International
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January 02, 2025
Japanese Cabinet Approves Backstop To 15% Min. Tax
Japan's Cabinet approved a backstop to its 15% global minimum tax that would enable authorities to collect on multinational corporations' profits in foreign jurisdictions taxed below the minimum rate, according to the country's Ministry of Finance.
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January 02, 2025
Republicans Want Yellen To Answer For Chinese Cyberattack
Congressional Republicans want U.S. Treasury Secretary Janet Yellen to explain how a Chinese state-sponsored entity hacked into Treasury's computer systems and accessed potentially sensitive information.
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January 02, 2025
NJ Residents Freed Of $2.1M Tax Bill On Repatriated Income
Two New Jersey residents don't owe state tax on income repatriated under the 2017 federal tax overhaul, the state's tax court ruled, saying New Jersey's personal income tax laws don't include deemed dividends as a category of taxable income.
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January 02, 2025
Feds Ask High Court To Unpause Corporate Transparency Law
The federal government is asking the U.S. Supreme Court to lift a Texas judge's injunction against the Corporate Transparency Act, telling the justices in a new application that the 2021 anti-money laundering law's compliance deadlines should take effect while the Fifth Circuit hears the full case.
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January 02, 2025
IRS, Treasury Float Regs On Excise Taxes For Drugmakers
The IRS and Treasury proposed rules for charging excise taxes to drugmakers that refuse to negotiate drug prices with Medicare under requirements of the 2022 tax and climate law, saying the tax only would apply to manufacturers and importers that initially sell the drugs.
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January 02, 2025
Consolidated Return Regs Revised With Gender-Neutral Terms
The IRS and Treasury finalized rules for companies that file consolidated federal income tax returns, saying the new regulations provide needed modernizations to terminology, including removing gender-specific pronouns.
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January 01, 2025
US International Tax Issues to Watch In 2025
As President-elect Donald Trump and Republicans take control of the U.S. government in 2025, policymakers are expected to address changing international provisions in the Internal Revenue Code and reevaluate the country's role in global tax talks. Here, Law360 examines key U.S. international tax policy issues to watch in the new year.
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January 01, 2025
Federal Tax Policy To Watch In 2025
While Republicans will hold majorities in both chambers of Congress in 2025, internal party divisions and procedural hurdles could complicate the GOP's effort to renew its 2017 tax overhaul law. Here, Law360 details federal tax policy to watch this year.
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January 01, 2025
Top International Tax Cases To Watch In 2025
Major multinational corporations such as 3M and Coca-Cola will continue to litigate high-stakes international tax cases during 2025, including transfer pricing disputes with billions of dollars on the line and fights against regulations that allegedly exceed the government's authority. Here, Law360 looks at six key international tax cases to follow in the new year.
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January 01, 2025
European Tax Policy To Watch In 2025
The European Union may have to go it alone on international tax policy in 2025, especially because President-elect Donald Trump's return to power means the U.S. will likely oppose any multilateral solution to taxing the digital economy. Here, Law360 looks at important European tax developments to watch for this year.
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January 01, 2025
Top Federal Tax Cases To Watch In 2025
Over the next year, tax practitioners will be closely monitoring suits that challenge the IRS' use of the economic substance doctrine, take advantage of the U.S. Supreme Court's landmark decision curbing federal agencies' regulatory authority and dispute the government's handling of worker retention credits. Here, Law360 looks at key federal tax cases to follow in 2025.
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December 23, 2024
Anti-Laundering Law Is Likely Constitutional, 5th Circ. Rules
The Fifth Circuit on Monday lifted a lower court's nationwide block of a federal corporate transparency law, ruling in an unpublished order that the federal government made a "strong showing" that it could successfully defend the law's constitutionality.
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December 20, 2024
Utah Judge Pauses Challenge To Corporate Transparency Act
A Utah federal judge has stayed a case seeking to block the Corporate Transparency Act to see how the new administration of President-elect Donald Trump handles the law after a kindred case in Texas won a preliminary injunction on it.
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December 20, 2024
Rules On Earnings, Profits Still Being Vetted, IRS Official Says
Recently proposed rules for previously taxed earnings and profits aren't able to be relied on by taxpayers until they are finalized because they contain new approaches that have to be properly vetted through a notice and comment period, an IRS official said Friday.
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December 20, 2024
Top Federal Tax Decisions Of 2024
Over the past year, federal courts have issued decisions further delimiting the power of the Internal Revenue Service, with the First Circuit affirming a decision to allow agency summonses for cryptocurrency account records and an Arizona federal court rejecting a call to lift the agency's moratorium on processing pandemic-era worker credits. Here, Law360 reviews some of the most significant federal tax decisions of 2024.
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December 20, 2024
Digital Taxes In Flux Amid Renewed US Tariff Threats
Governments around the world revisited their approaches to digital services taxes this year by adopting broader versions, raising rates, carving out industries and analyzing the impacts of adopting unilateral measures as threats of U.S. tariffs materialize once again. Here, Law360 looks at how countries around the world are considering, adopting or changing their DSTs.
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December 20, 2024
Osborne Clarke Pro Fined £50K Over Zahawi Libel Letter
A tribunal fined an Osborne Clarke LLP partner who represented Nadhim Zahawi £50,000 ($62,700) on Friday for trying to stop a blogger revealing that the former chancellor was contemplating libel action over allegations of dishonesty in his tax affairs.
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December 19, 2024
Atty Exits Denmark's $2.1B Tax Fraud Case After Settlement
A New York federal court removed an attorney from a $2.1 billion tax fraud suit after Denmark's tax authority settled with him on his involvement in the matter, according to recent filings.
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December 19, 2024
Denmark Says $500M Recovered In Dividend Tax Fraud Suits
Denmark's tax administration has recovered a total of 3.6 billion Danish kroner ($500 million) in money lost to suspected dividend tax refund fraud after entering settlements of civil cases in several countries in 2024, Denmark's tax minister announced.
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December 19, 2024
5th Circ. Urged To Deny Tax Break For Doc's Captive Insurance
A physician who owns a network of urgent care clinics was correctly denied tax deductions along with his wife for over $1 million in premiums they paid to insurance companies they owned, the government told the Fifth Circuit, saying the captive arrangements didn't qualify as insurance for tax purposes.
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December 19, 2024
UK Adds Pillar 2 Backstop To Finance Bill
The U.K. government introduced amendments to its latest finance bill Thursday that would update its Pillar Two global minimum tax system and add the backstop to the regime known as the undertaxed profits rule.
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December 18, 2024
Skat Fights To Bring New Cum-Ex Fraud Case Against Broker
The Danish tax authority argued at a London appeals court on Wednesday that it should not be blocked from bringing fresh tax fraud claims against an English brokerage, contending that the claims cover new material not already decided in earlier proceedings.
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December 18, 2024
Morrison Foerster Cites Tariffs As Key M&A Variable For 2025
International law firm Morrison Foerster LLP is among those citing President-elect Donald Trump's tariff plans as a key wild card that could affect mergers and acquisitions deal flow in 2025, a Wednesday report from the firm shows.
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December 18, 2024
Dutch Bank Exec Gave IRS Good Tax Tip, DC Circ. Judge Says
D.C. Circuit judges grappled Wednesday with the denial of a whistleblower award to a late Dutch bank executive who tipped off the IRS to tax reporting schemes, with one judge saying during oral arguments that the executive appeared to have handed the agency "gift-wrapped" evidence of wrongdoing.
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December 18, 2024
EU Court Rejects Latest Challenge To Portugal's Tax Clawback
A European court rejected a Brazilian-based company's challenge Wednesday to a European Commission ruling that Portugal must claw back tax breaks provided to companies with no local economic activity because that ran counter to commission-approved policies.
Expert Analysis
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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.
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Lessons From Country Singer's Personal Service Saga
Recent reports that country singer Luke Combs won a judgment against a Florida woman who didn’t receive notice of the counterfeit suit against her should serve as a reminder for attorneys on best practices for effectuating service by electronic means, say attorneys at Jenner & Block.