International

  • October 07, 2024

    Corp. Tactics May Call For Rethinking Tax Breaks, Paper Says

    Countries may want to look at scaling back corporate tax breaks to address tax planning opportunities taken advantage of by businesses over the past 20 years while those tax breaks have proliferated, according to a working paper published Monday by the Organization for Economic Cooperation and Development.

  • October 07, 2024

    India Seeking Feedback On Income Tax Regime

    India's government said Monday it is undergoing what it called a comprehensive review of its income tax regime in hopes of reducing litigation and increasing taxpayer certainty.

  • October 07, 2024

    TCJA Extension, Biz Tax Cut To Reward Top 5%, Report Says

    Former President Donald Trump's planned extension of the 2017 tax cuts and lowering of corporate rates contribute most among his platform to lowering taxes for the wealthiest 5% and hiking them for everyone else, the left-leaning Institute on Taxation and Economic Policy said Monday in a report.

  • October 05, 2024

    Biz Owners Saved £1.3B On Inheritance Tax, Report Says

    Business owners have saved their families an estimated £1.3 billion ($1.7 billion) last year by claiming business property relief on inheritance tax, according to law firm TWM Solicitors.

  • October 04, 2024

    DC Circ. Won't Reconsider Whistleblower's $690M Claim

    The D.C. Circuit on Friday rejected a whistleblower's request that it rehear a ruling upholding the denial of up to $690 million, or 30%, of the $2.3 billion collected in an Internal Revenue Service offshore voluntary disclosure program.

  • October 04, 2024

    Promise Of OECD's Payments Tax Treaty Called Into Question

    The OECD-designed tool to provide developing countries with better means to apply a minimum tax on income sent from their jurisdictions to low-taxed entities within a corporate group is inadequate to address those countries' revenue needs, tax policy organizations said.

  • October 04, 2024

    Australia Wants Feedback On Tax Promoter Penalty Regime

    The Australian government asked Friday for feedback on the country's current tax promoter penalty regime as part of its efforts to strengthen its regulatory frameworks in the wake of the PwC document leak scandal.

  • October 04, 2024

    Europe Votes To Raise Tariffs On Electric Vehicles From China

    European Union member states voted Friday to impose higher tariffs on imports of battery electric vehicles from China for the next five years, adding to the already staggering tariffs imposed by the United States and Canada.

  • October 04, 2024

    Brazil Establishes 15% Global Min. Tax On Large Cos.

    Brazil's government has adopted the Organization for Economic Cooperation and Development's 15% global corporate minimum tax on large multinational corporations making €750 million ($823 million) annually.

  • October 04, 2024

    Former NJ Doctor Owes $4.8M In FBAR Penalties, Court Told

    A former physician in New Jersey faces a tax bill of almost $5 million for failing to report 19 bank accounts he opened at Indian banks, the government told a federal court.

  • October 04, 2024

    ECJ Says Interest Deduction Limits Align With EU Law

    Governments across the European Union can legislate to block businesses from getting corporate tax deductions on interest paid as part of noncommercial loans, the European Court of Justice ruled Friday.

  • October 04, 2024

    Taxation With Representation: Gibson Dunn, Weil, Simpson

    In this week's Taxation with Representation, DirectTV buys EchoStar's video business for $10 billion, Marsh McLennan inks a $7.75 billion deal for McGriff Insurance, and PepsiCo closes a $1.2 billion deal to purchase Siete Foods.

  • October 04, 2024

    McDermott Taps Big 4 Partner As Senior Tax Pro In London

    McDermott Will & Emery LLP announced it has recruited a former U.K. partner from KPMG to join its firm as a tax partner, bringing an expert in private equity to its London office.

  • October 03, 2024

    12 Lawyers Who Are The Future Of The Supreme Court Bar

    One attorney hasn't lost a single U.S. Supreme Court case she's argued, or even a single justice's vote. One attorney is perhaps "the preeminent SCOTUS advocate." And one may soon become U.S. solicitor general, despite acknowledging there are "judges out there who don't like me." All three are among a dozen lawyers in the vanguard of the Supreme Court bar's next generation, poised to follow in the footsteps of the bar's current icons.

  • October 03, 2024

    US Partnership Excluded From Tax Treaty, Irish Court Says

    A Delaware corporation with three Irish subsidiaries must pay Irish taxes on distributions to its U.S. partners because a U.S.-Ireland tax treaty designed to prevent double taxation does not apply, the Irish High Court ruled.

  • October 03, 2024

    3M Tells 8th Circ. Chevron's End Dooms IRS In $24M Dispute

    Multinational conglomerate 3M said Thursday that the U.S. Supreme Court's striking down of Chevron deference dictates that the Eighth Circuit overturn a U.S. Tax Court decision that supported the IRS' reallocation of $24 million from the company's Brazilian affiliate.

  • October 03, 2024

    K&L Gates Boosts Houston Shop With Ernst & Young Tax Ace

    K&L Gates LLP strengthened its Houston office this week with the hire of a tax partner with nearly three decades of expertise in advising multinational corporations on U.S. taxation on cross-border acquisitions and other transactions.

  • October 03, 2024

    Aerospace Co. Says Conn. Town Wrongly Taxed $8M In Assets

    A unit of a U.K.-based aerospace manufacturer is claiming that a Connecticut town overvalued its taxable personal property by nearly $8 million after the company moved nearly $20 million worth of its property out of the jurisdiction, according to a suit filed in state court.

  • October 03, 2024

    Tax Could Help Curtail Plastic Pollution By 2040, OECD Says

    Taxation targeted at plastic use could help to nearly eliminate plastic pollution by 2040 by curbing both creation and consumption, the Organization for Economic Cooperation and Development said.

  • October 03, 2024

    EU, Norway Update VAT Fraud Cooperation Agreement

    The European Union and Norway have amended their agreement on administrative cooperation to help combat value-added tax fraud as well as the recovery of claims, the European Commission announced.

  • October 03, 2024

    EU Refers 4 Countries To Court Over Pillar 2 Delays

    The European Commission said it was referring Cyprus, Poland, Portugal and Spain to the European Union's top court for missing the deadline to implement the global minimum corporate tax, known as Pillar Two.

  • October 02, 2024

    BlackBerry's $17M In R&D Not Taxable, Canada Court Rules

    BlackBerry Ltd. won't pay taxes on $17.1 million in research and development services it procured from its U.S. affiliates because the services don't fit the definition of foreign accrual property income, the Tax Court of Canada ruled.

  • October 02, 2024

    Philippines Enacts 12% VAT On Foreign Digital Services

    Google, Amazon and Netflix are among the companies expected to pay a 12% value-added tax on foreign digital service providers that was signed into law Wednesday by Philippines President Ferdinand Marcos Jr., according to government agencies.

  • October 02, 2024

    IRS Says European Energy Exchange Is A Qualified Exchange

    The European Energy Exchange is a qualified board or exchange for purposes of mark-to-market contracts under Internal Revenue Code Section 1256(g)(7)(C), the Internal Revenue Service said Wednesday. 

  • October 02, 2024

    OECD Releases Crypto Data-Swap Guidance For Tax Agencies

    The Organization for Economic Cooperation and Development released guidance Wednesday to help tax administrations automatically exchange information under a new global crypto-asset reporting framework and under an updated system for swapping traditional financial data.

Expert Analysis

  • 5 Tips To Succeed In A Master Of Laws Program And Beyond

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    As lawyers and recent law school graduates begin their Master of Laws coursework across the country, they should keep a few pointers in mind to get the most out of their programs and kick-start successful careers in their practice areas, says Kelley Miller at Reed Smith.

  • How Law Firms Can Avoid 'Collaboration Drag'

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    Law firm decision making can be stifled by “collaboration drag” — characterized by too many pointless meetings, too much peer feedback and too little dissent — but a few strategies can help stakeholders improve decision-making processes and build consensus, says Steve Groom at Miles Mediation.

  • Litigation Funding Disclosure Key To Open, Impartial Process

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    Blanket investor and funding agreement disclosures should be required in all civil cases where the investor has a financial interest in the outcome in order to address issues ranging from potential conflicts of interest to national security concerns, says Bob Goodlatte, former U.S. House Representative for Virginia.

  • What NFL Draft Picks Have In Common With Lateral Law Hires

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    Nearly half of law firm lateral hires leave within a few years — a failure rate that is strikingly similar to the performance of NFL quarterbacks drafted in the first round — in part because evaluators focus too heavily on quantifiable metrics and not enough on a prospect's character traits, says Howard Rosenberg at Baretz+Brunelle.

  • Replacing The Stigma Of Menopause With Law Firm Support

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    A large proportion of the workforce is forced to pull the brakes on their career aspirations because of the taboo surrounding menopause and a lack of consistent support, but law firms can initiate the cultural shift needed by formulating thoughtful workplace policies, says Barbara Hamilton-Bruce at Simmons & Simmons.

  • Planning Law Firm Content Calendars: What, When, Where

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    During the slower month of August, law firms should begin working on their 2025 content calendars, planning out a content creation and distribution framework that aligns with the firm’s objectives and maintains audience engagement throughout the year, says Jessica Kaplan at Legally Penned.

  • Law Firms Should Move From Reactive To Proactive Marketing

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    Most law firm marketing and business development teams operate in silos, leading to an ad hoc, reactive approach, but shifting to a culture of proactive planning — beginning with comprehensive campaigns — can help firms effectively execute their broader business strategy, says Paul Manuele at PR Manuele Consulting.

  • The Big Issues A BigLaw Associates' Union Could Address

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    A BigLaw associates’ union could address a number of issues that have the potential to meaningfully improve working conditions, diversity and attorney well-being — from restructured billable hour requirements to origination credit allocation, return-to-office mandates and more, says Tara Rhoades at The Sanity Plea.

  • It's Time For A BigLaw Associates' Union

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    As BigLaw faces a steady stream of criticism about its employment policies and practices, an associates union could effect real change — and it could start with law students organizing around opposition to recent recruiting trends, says Tara Rhoades at The Sanity Plea.

  • How Justices Upended The Administrative Procedure Act

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    In its recent Loper Bright, Corner Post and Jarkesy decisions, the U.S. Supreme Court fundamentally changed the Administrative Procedure Act in ways that undermine Congress and the executive branch, shift power to the judiciary, curtail public and business input, and create great uncertainty, say Alene Taber and Beth Hummer at Hanson Bridgett.

  • Tips For Tax Equity-Tax Credit Transfers That Pass IRS Muster

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    Although the Internal Revenue Service has increased its scrutiny of complex partnership structures, which must demonstrate their economic substance and business purpose, recent cases and IRS guidance together provide a reliable road map for creating legitimate tax equity structures, say Ian Boccaccio and Michael Messina at Ryan Tax.

  • Mirror, Mirror On The Wall, Is My Counterclaim Bound To Fall?

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    A Pennsylvania federal court’s recent dismissal of the defendants’ counterclaims in Morgan v. Noss should remind attorneys to avoid the temptation to repackage a claim’s facts and law into a mirror-image counterclaim, as this approach will often result in a waste of time and resources, says Matthew Selmasska at Kaufman Dolowich.

  • 3 Leadership Practices For A More Supportive Firm Culture

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    Traditional leadership styles frequently amplify the inherent pressures of legal work, but a few simple, time-neutral strategies can strengthen the skills and confidence of employees and foster a more collaborative culture, while supporting individual growth and contribution to organizational goals, says Benjamin Grimes at BKG Leadership.

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