International
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August 05, 2024
EU Court To Hear Czech Value-Added Tax Case
The Court of Justice of the European Union will consider a case from the Czech Republic concerning whether the bloc's value-added tax system and proportionality principle precludes a Czech law regarding the transfers of VAT payment liabilities, the EU said Monday.
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August 05, 2024
Free Market Group Challenges EU Pillar 2 Directive In Court
A free market trade group is taking aim in court at the European Union's implementation of the OECD's Pillar Two anti-tax base erosion and profit shifting measures, which it claims are unfairly impacting the U.S. and subverting Congress' right to tax U.S. companies.
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August 05, 2024
Peru To Subject Foreign Platforms To Sales Tax
Foreign digital service providers doing business in Peru will be subject to the country's sales tax starting in October, in line with Organization for Economic Cooperation and Development standards, according to a legislative decree.
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August 05, 2024
Russia Increasing Corporate Tax Rates In 2025
Corporations in Russia will be assessed a 25% income tax rate starting in 2025, an increase from the current 20%, the country's tax agency said Monday.
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August 02, 2024
Ex-Loeb Tax Atty Latest Addition To Kilpatrick's NY Team
A former Loeb & Loeb LLP attorney is bringing his experience in U.S. federal tax matters and real estate transactions to Kilpatrick Townsend & Stockton LLP, the firm announced Thursday.
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August 02, 2024
Aussie Panel Opposes Aligning Public Tax Reporting With EU
The benefits of Australia's public country-by-country reporting bill would diminish if it were limited to jurisdictions covered by the European Union's regime, as businesses have requested, the Australian Senate's economics committee reported Friday.
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August 02, 2024
PwC Australia Names Independent Governance Board Chair
PwC Australia has chosen the first independent nonexecutive chair of its governance board, along with an independent nonexecutive board member, as it takes steps to rebound in the wake of its scandal involving the leak of government tax documents.
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August 02, 2024
Treasury Faces Complicated Path For Amount B Pricing Rules
The U.S. Treasury Department signaled it is considering how to enact the OECD's routine pricing plan known as Amount B, but U.S. tax attorneys expect a complicated compliance exercise if rulemakers establish the new transfer pricing approach.
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August 02, 2024
Coca-Cola Poised To Appeal $2.7B Tax Bill With 11th Circ.
The U.S. Tax Court signed off Friday on Coca-Cola's $2.7 billion tax bill, setting the stage for the beverage giant to appeal the liabilities and related rulings in its long-running dispute over the IRS' reallocation of the company's foreign income.
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August 02, 2024
IRS Tells Tax Court AbbVie's $1.6B Break Fee Is A Capital Loss
The Internal Revenue Service correctly reclassified AbbVie's $1.6 billion break fee to an Irish biotechnology company as a capital loss, the agency told the U.S. Tax Court, arguing that the failed merger is tantamount to disposing of property.
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August 02, 2024
Taxation With Representation: Sullivan, Dechert, Kirkland
In this week's Taxation With Representation, BNP Parabis SA acquires an investment management subsidiary for €5.1 billion, Cleveland accounting firm CBIZ merges with competitor Marcum for $2.3 billion, and Arcosa Inc. inks a deal with a family-owned construction materials business for $1.2 billion.
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August 02, 2024
Liberty Global's $110M Tax Refund Kosher, 10th Circ. Told
The IRS is trying to block Liberty Global's bid for a $110 million tax refund by improperly using a legal doctrine requiring transactions to have economic substance, the telecommunications giant told the Tenth Circuit, arguing it was allowed to make tax-driven choices in the transactions at issue.
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August 02, 2024
Top UK Court To Hear HMRC Car Park Tax Dispute With NHS
HM Revenue and Customs has been granted permission by Britain's highest court to challenge a ruling that a National Health Service trust qualified for value-added tax exemption for hospital car parking, a decision that could affect appeals brought by NHS entities.
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August 01, 2024
Divided Tax Court Says Treaty Bars Collections Hearing
A divided U.S. Tax Court ruled Thursday that it lacked authority to review an Internal Revenue Service decision preventing a woman from challenging a federal tax lien the agency issued on behalf of the Canadian government to secure her tax debt to that country.
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August 01, 2024
Coca-Cola, IRS Enter $2.7B Tax Bill In Transfer Pricing Dispute
Coca-Cola and the IRS submitted tax liability calculations totaling $2.73 billion to the U.S. Tax Court, reflecting the latest step in the company's long-running transfer pricing dispute over the agency's reallocation of the company's foreign affiliate income.
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August 01, 2024
EU Seeking Input On Electronic Country-By-Country Reporting
The European Commission is looking for feedback on draft regulations creating a common template and electronic format for country-by-country reporting forms that large multinational corporations operating in the European Union will be required to use to disclose their corporate taxes, the EU's executive arm said Thursday.
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August 01, 2024
Airbnb's $1.3B Bill From IRS Overvalues IP, Tax Court Told
Airbnb is challenging a $1.3 billion tax bill tied to income the IRS allocated from overseas, telling the U.S. Tax Court the agency overvalued intellectual property the home-rental giant licensed to its Irish affiliate before going public.
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August 01, 2024
Australia Seeking Feedback On Nonresident Trust Guidance
The Australian Taxation Office is soliciting input on draft guidelines for compliance with the country's income tax obligations in cases where property of a nonresident trust is paid to or applied for the benefit of a resident beneficiary.
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August 01, 2024
3rd Circ. Affirms Nix Of Discovery Ask On GM In Brazil Case
A Delaware federal court didn't abuse its discretion by declining to begin discovery on General Motors to aid ongoing litigation in Brazil for a group that is entitled to receive dozens of car dealerships' tax credits from the early 1990s, the Third Circuit found.
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August 01, 2024
15 Arrested In Albanian Ring Involving Money Laundering
A "prominent money launderer" was among 15 members of what was called a high-profile Albanian organized crime group arrested by authorities under suspicion of crimes including contract killings and money laundering using cryptocurrency transactions, Europol said Thursday.
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August 01, 2024
Australia Slows Tax Pro Conduct Code Update After Blowback
The Australian government is delaying the start of its newly passed changes to the country's code of conduct for tax agent services, which were supposed to enter into force this month, following pushback from industry groups, a minister said Thursday.
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August 01, 2024
Taxpayers Find Belgian Pillar 2 Request Sudden, Intrusive
Belgian demands for detailed information that must be supplied within a short deadline are troubling taxpayers within the scope of the global minimum corporate tax, who said the country's quest for information is more challenging than that imposed by other governments.
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August 01, 2024
UK Capital Gains Tax Liabilities Decline, HMRC Says
Capital gains tax liability in the U.K. declined in the 2022-2023 tax year, HM Revenue & Customs said in a news release Thursday.
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July 31, 2024
Treasury's New 'Killer B' Rules May Revive Controversies
Recent U.S. Treasury Department regulations centered on contentious 2011 guidance aimed at so-called Killer B transactions have revived long-standing questions about how much authority rule writers have to target what they perceive as corporate tax avoidance in these maneuvers.
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July 31, 2024
'Tax Avoidance' Fuels Global Reporting Pushback, Pro Says
A lobbying effort from multinational corporations to dissuade states from adopting mandatory worldwide combined reporting aims to keep billions of dollars in profits that were shifted into tax-friendly jurisdictions beyond the reach of tax administrators, a retired researcher from a progressive think tank said Wednesday.
Expert Analysis
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A Vision For Economic Clerkships In The Legal System
As courts handle increasingly complex damages analyses involving vast amounts of data, an economic clerkship program — integrating early-career economists into the judicial system — could improve legal outcomes and provide essential training to clerks, say Mona Birjandi at Data for Decisions and Matt Farber at Secretariat.
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A Look At New IRS Rules For Domestically Controlled REITs
The Internal Revenue Services' finalized Treasury Regulations addressing whether real estate investment trusts qualify as domestically controlled adopt the basic structure of previous proposals, but certain new and modified rules may mitigate the regulations' impact, say attorneys at Simpson Thacher.
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E-Discovery Quarterly: Recent Rulings On Text Message Data
Electronically stored information on cellphones, and in particular text messages, can present unique litigation challenges, and recent court decisions demonstrate that counsel must carefully balance what data should be preserved, collected, reviewed and produced, say attorneys at Sidley.
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Don't Use The Same Template For Every Client Alert
As the old marketing adage goes, consistency is key, but law firm style guides need consistency that contemplates variety when it comes to client alert formats, allowing attorneys to tailor alerts to best fit the audience and subject matter, says Jessica Kaplan at Legally Penned.
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Think Like A Lawyer: Follow The Iron Rule Of Trial Logic
Many diligent and eager attorneys include every good fact, point and rule in their trial narratives — spurred by the gnawing fear they’ll be second-guessed for leaving something out — but this approach ignores a fundamental principle of successful trial lawyering, says Luke Andrews at Poole Huffman.
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The Art Of Asking: Leveraging Your Contacts For Referrals
Though attorneys may hesitate to ask for referral recommendations to generate new business, research shows that people want to help others they know, like and trust, so consider who in your network you should approach and how to make the ask, says Rebecca Hnatowski at Edwards Advisory.
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Unpacking The Bill To Extend TCJA's Biz-Friendly Tax Breaks
Attorneys at Skadden examine how a bipartisan bill currently being considered by the U.S. Senate to save the Tax Cuts and Jobs Act's tax breaks for research and development costs, and other expiring business-friendly provisions, would affect taxpayers.
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Deciding What Comes At The End Of WTO's Digital Tariff Ban
Companies that feel empowered by the World Trade Organization’s recent two-year extension of the ban on e-commerce tariffs should pay attention to current negotiations over what comes after the moratorium expires, as these agreements will define standards in international e-commerce for years to come, say Jan Walter, Hannes Sigurgeirsson and Kulsum Gulamhusein at Akin Gump.
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4 Ways To Refresh Your Law Firm's Marketing Strategy
With many BigLaw firms relying on an increasingly obsolete marketing approach that prioritizes stiff professionalism over authentic connection, adopting a few key communications strategies to better connect with today's clients and prospects can make all the difference, say Eric Pacifici and Kevin Henderson at SMB Law.
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This Earth Day, Consider How Your Firm Can Go Greener
As Earth Day approaches, law firms and attorneys should consider adopting more sustainable practices to reduce their carbon footprint — from minimizing single-use plastics to purchasing carbon offsets for air travel — which ultimately can also reduce costs for clients, say M’Lynn Phillips and Lisa Walters at IMS Legal Strategies.
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Cum-Ex Prosecutions Storm Shows No Sign Of Abating
The ongoing trial of Sanjay Shah in Denmark is a clear indicator that efforts remain focused on holding to account the alleged architects and beneficiaries of cum-ex trading, and with these prosecutions making their way across Europe, it is a more turbulent time now than ever, says Niall Hearty at Rahman Ravelli.
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Practicing Law With Parkinson's Disease
This Parkinson’s Awareness Month, Adam Siegler at Greenberg Traurig discusses his experience working as a lawyer with Parkinson’s disease, sharing both lessons on how to cope with a diagnosis and advice for supporting colleagues who live with the disease.
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Why Supreme Court Should Allow Repatriation Tax To Stand
If the U.S. Supreme Court doesn't reject the taxpayers' misguided claims in Moore v. U.S. that the mandatory repatriation tax is unconstitutional, it could wreak havoc on our system of taxation and result in a catastrophic loss of revenue for the government, say Christina Mason and Theresa Balducci at Herrick Feinstein.