International
-
June 21, 2024
Supreme Court Leaves Lifeline For Billionaire Income Tax
The U.S. Supreme Court narrowed but did not entirely block the path to billionaire income tax legislation when the majority's opinion declined to weigh constitutional questions about taxing unrealized gains in its decision to uphold a mandatory repatriation levy.
-
June 21, 2024
USTR Warns Canada After Digital Services Tax Enactment
The U.S. Trade Representative's Office remains concerned about Canada's enactment of its digital services tax and is weighing options in defense of potential discrimination against U.S. businesses, a USTR official told Law360 on Friday.
-
June 21, 2024
Fed. Circ. Backs Subsidy Duties For Canadian Wind Towers
A Canadian wind tower manufacturer can't get a break on countervailing duties despite being upfront about errors in its sales data, with the Federal Circuit ruling Friday that the errors raise the possibility of additional mistakes.
-
June 21, 2024
US Formally Suspends Part Of Tax Treaty With Russia
The U.S. government has provided formal notice to Russia suspending, via mutual agreement, parts of the countries' double-taxation treaty.
-
June 21, 2024
Big 4 Continue Push For Broader Irish Dividend Exemption
The Big Four accounting firms reiterated support for Ireland's plans to implement a corporate tax exemption for foreign-sourced dividends and foreign branch profits, but they found the latest proposal still too narrow and complicated to qualify for, according to comments released Friday.
-
June 21, 2024
Norway Seeking Feedback On Undertaxed Profits Rule
Norway is looking for feedback on a proposal that would implement the undertaxed profits rule, one component of the Organization for Economic Cooperation and Development's 15% corporate global minimum tax plan, the country's Finance Ministry said.
-
June 21, 2024
OECD Official Sees Amount B Deal Helping With Amount A
The Organization for Economic Cooperation and Development is close to a final deal on a key part of its efforts to establish new international taxing rights under Amounts A and B of its Pillar One plans, according to the organization's tax chief.
-
June 21, 2024
Taxation With Representation: Travers Smith, Potamitis Vekris
In this week's Taxation With Representation, RSK Group Ltd. gets a £500 million ($632 million) investment, Boston Scientific Corp. acquires Silk Road Medical Inc., Masdar takes a part of Terna Energy SA, and Tate & Lyle PLC buys CP Kelco from JM Huber Corp.
-
June 21, 2024
EU Digital Tax Is Backup If Pillar 1 Stalls, French Official Says
Finalizing the Pillar One agreement to reallocate corporate taxing rights globally should remain a paramount goal, but if the effort stalls, the European Union should revive its plan for a digital tax of mostly U.S.-based tech giants, French Finance Minister Bruno Le Maire said Friday.
-
June 21, 2024
Estonia Again Blocks Agreement On VAT Deal
For the second straight month, Estonia blocked agreement Friday on a European Union proposal for platform companies such as Airbnb, Uber and Estonia-based Bolt to collect value-added tax on behalf of service providers.
-
June 21, 2024
Next UK Gov't Urged To Ease Private Healthcare Insurance Tax
Whoever wins the U.K. election on July 4 should introduce tax breaks on private medical insurance to relieve pressure on the National Health Service, a consultancy warned Friday.
-
June 20, 2024
German Court Convicts 5 In €52M VAT Fraud In Cars, Masks
Five people who played roles in a value-added tax fraud scheme involving the trade of luxury cars and medical face masks that caused over €52 million ($55.7 million) in losses were convicted by a Berlin court, the European Public Prosecutor's Office announced Thursday.
-
June 20, 2024
EU Court Rejects Co.'s Portuguese Tax Breaks Appeal
An appeal contesting a European Commission decision against a Portuguese tax exemption scheme was rejected by the European General Court, which found a Panama-based food company unable to prove why recovering the illegal state aid should be prohibited.
-
June 20, 2024
China Denies Tax Crackdown As 2 Cos. Report $80M In Bills
China's tax authority denied a nationwide crackdown on companies' old tax returns Thursday, less than a week after a chemical firm facing 500 million yuan ($69 million) in additional liabilities halted production and a beverage maker reported owing 85 million yuan.
-
June 20, 2024
UK Tax Pros Largely Support 2027 Carbon Border Tax Plan
Two groups representing tax professionals welcomed the U.K. government's plan to introduce a carbon border tax on certain carbon-intensive imports by 2027, but specifics regarding both default embedded emissions values and carveouts for smaller businesses must be ironed out, they said.
-
June 20, 2024
Norway's $95M Yearly Dividend Tax Losses Spur Joint Audit
Norway's tax agency announced a joint audit with other Nordic tax agencies, saying it loses an estimated 1 billion kroner ($95 million) a year in withholding taxes that should be paid by foreign shareholders on dividends but aren't due to aggressive tax planning.
-
June 20, 2024
Canada Lawmakers OK Digital Tax, Advance Min. Tax
Canada's Senate passed a 3% digital services tax that would target the revenue of large technology companies, following through on a plan that has drawn criticism from the U.S. and groups representing American tech giants.
-
June 20, 2024
UK Tax Gap Continues Downward Trend, HMRC Says
The U.K. has continued to shrink its estimated tax gap, reaching a new low of 4.8% in the 2022-2023 tax year, following a trend of decreases over the past almost two decades, HM Revenue & Customs said Thursday.
-
June 20, 2024
G20 Should Not Give Up On Pillar 1, Gentiloni Says
The Group of 20 rich and developing countries should not give up on the Pillar One agreement to reallocate corporate taxing rights globally, European Union tax commissioner Paolo Gentiloni said Thursday, pointing to a G20 summit in November as crucial.
-
June 20, 2024
EU Adopts Sanctions On Russian LNG, Oil Tanker Fleet
The European Union agreed in principle Thursday on the 14th economic sanctions package against Russia since its war against Ukraine began, targeting liquefied natural gas, dual-use goods and technologies, and a fleet of oil tankers from non-EU countries.
-
June 20, 2024
Repatriation Tax Doesn't Violate Constitution, Justices Rule
The U.S. Supreme Court upheld the 2017 federal tax overhaul's mandatory repatriation levy on Thursday, finding the measure applies to the earnings of foreign corporations with U.S. shareholders and therefore does not raise constitutional questions about taxing unrealized income.
-
June 20, 2024
German Casino Tax Regime Is Illegal State Aid, EU Says
Germany's special tax system for public casino operators violates the European Union's law on state aid law, the bloc's executive branch and treaty regulator said on Thursday.
-
June 19, 2024
EU Commission Tells France, Italy To Lower Budget Deficits
The European Commission told France, Italy and six other European Union countries to rein in their big budget deficits on Wednesday, although their governments can decide themselves on the details of spending cuts and tax hikes.
-
June 19, 2024
Problems With VAT Law Still Not Resolved, Estonia Says
Estonia said Wednesday that it continues to have concerns about a proposed change to the European Union's value added tax law, which the small northeastern European country said would hurt small businesses.
-
June 18, 2024
IRS Guidance Doesn't Perceive Spinoff Abuse, Official Says
Recent IRS guidance limiting the corporate spinoffs that revenue officials will approve as tax-free ahead of time was designed to reflect the drafters' current views, rather than suggest perceived abuse of these transactions, a U.S. Treasury Department official said Tuesday.
Expert Analysis
-
This Earth Day, Consider How Your Firm Can Go Greener
As Earth Day approaches, law firms and attorneys should consider adopting more sustainable practices to reduce their carbon footprint — from minimizing single-use plastics to purchasing carbon offsets for air travel — which ultimately can also reduce costs for clients, say M’Lynn Phillips and Lisa Walters at IMS Legal Strategies.
-
Cum-Ex Prosecutions Storm Shows No Sign Of Abating
The ongoing trial of Sanjay Shah in Denmark is a clear indicator that efforts remain focused on holding to account the alleged architects and beneficiaries of cum-ex trading, and with these prosecutions making their way across Europe, it is a more turbulent time now than ever, says Niall Hearty at Rahman Ravelli.
-
Practicing Law With Parkinson's Disease
This Parkinson’s Awareness Month, Adam Siegler at Greenberg Traurig discusses his experience working as a lawyer with Parkinson’s disease, sharing both lessons on how to cope with a diagnosis and advice for supporting colleagues who live with the disease.
-
Why Supreme Court Should Allow Repatriation Tax To Stand
If the U.S. Supreme Court doesn't reject the taxpayers' misguided claims in Moore v. U.S. that the mandatory repatriation tax is unconstitutional, it could wreak havoc on our system of taxation and result in a catastrophic loss of revenue for the government, say Christina Mason and Theresa Balducci at Herrick Feinstein.
-
For Lawyers, Pessimism Should Be A Job Skill, Not A Life Skill
A pessimistic mindset allows attorneys to be effective advocates for their clients, but it can come with serious costs for their personal well-being, so it’s crucial to exercise strategies that produce flexible optimism and connect lawyers with their core values, says Krista Larson at Stinson.
-
Requiring Leave To File Amicus Briefs Is A Bad Idea
A proposal to amend the Federal Rules of Appellate Procedure that would require parties to get court permission before filing federal amicus briefs would eliminate the long-standing practice of consent filing and thereby make the process less open and democratic, says Lawrence Ebner at the Atlantic Legal Foundation and DRI Center.
-
4 Ways To Motivate Junior Attorneys To Bring Their Best
As Gen Z and younger millennial attorneys increasingly express dissatisfaction with their work and head for the exits, the lawyers who manage them must understand and attend to their needs and priorities to boost engagement and increase retention, says Stacey Schwartz at Katten.
-
Former Minn. Chief Justice Instructs On Writing Better Briefs
Former Minnesota Supreme Court Chief Justice Lorie Gildea, now at Greenberg Traurig, offers strategies on writing more effective appellate briefs from her time on the bench.
-
Stay Interviews Are Key To Retaining Legal Talent
Even as the economy shifts and layoffs continue, law firms still want to retain their top attorneys, and so-called stay interviews — informal conversations with employees to identify potential issues before they lead to turnover — can be a crucial tool for improving retention and morale, say Tina Cohen Nicol and Kate Reder Sheikh at Major Lindsey.
-
Neb. Justices Should Weigh IRC Terms In Dividend Tax Case
Nebraska’s highest court, which will hear oral arguments in Precision CastParts v. Department of Revenue on April 1, should recognize that the Internal Revenue Code provides key clues to defining “dividends received or deemed to be received,” and therefore limits Nebraska’s tax on foreign-sourced corporate income, says Joseph Schmidt at Ryan.
-
Judicial Independence Is Imperative This Election Year
As the next election nears, the judges involved in the upcoming trials against former President Donald Trump increasingly face political pressures and threats of violence — revealing the urgent need to safeguard judicial independence and uphold the rule of law, says Benes Aldana at the National Judicial College.
-
Spartan Arbitration Tactics Against Well-Funded Opponents
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
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.