International

  • January 13, 2025

    PepsiCo Created Shell Co. To Avoid Taxes, Ill. Court Says

    PepsiCo operated a shell company as part of a scheme that resulted in its Illinois income tax bill for its Frito-Lay unit being deficient nearly $10.9 million, a state circuit court ruled.

  • January 13, 2025

    AGs, Lobbyists Ask Justices To Keep Shell Co. Law Blocked

    The U.S. Supreme Court should deny the federal government's emergency application to stay a Texas district court's injunction on a law aimed at cracking down on crimes committed with shell companies, according to numerous state attorneys general and interest groups and a handful of small businesses.

  • January 13, 2025

    Tax Firm Asks Court To Ax Final IRS Microcaptive Rules

    A global tax services provider asked a Texas federal court to vacate finalized tax rules requiring the reporting of certain transactions involving captive insurance companies deemed as potentially abusive, arguing the guidance goes beyond the agency's authority.

  • January 13, 2025

    Sen. Warren To Grill Treasury Pick On Trump's Tax Agenda

    Sen. Elizabeth Warren, D-Mass., plans to ask Treasury secretary nominee Scott Bessent at his confirmation hearing in front of the Senate Finance Committee on Thursday about President-elect Donald Trump's tax agenda and plans for the Internal Revenue Service, according to a letter she sent the nominee.

  • January 13, 2025

    The Tax Angle: GOP Lawmakers Grapple With TCJA Renewal

    From a look at Congress setting parameters for consideration of legislation to renew the GOP's 2017 tax overhaul law to other upcoming tax action in the House and Senate, here's a peek into a reporter's notebook on a few of the week's developing tax stories.

  • January 13, 2025

    Norway Seeking Comments On Shareholder Register Plans

    The Norway Tax Administration is looking for public comments on plans to introduce a shareholder register that it said would provide authorities with important ownership information, laying out four options for consideration but highlighting its preferred one, it said Monday.

  • January 13, 2025

    Pillar 2's Effect May Vary Based On Biz Function, Report Says

    The global minimum tax deal known as Pillar Two may have a minimal effect on where multinational corporations carry out routine business functions, but companies could eventually change where they perform other operations, according to an OECD paper released Monday.

  • January 13, 2025

    Still No Unanimous Path Forward On Amount B, OECD Says

    The Organization for Economic Cooperation and Development has still not found a path to an agreement on Pillar One's Amount B, which is designed to streamline the pricing of certain baseline marketing and distribution activities, with conversations being held up by possible "inappropriate outcomes," the OECD said Monday.

  • January 13, 2025

    Tax Hikes Hit Business Confidence, UK Industry Chair Says

    The Labour government's decision to raise payroll taxes on employers in last year's budget has hurt business confidence, the chair of an influential British industry group said Monday.

  • January 10, 2025

    Treasury Finalizes Rules For Disregarded Foreign Payments

    The U.S. Treasury Department issued final regulations Friday that are designed to prevent companies from receiving foreign payments in a way that allows them to reduce their overseas taxes without a corresponding increase in U.S. taxable income.

  • January 10, 2025

    Ga. Law Firm Latest To Fight Corporate Transparency Act

    A federal law designed to combat money laundering violates the U.S. Constitution by forcing lawyers to disregard attorney-client privilege, a Georgia lawyer told a federal court, joining a chorus seeking legal action to stop the law.

  • January 10, 2025

    IRS Finalizes Regulations For Taxing Gifts From Expats

    The Internal Revenue Service issued final regulations and guidance Friday for a 2008 tax on gifts and bequests made by current or former U.S. citizens living abroad to U.S. citizens or residents, including through foreign trusts.

  • January 10, 2025

    IRS OKs New Test For Classifying Digital, Cloud Transactions

    Transactions involving digital content and cloud computing will be classified using a new predominant character test, according to final rules issued Friday by the Internal Revenue Service and the U.S. Department of the Treasury.

  • January 10, 2025

    Taxation With Representation: Kirkland, Davis Polk, Wachtell

    In this week's Taxation With Representation, Constellation acquires Calpine, Cintas seeks a deal with UniFirst Corp., Stryker Corp. acquires Inari Medical Inc., and Paychex Inc. buys Paycor.

  • January 10, 2025

    Group Busted For Dodging $3.6M In Corp. Tax, Poland Says

    Poland's tax authority said Friday that it had identified an organized crime group that used several companies as fronts to make transactions that avoided 15 million złoty ($3.6 million) in corporate tax.

  • January 10, 2025

    Senate Finance Panel To Vet Treasury Nominee Thursday

    The Senate Finance Committee will hold a hearing Thursday to consider the nomination of Scott Bessent to serve as the new U.S. Treasury secretary under the incoming administration, Sen. Mike Crapo, R-Idaho, said Friday.

  • January 10, 2025

    CMS Taps Tax Disputes Specialist From KPMG

    CMS announced that it has appointed a former KPMG director as a partner in its London-based tax practice.

  • January 10, 2025

    Broker Arian Hit With Fine For Cum-Ex Trade Failings

    The finance watchdog said Friday that it has fined broker Arian Financial LLP £289,000 ($354,000) for having inadequate systems and controls against financial crime in a cum-ex dividend trading case.

  • January 09, 2025

    EisnerAmper Adds Tax Pro As Partner In Dallas

    International business adviser EisnerAmper LLC announced it appointed a certified public accountant from Citrin Cooperman Advisors LLC to serve as a tax partner in the firm's private client services group based in Dallas.

  • January 09, 2025

    Sri Lanka Publishes Advance Pricing Agreement Guidance

    Sri Lanka's Inland Revenue Department published guidance for those interested in entering advance pricing agreements, including eligibility requirements and the steps of the confirmation process.

  • January 09, 2025

    UK Supermarkets Fear Higher Costs Amid Tax Changes

    Supermarket companies Marks & Spencer and Tesco reported Thursday that they had high sales figures due to Christmas, but both retailers also said they expect to face higher tax costs in 2025 due to changes to National Insurance, a payroll tax used to fund social programs.

  • January 09, 2025

    Chile Voluntary Disclosure Program Hits Just 15% Of Estimate

    A Chilean program that allowed for the voluntary disclosure of foreign assets in exchange for a favorable tax rate collected just 92.5 billion Chilean pesos ($92.1 million), which was 15.6% of the projected total, the country's tax authority said.

  • January 09, 2025

    Truss Sends Starmer Legal Threat Over Economy Crash Claim

    Former Prime Minister Liz Truss sent a legal letter to Keir Starmer on Thursday demanding that he stop making "false and defamatory" statements that she crashed the economy, claiming that it is damaging her reputation.

  • January 08, 2025

    Pension Plan Official's Estate Excused From Danish Tax Suit

    A New York federal court approved Wednesday an agreement for Denmark's tax authority to settle its claims against the estate of a pension plan official whose plan allegedly defrauded the agency out of $9 million.

  • January 08, 2025

    Bank Misclassified Card Fee Revenue, Canada Tax Court Says

    A major Canadian bank must reclassify about CA$392 million ($273 million) in revenue from credit card services in the calculation of its taxes, reducing credits it can claim for three years, the Tax Court of Canada ruled.

Expert Analysis

  • A Year-End Look At Florida's Capital Investment Tax Credit

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    Notwithstanding the Walt Disney Co.’s feud with Gov. Ron DeSantis this year, Florida's capital investment tax credit will continue to make the state a favored destination for large corporations, particularly in light of the new federal alternative minimum tax and the Pillar Two top-up tax, says Alan Lederman at Gunster.

  • Understanding Discovery Obligations In Era Of Generative AI

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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.

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