deduct expenses for financing with borrowed capital, according to a consultation by the federal government.

  • August 15, 2024

    Finland To Have EU's 2nd-Highest VAT Rate Starting Sept. 1

    Finland's general value-added tax rate will jump to 25.5% from 24% starting Sept. 1, the country's tax agency said Thursday, putting it behind only Hungary for the highest VAT rate in the European Union.

  • August 15, 2024

    Aussie Senate Economics Committee OKs 15% Min. Tax Bill

    The Australian Senate's Economics Legislation Committee said it supports the passage of a three-bill package that would implement the OECD's 15% global corporate minimum tax on large multinational entities, sending it to the entire Senate for approval.

  • August 15, 2024

    UK Plastic Packaging Tax Revenue Dipped By 6%

    The U.K. collected £268 million ($344 million) from its tax on certain plastic packaging manufactured in or imported into the country in the 2023-2024 fiscal year, down 6% from the £285 million the year prior, HM Revenue & Customs said Thursday.

  • August 14, 2024

    PwC Owes $11M For Tax Errors, Real Estate Group Says

    PwC should pay £8.9 million ($11.4 million) in damages to a real estate group for miscalculating its tax liabilities and mispricing its properties, which prompted several additional assessments and penalties, according to a claim in a London court.

  • August 14, 2024

    Baker McKenzie Adds Tax Expert To Monterrey Office

    Baker McKenzie has added a partner from Turanzas Bravo & Ambrosi to its Monterrey, Mexico, office who brings more than 15 years of experience practicing international trade law with a focus on taxation and customs-related litigation.

  • August 14, 2024

    Kenya Tax Court Finds Chinese Firm Dodged $7.8M VAT

    A Kenyan tax court affirmed an assessment that found a China-based firm used a series of shell companies to dodge over 1 billion Kenyan shillings ($7.8 million) in value-added tax payments, the Kenya Revenue Authority said Wednesday.

  • August 14, 2024

    Swiss Seeking Input On Delays Of Crypto-Asset Info Exchange

    Switzerland's executive body, the Federal Council, is looking for public input on when it should begin automatically exchanging financial information regarding crypto-assets with countries with which it already has set up general automatic exchange of information agreements, its finance ministry said.

  • August 14, 2024

    EU General Court Jurisdiction Expanded To VAT Cases

    The General Court of the European Union will be able to make preliminary rulings in cases involving the EU's common system of value-added taxes starting Oct. 1, following an expansion of the court's jurisdiction.

  • August 14, 2024

    Pros Lament Lack Of Ownership Clarity In New EU Law

    The lack of a clear beneficial ownership definition in new European Union legislation designed to speed up the repayment of withholding taxes represents a missed opportunity — and could cause confusion for investors about whether they are in fact eligible for a refund, tax professionals say.

  • August 14, 2024

    Other Price Rises Offset German Tampon VAT Cut, Study Says

    Germany's reduction in the value-added tax on female sanitary products, such as tampons, has led to higher prices on panty liners, a Munich-based think tank said in a news release Wednesday.

  • August 13, 2024

    Walz Backed Tax Hikes Funding Plans For Children, Families

    As Minnesota's governor, Democrat Tim Walz, now the presumed vice presidential nominee of his party, separated himself from most other governors by signing into law numerous tax increases funding progressive priorities such as a paid family leave plan and the nation's largest child tax credit.

  • August 13, 2024

    Treasury's Loss Rules Take Broad Approach To Min. Tax Deal

    The U.S. Treasury Department recently dashed the hopes of multinational corporations seeking regulations that would have carved out an international minimum tax agreement from interacting with long-standing domestic rules aimed at preventing companies from using the same economic loss twice.

  • August 13, 2024

    Firm Asks Court To Reconsider $1.5M Freeze In Tax Dispute

    A Baltimore law firm that sued the IRS for freezing $1.5 million in its operating account to satisfy a client's tax debts told a Maryland federal court it was "dead wrong" in denying the firm's request to release the money without going to trial.

  • August 13, 2024

    Developing Countries Defend 3-Year Deadline For UN Tax Pact

    Three years is enough time to finish writing a United Nations framework convention on international tax cooperation, Brazil, India, Nigeria and other developing countries said Tuesday in defense of a proposed timeline that was criticized by Canada, the U.S. and France.

  • August 13, 2024

    Canada Seeking Comments On Global Min. Tax, Capital Gains

    Canada's government is seeking comments from the public on a wide range of tax proposals included in its 2024 budget, including the introduction of the OECD's global minimum tax on large multinational corporations and adjustments to the country's taxation of capital gains, the government announced.

  • August 13, 2024

    HMRC Collected £384M In Soccer Tax Crackdowns, Firm Says

    HM Revenue & Customs has recovered £384 million ($494 million) in taxes through investigations into soccer clubs, players and agents over the past five years, including £67.5 million in the past year alone, a U.K. accounting firm said.

  • August 13, 2024

    Finland Seeking Input On Global Min. Tax Changes

    Finland's Ministry of Finance is seeking input on proposed changes to the country's implementation of the OECD's 15% global minimum tax on large multinational corporations, including clarifications, though it said the changes wouldn't impact the core principles of the law.

  • August 13, 2024

    Int'l Tax Projects Must Seek Consensus, Finance Ministers Say

    Any international tax policy project should focus on consensus-based solutions in order to keep competitive conditions fair, a group of finance ministers from German-speaking countries said Tuesday.

  • August 12, 2024

    US Seeks To Omit Fair Split Of Tax Rights From UN Tax Pact

    The U.S. government proposed on Monday dropping the fair allocation of taxing rights as a principle to guide negotiators on the United Nations framework convention on international tax cooperation, saying that the agenda risks duplication, but the organization's African bloc and others opposed its move.

Expert Analysis

  • 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.

  • Reimagining Law Firm Culture To Break The Cycle Of Burnout

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    While attorney burnout remains a perennial issue in the legal profession, shifting post-pandemic expectations mean that law firms must adapt their office cultures to retain talent, say Kevin Henderson and Eric Pacifici at SMB Law Group.

  • Cayman Islands Off AML Risk Lists, Signaling Robust Controls

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    As a world-leading jurisdiction for securitization special purpose entities, the removal of the Cayman Islands from increased anti-money laundering monitoring lists is a significant milestone that will benefit new and existing financial services customers conducting business in the territory, say lawyers at Walkers Global.

  • The Legal Industry Needs A Cybersecurity Paradigm Shift

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    As law firms face ever-increasing risks of cyberattacks and ransomware incidents, the legal industry must implement robust cybersecurity measures and privacy-centric practices to preserve attorney-client privilege, safeguard client trust and uphold the profession’s integrity, says Ryan Paterson at Unplugged.

  • As Promised, IRS Is Coming For Crypto Tax Evaders

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    The IRS is fulfilling its promise to crack down on those who have neglected to pay taxes on cryptocurrency earnings, as demonstrated by recently imposed prison sentences, enforcement initiatives and meetings with international counterparts — suggesting a few key takeaways for taxpayer compliance, say attorneys at BakerHostetler.

  • 5 Reasons Associates Shouldn't Take A Job Just For Money

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    As a number of BigLaw firms increase salary scales for early-career attorneys, law students and lateral associates considering new job offers should weigh several key factors that may matter more than financial compensation, say Albert Tawil at Lateral Hub and Ruvin Levavi at Power Forward.

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