International

  • July 12, 2024

    Switzerland, Hungary Adding Anti-Abuse Clause To Tax Treaty

    Switzerland and Hungary moved on Friday to add to their double-taxation treaty an anti-abuse clause that prevents a person who is not a resident of either country from claiming the benefits of the treaty.

  • July 12, 2024

    European Tax Policy To Watch In The Second Half Of 2024

    Observers of European Union tax policy expect the EU to devote more attention to problems with existing tax legislation in the coming months as the introduction of major policy proposals takes a pause. Specialists also will be watching for progress on EU tax laws that remain stuck, and the bloc is likely to fill roles including tax commissioner. Here, Law360 examines key tax issues to watch for the remaining six months of the year.

  • July 12, 2024

    Taxation With Representation: Ropes & Gray, Cravath, Latham

    In this Week's Taxation with Representation, Paramount Global merges with Skydance Media, Devon Energy acquires Grayson Mill Energy's Williston Basin oil and gas business, Ryan acquires Altus Group Ltd.'s property tax business, and Bain Capital buys Envestnet Inc.

  • July 12, 2024

    Worried Companies Ask For Pillar 2 Simplification

    Multinational corporations are worried about what they see as the huge compliance burden imposed by the global 15% minimum tax and are asking for permanent simplifications of the rules, two corporate tax officials said Friday.

  • July 12, 2024

    Alvarez & Marsal Appoints Managing Director Of Tax Group

    Alvarez & Marsal Tax LLC appointed an experienced negotiator of tax incentives as managing director to the firm's corporate transformation tax group, the firm announced.

  • July 12, 2024

    EU Chair Doesn't Expect Energy Tax Deal This Year

    The new chair of European Union finance ministers doesn't expect to reach agreement on a landmark energy taxation law in the next half-year, anticipating only exploratory talks, an official from Hungary's EU presidency said Friday.

  • July 11, 2024

    House GOP Urges USTR To Probe Canada Digital Services Tax

    The U.S. trade representative should immediately launch an investigation into Canada's recently enacted digital services tax and determine if trade actions are necessary to protect American interests, U.S. House Ways and Means Republicans said in a letter Thursday.

  • July 11, 2024

    ABA Attys Seek To Avoid Reporting Foreign Trust Loans

    The American Bar Association's tax, real estate and trust attorneys are seeking to prevent the U.S. Treasury Department from tightening reporting requirements for the exemption of loans from foreign trusts, which are often used by wealthy families and in succession planning, according to a consultation response.

  • July 11, 2024

    Brazilian Tax Agency Probes Refund Fraud Scheme

    Brazilian federal tax authorities and police said Thursday they had conducted a search-and-seizure operation related to the investigation of an income tax refund fraud scheme.

  • July 11, 2024

    Ex-Leaders Ask Biden For Int'l Coordination On Billionaire Tax

    President Joe Biden should get behind Brazil's proposal for the Group of 20 nations to coordinate a minimum tax on billionaires, nearly 20 former presidents and prime ministers from countries such as Canada, France and South Korea said in an open letter.

  • July 11, 2024

    IRS Proposes 'Basket Contracts' As Listed Transactions

    The Internal Revenue Service proposed rules Thursday that would flag so-called basket option contracts as potentially abusive listed transactions, imposing additional reporting requirements under the threat of penalty for individuals and businesses involved in such arrangements.

  • July 11, 2024

    IRS, OECD Officials Detail Expansion Of AI In Tax Work

    The Internal Revenue Service and Organization for Economic Cooperation and Development are making great progress in adopting artificial intelligence in tax administration, representatives of both organizations said Thursday.

  • July 11, 2024

    Israel Says Resident Hid $5.5M In Offshore Bank Accounts

    An Israeli resident was released under restrictive conditions Thursday after the government alleged he failed to report foreign bank accounts that held more than 20 million shekels ($5.5 million), according to a statement from the Israel Tax Authority.

  • July 11, 2024

    Tax Haven Biz Revenues Per Worker Still Far Outpace Norm

    Companies recorded median revenues per employee of $1.6 million in low-tax jurisdictions like Ireland, the Cayman Islands and Hong Kong and around $300,000 in all other jurisdictions in 2021, a difference that has narrowed since 2017, the OECD said Thursday.

  • July 11, 2024

    Biz Officials Call For Simpler Tax Rules In Light Of Pillar 2

    Business representatives said Thursday that tax compliance rules need to be simplified as new minimum tax rules, known as Pillar Two, are added to the existing regime.

  • July 11, 2024

    Failure Of Pillar 1 Would Yield Worse Alternatives, Panel Says

    A failure of the Pillar One agreement to reallocate corporate taxing rights would lead to alternatives that are worse, with the return of national digital services taxes worldwide, tax officials and academics said Thursday.

  • July 10, 2024

    Engineer Who Faced Export Charges Cops To Tax Counts

    A Chinese-born engineer has pled guilty to two counts of filing a false tax return related to allegations that he and his wife omitted gross income from their tax returns between 2015 and 2019, after Texas federal prosecutors initially charged the couple with export violations and fraud. 

  • July 10, 2024

    Portugal Enacts Pillar 2 As Part Of Economic, Tax Package

    Portugal's Council of Ministers approved the minimum tax provision known as Pillar Two in a package of economic and tax measures designed to boost the country's economic growth, the council announced.

  • July 10, 2024

    OECD Publishes Pillar 2 Technical Reporting Language Draft

    The Organization for Economic Cooperation and Development published a draft of technical details required to digitally input and disseminate information required for Pillar Two global minimum tax returns Wednesday.

  • July 10, 2024

    Americans Overseas Ask for Clarity In Foreign Trust Regs

    An advocacy group representing U.S. citizens living abroad urged the U.S. Treasury Department to clarify proposed rules for reporting transactions with foreign trusts, contending that guidance should explain which common pension arrangements are exempt from disclosure obligations.  

  • July 10, 2024

    Curtis Mallet-Prevost To Open Law Office In Saudi Arabia

    Curtis Mallet-Prevost Colt & Mosle LLP has obtained a license to practice law in the Kingdom of Saudi Arabia, the firm announced this week.

  • July 10, 2024

    HMRC, CPS Beat Financier's Claim Over Botched Prosecution

    HM Revenue and Customs and the Crown Prosecution Service have beaten claims of malicious prosecution and misfeasance in public office by a corporate financier following a failed criminal fraud case, with a judge finding that they had enough evidence to pursue him.

  • July 10, 2024

    French Left's Tax Pledges May Go Unfulfilled

    The tax policy pledges put forward by the leftist bloc of parties that won the most seats in France's legislative election may not be fulfilled given the bloc's failure to win an outright majority.

  • July 10, 2024

    India's High Court Nixes Challenge To Taxing Of Tour Vehicles

    The Indian Supreme Court dismissed a group of petitions challenging border taxes imposed by state governments on tour company vehicles because it said the litigation should have begun in a different court.

  • July 10, 2024

    Attempts To Scrap EU Tax Veto Are Useless, Hungary Says

    Attempts by European Union countries to try to remove the requirement of unanimity for delicate policy decisions such as tax law and adding new EU member states are futile, Hungary's minister for European affairs said Wednesday.

Expert Analysis

  • Understanding Discovery Obligations In Era Of Generative AI

    Excerpt from Practical Guidance
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    Attorneys and businesses must adapt to the unique discovery challenges presented by generative artificial intelligence, such as chatbot content and prompts, while upholding the principles of fairness, transparency and compliance with legal obligations in federal civil litigation, say attorneys at King & Spalding.

  • The Case For Post-Bar Clerk Training Programs At Law Firms

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    In today's competitive legal hiring market, an intentionally designed training program for law school graduates awaiting bar admission can be an effective way of creating a pipeline of qualified candidates, says Brent Daub at Gilson Daub.

  • AI Can Help Lawyers Overcome The Programming Barrier

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    Legal professionals without programming expertise can use generative artificial intelligence to harness the power of automation and other technology solutions to streamline their work, without the steep learning curve traditionally associated with coding, says George Zalepa at Greenberg Traurig.

  • Preparing Law Students For A New, AI-Assisted Legal World

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    As artificial intelligence rapidly transforms the legal landscape, law schools must integrate technology and curricula that address AI’s innate challenges — from ethics to data security — to help students stay ahead of the curve, say Daniel Garrie at Law & Forensics, Ryan Abbott at JAMS and Karen Silverman at Cantellus Group.

  • General Counsel Need Data Literacy To Keep Up With AI

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    With the rise of accessible and powerful generative artificial intelligence solutions, it is imperative for general counsel to understand the use and application of data for myriad important activities, from evaluating the e-discovery process to monitoring compliance analytics and more, says Colin Levy at Malbek.

  • Navigating Discovery Of Generative AI Information

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    As generative artificial intelligence tools become increasingly ubiquitous, companies must make sure to preserve generative AI data when there is reasonable expectation of litigation, and to include transcripts in litigation hold notices, as they may be relevant to discovery requests, say Nick Peterson and Corey Hauser at Wiley.

  • Finding Focus: Strategies For Attorneys With ADHD

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    Given the prevalence of ADHD among attorneys, it is imperative that the legal community gain a better understanding of how ADHD affects well-being, and that resources and strategies exist for attorneys with this disability to manage their symptoms and achieve success, say Casey Dixon at Dixon Life Coaching and Krista Larson at Stinson.

  • Attorneys, Law Schools Must Adapt To New Era Of Evidence

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    Technological advancements mean more direct evidence is being created than ever before, and attorneys as well as law schools must modify their methods to account for new challenges in how this evidence is collected and used to try cases, says Reuben Guttman at Guttman Buschner.

  • 1st Tax Easement Convictions Will Likely Embolden DOJ, IRS

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    After recent convictions in the first criminal tax fraud trial over allegedly abusive syndicated conservation easements, the IRS and U.S. Department of Justice will likely pursue other promoters for similar alleged conspiracies — though one acquittal may help attorneys better evaluate their clients' exposure, say Bill Curtis and Lauren DeSantis-Then at Polsinelli.

  • Tips For Litigating Against Pro Se Parties In Complex Disputes

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    Litigating against self-represented parties in complex cases can pose unique challenges for attorneys, but for the most part, it requires the same skills that are useful in other cases — from documenting everything to understanding one’s ethical duties, says Bryan Ketroser at Alto Litigation.

  • Anticipating Intensified Partnership Enforcement From IRS

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    The Internal Revenue Service's decadeslong difficulties with partnership audits led to the recent announcement of a clear, well-funded, focused initiative, and businesses operating in the partnership form will feel the impact, with definite changes ahead, says Sharon Katz-Pearlman at Greenberg Traurig.

  • Pro Bono Work Is Powerful Self-Help For Attorneys

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    Oct. 22-28 is Pro Bono Week, serving as a useful reminder that offering free legal help to the public can help attorneys expand their legal toolbox, forge community relationships and create human connections, despite the challenges of this kind of work, says Orlando Lopez at Culhane Meadows.

  • The Pop Culture Docket: Judge Espinosa On 'Lincoln Lawyer'

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    The murder trials in Netflix’s “The Lincoln Lawyer” illustrate the stark contrast between the ethical high ground that fosters and maintains the criminal justice system's integrity, and the ethical abyss that can undermine it, with an important reminder for all legal practitioners, say Judge Adam Espinosa and Andrew Howard at the Colorado 2nd Judicial District Court.

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