International
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September 11, 2024
Latham Hires Senior Tax Pro From Travers Smith In London
Latham & Watkins LLP said on Wednesday that it has recruited a former head of tax at Travers Smith LLP for its office in London, a blow for the U.K. law firm, which has been hit by the departure of a series of partners.
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September 11, 2024
European Commission Urged To Review Tax Laws
The European Commission, the executive branch of the European Union, should analyze its tax regulations to help avoid overlap and potential over-regulation, a body representing tax professionals has said.
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September 10, 2024
Wealthiest 0.01% Had 34% Average Tax Rate, JCT Says
The income group constituting the top 0.01% wealthiest individuals had an average federal tax rate of 34% in 2019, the Joint Committee on Taxation said in a report on high-income and high-wealth taxpayers.
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September 10, 2024
UK Court OKs Nix Of Partners' Tax Deduction For Amortization
A lower court was correct in ruling that a trio of U.K. entities that formed a limited liability partnership cannot take a tax deduction for the amortization of intangible assets they contributed to the LLP against their share of the profits, the Upper Tribunal ruled.
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September 10, 2024
UK's Capital Gains Tax Should Mirror Labor Rate, Report Says
Capital gains tax changes should be a key part of the United Kingdom government's October budget statement, a leading British think tank said Tuesday, recommending that the government equalize capital gains tax with the dividend tax and income tax.
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September 10, 2024
State Pension Likely To Rise 4% Under Triple Lock
The U.K. government is likely to push through an inflation-busting increase to the state pension of approximately £460 ($600) a year from April, after official figures revealed on Tuesday a rise in average earnings.
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September 10, 2024
Apple Illegally Obtained €13B In State Aid, Top EU Court Rules
The European Union's highest court ruled on Tuesday that Ireland illegally granted Apple state aid in past tax rulings, requiring the U.S. technology giant to repay €13 billion ($14.3 billion) in back taxes as well as interest.
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September 09, 2024
Russia Says DC Circ. Ruling Erodes $5B Award To Yukos
A recent D.C. Circuit ruling that Spain must comply with $395 million in arbitration awards awarded to Yukos Oil's financing arm undermines the company's $5 billion claim against Russia because the country, unlike Spain, never ratified the international treaty on which the court relied, Russia has told a D.C. federal court.
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September 09, 2024
Tax Court's Take Shouldn't Loom Over Kyocera Case, US Says
The U.S. Tax Court's opinion that allowed a company to treat a gross-up for taxes paid by its foreign subsidiaries as a dividend received goes against what Congress intended and shouldn't be applied to Kyocera's similar claims, the U.S. Department of Justice told a South Carolina federal court.
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September 09, 2024
Bradley Arant Adds Katten Partner In Dallas
Bradley Arant has hired a six-and-a-half-year veteran of Katten Muchin Rosenman LLP who is joining the firm's corporate and securities practice in Dallas as a partner.
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September 09, 2024
Australia, Slovenia Reach Deal On Double-Tax Treaty
Australia and Slovenia have agreed to a treaty to prevent double taxation between the two countries, which would come into force after approval by both countries' legislatures, Australia's Treasury said Monday.
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September 09, 2024
EU Should Loosen Merger Rules To Compete, Report Says
The European Union should loosen its merger rules and reform trade policy and the energy market in order to boost EU competitiveness enough to catch up with the U.S. and China, a former European Central Bank president reported Monday.
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September 09, 2024
Tax Compliance Costs Keeps EU Firms Small, Report Says
The high cost of tax compliance and the challenges presented by differing regulatory environments encourage European companies to stay small, potentially harming the European Union's competitiveness, according to a report by a former European Central Bank head published on Monday.
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September 09, 2024
HMRC Fails To Nab £4B In Small-Biz Tax Evasion, Report Says
HM Revenue & Customs has failed to stop small businesses from dodging more than £4.4 billion ($5.8 billion) in taxes because it lacks a focused strategy to tackle different tax evasion schemes, the U.K.'s National Audit Office reported Monday.
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September 06, 2024
Federal Tax Policies To Watch In The Rest Of The Year
As Congress returns to Washington, D.C., after the August recess, proposals including disaster tax relief and an agreement to provide tax treaty-like benefits to Taiwanese residents could be readied to be included in year-end legislation. Here, Law360 examines federal tax policies to watch during the last four months of 2024.
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September 06, 2024
FDII Covers Overseas Services For US Gov't, Memo Says
Government contractors that provide services to U.S. operations overseas are allowed to claim the deduction for foreign-derived intangible income, the IRS said in one of two internal memos released Friday that address foreign income issues.
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September 06, 2024
Broaden Tax Bases For Cleaner Energy Transition, EU Says
The impact on government revenues from the transition to cleaner energy, including diminishing fossil fuel tax receipts and increased spending on subsidies supporting green technology, necessitates that countries develop broader tax bases, the European Commission said.
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September 06, 2024
4 Key Complications 3 Years After Pillar 2
Three years ago, countries around the world outlined an agreed-upon minimum corporate tax system in an eight-page document that couldn't have foreseen the full scope of complications that later emerged during implementation, including frictions with existing tax laws. Here, Law360 looks at four key issues that countries and multinational corporations are grappling with as Pillar Two turns three.
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September 06, 2024
China Complains To WTO About Canada EV Surtaxes
China is looking for the World Trade Organization to step in to address proposed Canadian surtaxes on imported Chinese electric vehicles, steel and aluminum, taxes that a spokesperson for China's Ministry of Commerce said Friday violate the organization's rules.
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September 06, 2024
Taxation With Representation: Debevoise, Bennett, Orrick
In this week's Taxation With Representation, Verizon reaches a deal to absorb Frontier in a deal worth $20 billion, First Majestic agrees to buy Gatos Silver for $970 million, and Epam Systems inks a $630 million purchase of Neoris.
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September 06, 2024
Vialto Partners Member Joins Baker McKenzie As Partner
Baker McKenzie has hired a tax partner in Washington, D.C., from Vialto Partners, a business consulting firm, the firm announced Thursday.
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September 06, 2024
EU Should Align Disclosure Standards, Industry Group Says
The European Union should align its forthcoming public tax reporting rules with the same systems in use under the Organization for Economic Cooperation and Development's non-public reporting system, the American Chamber of Commerce in the EU said.
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September 05, 2024
Unconstitutionality Of Transparency Act Clear, 11th Circ. Told
A small business group and one of its members have told the Eleventh Circuit that an Alabama federal judge correctly ruled that the Corporate Transparency Act is unconstitutional, so there was no need for them to demonstrate that the law fails to pass constitutional muster.
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September 05, 2024
Liberty Global Urges 10th Circ. To Grant $248M Tax Credit
The U.S. Tax Court improperly applied an Internal Revenue Code provision to some of the $2.8 billion gain from Liberty Global's sale of a Japanese entity, the telecommunications company said in urging the Tenth Circuit to overturn the resulting rejection of a $248 million tax credit.
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September 05, 2024
Holland & Knight Appoints Former Perkins Coie Tax Partner
Holland & Knight LLP appointed a partner to its Portland, Oregon, office who previously served as a partner in energy tax law for Perkins Coie LLP, the firm announced.
Expert Analysis
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7 Common Myths About Lateral Partner Moves
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.
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6 Pointers For Attys To Build Trust, Credibility On Social Media
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.
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US-Chile Tax Treaty May Encourage Cross-Border Investment
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.
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A Post-Mortem Analysis Of Stroock's Demise
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.
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SG's Office Is Case Study To Help Close Legal Gender Gap
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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Reimagining Law Firm Culture To Break The Cycle Of Burnout
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.
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Cayman Islands Off AML Risk Lists, Signaling Robust Controls
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.
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The Legal Industry Needs A Cybersecurity Paradigm Shift
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.
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As Promised, IRS Is Coming For Crypto Tax Evaders
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.
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5 Reasons Associates Shouldn't Take A Job Just For Money
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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The Pop Culture Docket: Judge Djerassi On Super Bowl 52
Philadelphia Court of Common Pleas Judge Ramy Djerassi discusses how Super Bowl 52, in which the Philadelphia Eagles prevailed over the New England Patriots, provides an apt metaphor for alternative dispute resolution processes in commercial business cases.
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Employee Experience Strategy Can Boost Law Firm Success
Amid continuing business uncertainty, law firms should consider adopting a holistic employee experience strategy — prioritizing consistency, targeting signature moments and leveraging measurement tools — to maximize productivity and profitability, says Haley Revel at Calibrate Consulting.
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6 Practice Pointers For Pro Bono Immigration Practice
An attorney taking on their first pro bono immigration matter may find the law and procedures beguiling, but understanding key deadlines, the significance of individual immigration judges' rules and specialized aspects of the practice can help avoid common missteps, says Steven Malm at Haynes Boone.