International
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September 24, 2024
Abbott Seeks $24M Refund Over Transfer Pricing Adjustments
Healthcare products giant Abbott Laboratories is owed $24.3 million for overpaid taxes after the IRS incorrectly adjusted its intragroup income and payments this year, the company told the U.S. Tax Court in a petition.
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September 24, 2024
IRS Wary Of Adding Complexity In Min. Tax Regs, Official Says
The IRS opted to use existing tax rules in proposed guidance to address risks that the U.S. corporate alternative minimum tax could count offshore income twice, an agency official said Tuesday, noting a more precise method would increase complexity.
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September 24, 2024
Australia Floats Denying Late, Wrong Tax Interest Deductions
Australia's government opened a consultation Tuesday on a measure that would deny tax deduction claims for interest charged on late payments of tax liabilities as well as for interest charged when incorrect self-assessments result in a shortfall of tax paid.
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September 24, 2024
Treasury To Allow 3 AMT Transition Methods, Official Says
Final rules on the new corporate alternative minimum tax are expected to adopt the proposed regulations' three ways for companies to transition to the regime, and the U.S. Treasury Department is open to other ways as well, a department official said Tuesday.
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September 24, 2024
Exxon Claims It Beat Weak Defense In $1.8B Tax Trial
Exxon Mobil urged a Texas federal judge to find that it defeated what it called a scattered defense by the U.S. government during a five-day bench trial in April when the company argued for a $1.8 billion tax refund on its natural gas deal with Qatar, according to newly released filings.
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September 24, 2024
Azerbaijan Ratifies OECD Tax Treaty Standards
Azerbaijan ratified the Organization for Economic Cooperation and Developement's multilateral convention on base erosion and profit shifting Tuesday, which updates bilateral tax treaties of its signatories with agreed-upon standards, the OECD said.
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September 24, 2024
HMRC Set To Launch Consultation On VAT E-Invoicing
HM Revenue & Customs will hold a consultation on e-invoicing for value-added tax "soon," the British Treasury confirmed following a speech by the chancellor.
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September 24, 2024
Miller & Chevalier Adds Federal Tax Expert From White & Case
Miller & Chevalier Chtd. announced that it added a former partner at White & Case LLP to its tax controversy and litigation practice.
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September 23, 2024
Clean Energy Safe Harbor Applies To Direct Pay, Official Says
The safe harbor for the bonus clean energy tax credits' domestic content rules applies to all applicable project owners, including tax-exempt entities that are eligible to get a direct cash payment of the credits, a U.S. Treasury Department attorney said Monday.
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September 23, 2024
The Tax Angle: Corporate Inversions, SALT Cap
From a look at criticisms that the 2017 federal tax law failed to stop corporations from moving overseas to GOP efforts to navigate the SALT cap ahead of the November elections, here's a peek into a reporter's notebook on a few of the week's developing tax stories.
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September 23, 2024
Sysco Allowed $324M Dividend Deduction After Varian Ruling
Sysco Corp. can deduct $324 million in foreign dividends after agreeing with the Internal Revenue Service that a decision in a similar case brought by Varian Medical Systems resolved their dispute, the U.S. Tax Court said in an order.
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September 23, 2024
Disney Asks Justices To Review NY Tax On Foreign Royalties
New York's highest court used the wrong standard for evaluating tax statutes for discrimination when it denied deductions that The Walt Disney Co. sought for royalties received from foreign affiliates, the company argued in a petition to the U.S. Supreme Court that Law360 obtained Monday.
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September 23, 2024
Singapore Man Sentenced To 4 Years In $43M Fraud Scheme
A Singapore man involved in a scheme that made SG$55 million ($43 million) in fictitious sales that resulted in more than SG$7.5 million in fraudulent goods-and-services tax, or GST, refund claims was sentenced to more than four years in prison Monday, the country's revenue authority said.
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September 23, 2024
IRS Finalizing Pricing Pact Guidance, Official Says
The Internal Revenue Service is in the final stages of updating revenue procedures to help multinational corporations pursue advance pricing agreements and resolve tax treaty disputes, and it will release the guidance soon, an agency official said Monday.
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September 23, 2024
Irish Carbon Tax Could Generate €8.8B By 2030, Report Says
Planned rate increases and other factors could see Ireland's carbon tax generate at least €8.8 billion ($9.8 billion) in revenue over the next six years, compared with over €3.3 billion generated from 2019 through 2023, the country's Financial Services Division said.
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September 23, 2024
Squire Patton Tax Ace Joins Winston & Strawn In Dallas
Winston & Strawn LLP announced Monday it has expanded its tax offerings with the addition of an experienced attorney from Squire Patton Boggs LLP in Texas.
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September 23, 2024
HMRC Raises £1B Cracking Down On Tax Fraud
HM Revenue & Customs raised almost £1 billion ($1.3 billion) in its most serious criminal investigations of tax fraud year-on-year in April, according to research published by a law firm Monday.
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September 23, 2024
Belgium Has High Tax Burden, Public Debt, OECD Says
While there are some tax changes Belgium should consider, the country should tackle its high public debt through better spending practices because its tax burden is among the highest in the OECD, the organization said Monday.
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September 23, 2024
Pension Experts Urge Tax Breaks For UK Investment Plan
The government could best encourage investment in the economy from pension schemes by adopting tax incentives, a trade body said.
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September 20, 2024
8th Circ. To Hear Args In 3M's $24M Tax Case Next Month
The Eighth Circuit said Friday that it will hear oral arguments next month in 3M's transfer pricing appeal, in which the multinational conglomerate is challenging the Internal Revenue Service's authority to reallocate to the company $24 million from a Brazilian affiliate.
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September 20, 2024
IRS Special Trial Attorney Joins Hochman Salkin In California
When Hochman Salkin Toscher Perez PC's newest principal, Sebastian Voth, was studying at Emory University School of Law, a former chief counsel for the Internal Revenue Service told students that the IRS was a great place to start their careers. After 15 years as an IRS attorney, Voth found that the agency was also a great place to work, he told Law360 Pulse in an interview Friday.
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September 20, 2024
Australia Seeks Comments On Luxury Car Tax Green Changes
Australia is looking for comments on plans to adjust the country's luxury car tax to update the definition of a fuel-efficient car and to make changes to the way the tax threshold is indexed, the country's Treasury Department said Friday.
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September 20, 2024
Hong Kong's Tax Revenue Drops For 2nd Straight Year
Hong Kong's tax revenue dipped by HK$14 billion ($1.8 billion) to HK$342 billion in the 2023-24 tax year — the second straight year with a drop — largely because of decreases in stamp duty and profit tax collections, its tax authority said Friday.
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September 20, 2024
Taxation With Representation: Gibson Dunn, Holland & Knight
In this week's Taxation With Representation, CACI International buys Azure Summit Technology, Hotel Engine lands a valuation led by Permira, and Knowles Corp. sells its microphone business to Syntiant Corp.
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September 20, 2024
UK Budget May Seek Gains From Inheritance Tax, Firms Say
The U.K. government may try to squeeze more revenue out of the wealthy via inheritance tax, wealth management firms said Friday following the release of data showing the levy is generating higher returns for HM Treasury.
Expert Analysis
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Breaking Down High Court's New Code Of Conduct
The U.S. Supreme Court recently adopted its first-ever code of conduct, and counsel will need to work closely with clients in navigating its provisions, from gift-giving to recusal bids, say Phillip Gordon and Mateo Forero at Holtzman Vogel.
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Legal Profession Gender Parity Requires Equal Parental Leave
To truly foster equity in the legal profession and to promote attorney retention, workplaces need to better support all parents, regardless of gender — starting by offering equal and robust parental leave to both birthing and non-birthing parents, says Ali Spindler at Irwin Fritchie.
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A Year-End Look At Florida's Capital Investment Tax Credit
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.
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Understanding Discovery Obligations In Era Of Generative AI
Excerpt from Practical Guidance
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.
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The Case For Post-Bar Clerk Training Programs At Law Firms
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.
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AI Can Help Lawyers Overcome The Programming Barrier
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.
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Preparing Law Students For A New, AI-Assisted Legal World
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.
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General Counsel Need Data Literacy To Keep Up With AI
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.
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Navigating Discovery Of Generative AI Information
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.
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Finding Focus: Strategies For Attorneys With ADHD
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.
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Attorneys, Law Schools Must Adapt To New Era Of Evidence
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.
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1st Tax Easement Convictions Will Likely Embolden DOJ, IRS
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.
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Tips For Litigating Against Pro Se Parties In Complex Disputes
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.