International
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July 29, 2024
Sites Should Pay Sport Fishing, Archery Import Tax, GAO Says
Congress should make U.S. online marketplaces responsible for any sport fishing and archery excise taxes owed on consumer import sales they're involved with, the Government Accountability Office said in a report released Monday.
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July 29, 2024
UK Seeks Input On Rule Targeting Min. Tax's Safe Harbor
HM Revenue & Customs opened a consultation Monday seeking comments on an anti-arbitrage rule to help prevent large multinational companies from exploiting the safe harbor provision in the Organization for Economic Cooperation and Development's global minimum tax.
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July 29, 2024
ECJ Nixes Swedish Dividends Tax On Foreign Pension Funds
Sweden can't collect a withholding tax on dividends distributed by Swedish companies to public pension funds abroad while exempting its own public funds because that is inconsistent with European Union law requiring the free movement of capital, the European Court of Justice said Monday.
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July 29, 2024
France Restricts Access To Beneficial Ownership Registry
France is dialing back access to its beneficial ownership information registry by introducing what it is calling a filtering system that limits the previously entirely public database starting Wednesday, the French Finance Ministry said Monday.
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July 29, 2024
Gov't Consults On Tax Hikes For Fund Managers, Non-Doms
Chancellor Rachel Reeves said Monday that an autumn Budget planned for Oct. 30 will include feature selected tax rises, a warning accompanied by strong hints from HM Treasury that fund managers and non-domicile taxpayers could take a bigger hit.
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July 29, 2024
EU's Highest Court Upholds Disclosure Law
The European Union's highest court on Monday upheld the bloc's law requiring tax advisers to report potentially aggressive cross-border tax arrangements, rejecting a challenge from Belgian tax attorneys who said their country's implementation of the EU's DAC6 law violated European law.
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July 26, 2024
G20 Declines To Back Brazil's Plan For A Minimum Wealth Tax
Finance ministers from the Group of 20 nations declined to back Brazil's proposal for an agreement on individual wealth taxation similar to the global corporate minimum tax, instead issuing a statement Friday that opted for softer language about cooperation.
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July 26, 2024
Biz Groups Call Corp. Transparency Act Unconstitutional
The U.S. government has failed to show how the Corporate Transparency Act meets narrow exceptions to the Fourth Amendment's search warrant requirements, a group of small businesses told a Michigan federal court Friday in contending that the statute is unconstitutional.
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July 26, 2024
Denmark's Tax Losses From Evasion Fell 70%, Study Says
Denmark's tax losses from offshore evasion by individuals dropped 70% following the implementation of the automatic exchange of banking information between tax authorities, researchers found in a study of the Danish Tax Agency's data.
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July 26, 2024
Chile Considering New Tax Compliance Measures
Chile's Senate Finance Committee approved a tax compliance measure that includes creating an anonymous whistleblower process related to tax crimes, a lifting of bank secrecy measures and an overall modernization of the country's revenue agency, the country's Ministry of Finance said.
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July 26, 2024
Denmark Says Pension Plans Misread Law In $2B Fraud Case
U.S. pension plans accused by Denmark's tax agency of participating in a $2.1 billion fraud scheme involving withholding tax refunds are misconstruing Danish law as it applies to the ownership of shares, the agency told a New York federal court.
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July 26, 2024
Two Admit Trying To Bribe IRS Official On China's Behalf
Two people admitted to secretly acting on behalf of the Chinese government and bribing an undercover agent in connection with a scheme to revoke the tax-exempt status of U.S. participants in a spiritual practice banned in China, according to New York federal court filings.
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July 26, 2024
Taxation With Representation: Wachtell, Polsinelli, Kirkland
In this week's Taxation With Representation, T-Mobile partners with KKR to acquire Metronet, Exclusive Networks gets a takeover offer, KKR buys Instructure Holdings Inc., and Bally's Corp. merges with The Queen Casino & Entertainment Inc.
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July 26, 2024
Australia Clarifies Tax Treatment Of Exploration, Land Rights
The Australian government has amended its petroleum resource rent tax to clarify what is considered "exploration for petroleum" for tax purposes, and changes are coming soon regarding the depreciation of mining, quarrying and prospecting rights, the Australian Taxation Office said.
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July 26, 2024
EU Closes Investigation Into Repealed Hungarian Ad Tax
The European Commission said Friday it has closed its nearly decadelong investigation into a Hungarian advertisement tax that it said violated the European Union's state aid rules, noting that the country has repealed the law in question.
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July 26, 2024
EU Frees Up €1.5B Of Frozen Russian Assets To Aid Ukraine
The European Union's executive branch said Friday that it is freeing up €1.5 billion ($1.6 billion) of revenue generated from immobilized Russian assets to aid Ukraine in defending itself against the Russian invasion.
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July 25, 2024
Global Tax Revamp Continues To Progress, OECD Tells G20
Implementation of the Pillar Two minimum tax portion of the OECD's international plan to address tax base erosion and profit shifting is well underway, while an agreement is close on the Pillar One taxing rights overhaul, the organization told the Group of 20 nations Thursday.
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July 25, 2024
UK Telecom Co. Owes VAT For Phone Plans In £51M Dispute
A U.K. telecommunications provider will not recover £51.1 million ($65.7 million) in value-added tax payments after the First-tier Tribunal ruled that VAT is chargeable on phone plans from the point of sale, not when the services are used.
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July 25, 2024
Global Tax Police Unit Probes More Than 30 Cybercrime Cases
The Joint Chiefs of Global Tax Enforcement, an intergovernmental tax enforcement group, is investigating more than 30 active cybercrime cases tied to financial and tax criminal activities all over the world, the group announced Thursday in its first report.
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July 25, 2024
Income Inequality Calls For Stronger Tax Policies, OECD Says
More focus is being drawn to stronger tax policies as a way to solve persistent income inequality, especially in light of the continually increasing concentration of wealth by the top 0.001% of earners, the Organization for Economic Cooperation and Development said Thursday.
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July 25, 2024
Mixed Progress Made On Beneficial Ownership, OECD Says
The U.S., Japan and the European Union now have wide-reaching beneficial ownership registries in place, but many jurisdictions worldwide aren't effectively exchanging data on the owners of legal entities, the OECD said Thursday in a report based on peer reviews.
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July 25, 2024
Australian Officials Defend Basis for Tax Reporting Framework
Australia's public corporate tax disclosure legislation builds on global standards that could provide more insights into profit shifting risks than European Union reporting rules, Australian government officials said Thursday in response to calls for closer alignment between the two regimes.
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July 25, 2024
Billionaire Tax Not Fit For Global Agreement, Yellen Says
The U.S. government doesn't think it's appropriate to seek a global agreement on taxing billionaires, Treasury Secretary Janet Yellen said Thursday ahead of a discussion by the Group of 20 nations on coordinating wealth taxes.
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July 25, 2024
58 Jurisdictions Plan For Crypto Info Swaps By 2027
Fifty-eight tax jurisdictions have pledged to implement the Organization for Economic Cooperation and Development's crypto-asset information exchange system by 2027, the OECD said Thursday.
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July 25, 2024
Wyden Seeks Swiss Bank Info On Indicted Defense Contractor
Senate Finance Committee Chairman Ron Wyden asked Swiss bank UBS in a letter published Thursday for information about a former U.S. defense contractor who the Department of Justice says avoided taxes on more than $350 million in income.
Expert Analysis
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Think Like A Lawyer: Forget Everything You Know About IRAC
The mode of legal reasoning most students learn in law school, often called “Issue, Rule, Application, Conclusion,” or IRAC, erroneously frames analysis as a separate, discrete step, resulting in disorganized briefs and untold obfuscation — but the fix is pretty simple, says Luke Andrews at Poole Huffman.
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How New EU Tax And Transfer Pricing Rules May Affect M&A
Companies involved in mergers and acquisitions may need to adjust fiscal due diligence procedures to ensure they consider potential far-reaching effects of newly implemented transfer pricing measures, such as newly implemented global minimum tax and European Union anti-tax avoidance directives and proposals, says Patrick Tijhuis at BDO.
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How Firms Can Ensure Associate Gender Parity Lasts
Among associates, women now outnumber men for the first time, but progress toward gender equality at the top of the legal profession remains glacially slow, and firms must implement time-tested solutions to ensure associates’ gender parity lasts throughout their careers, say Kelly Culhane and Nicole Joseph at Culhane Meadows.
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7 Common Myths About Lateral Partner Moves
As lateral recruiting remains a key factor for law firm growth, partners considering a lateral move should be aware of a few commonly held myths — some of which contain a kernel of truth, and some of which are flat out wrong, says Dave Maurer at Major Lindsey.
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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.