International
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January 31, 2025
Tax Group Of The Year: Sullivan & Cromwell
Sullivan & Cromwell LLP's diverse tax practice went from strength to strength this year, from advising well-known companies like Boeing and Discover that inked multibillion-dollar deals to counseling industry leaders in shaking up their sectors, helping it earn a place among the 2024 Law360 Tax Groups of the Year.
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January 31, 2025
Taxation With Representation: Cravath, Gibson Dunn, Milbank
In this week's Taxation with Representation, Eversource Energy sells Aquarion Water Co., Diversified Energy Partners acquires oil and gas company Maverick, Lantheus Holdings buys Evergreen Theragnostics, and NASCAR champion Jimmie Johnson becomes the majority owner in the Legacy Motor Club racing team.
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January 31, 2025
NZ Looking Into Deferring Employee Share Taxes For Startups
New Zealand's government is seeking input on whether it would be beneficial to allow employees of startups to defer taxes they owe on their shares in the company while the company is still not making money, the country's tax agency said Friday.
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January 31, 2025
Trump Initiates Trade War With 25% Tariffs On Canada, Mexico
President Donald Trump said Saturday he is imposing 25% tariffs on imports from Mexico and Canada, and a 10% tariff on imports from China, citing the U.S. national security risks associated with illegal drug flows.
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January 31, 2025
Canada Delays Capital Gains Tax Hike Amid Pressure
Canada delayed on Friday a proposed increase to the capital gains inclusion rate on annual gains above CA$250,000 ($174,000) to Jan. 1, 2026, as the government faces suits in addition to politicians' pledges to kill the new rate, which has not been formally passed.
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January 30, 2025
IRS Allowed Summonses For Records In Foreign Assets Case
A Georgia federal court gave the Internal Revenue Service the go-ahead to issue summonses for the records of a group of financial institutions that clients may have used to avoid taxes, the U.S. Department of Justice said Thursday.
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January 30, 2025
IRS Asked To Cut Forms For Tax-Exempt Groups' Int'l Deals
Tax-exempt organizations shouldn't need to report transactions with foreign corporations or foreign partnerships if they don't hold a controlling interest in those entities, since the risk of unreported income is negligible, the American Institute of Certified Public Accountants told the IRS.
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January 30, 2025
Crapo, Wyden Pitch Harsher Tax Pro Fines In IRS Revamp Bill
The Internal Revenue Service would be required to simplify foreign bank account report compliance and increase civil and criminal penalties on tax professionals who deliberately harm their clients under draft legislation released Thursday by the Senate Finance Committee's top Democrat and Republican.
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January 30, 2025
Pillar 2 Should Live On Despite US Threats, Economists Say
Nations worldwide should continue implementing the international minimum tax agreement known as Pillar Two despite recent threats from the U.S. government to retaliate against what it sees as discriminatory measures imposed on U.S. companies, a group of economists said.
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January 30, 2025
Tax Group Of The Year: Skadden
Skadden Arps Slate Meagher & Flom LLP's tax practice advised on key deals and cases in 2024, including Mars Inc.'s $35.9 million acquisition of Kellanova and BlackRock Inc.'s $12.5 billion acquisition of Global Infrastructure Partners, landing it among the 2024 Law360 Tax Groups of the Year.
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January 30, 2025
Dechert's NY Office Adds Tax Pro From Milbank
Dechert LLP said it has bolstered its global tax group by adding a former special counsel from Milbank LLP to the firm's New York office.
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January 30, 2025
Sweden Becomes Latest To Suspend Tax Treaty With Russia
Sweden's government followed through on its plan to suspend its treaty to avoid double taxation with Russia on Thursday, joining a growing number of countries that have done so following Russia's cessation to parts of its treaties with numerous countries at the end of 2023.
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January 30, 2025
Energy Group Urges UK To Link To EU's Carbon-Tax Measure
The U.K. government should link to the European Union's Emissions Trading System to mitigate the impact of carbon border taxes on businesses in Northern Ireland, an energy industry group said.
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January 30, 2025
Denmark Cuts British Trader's Tax Fraud Prison Sentence
A British hedge fund trader convicted of defrauding Denmark's tax authority out of more than 320 million Danish krone ($47 million) in a sham trading scheme to reclaim tax has had his prison sentence shortened by an appeals court.
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January 30, 2025
Assets In Italy Seized In €14M Fuel VAT Fraud Investigation
Authorities have uncovered a complex value-added tax fraud scheme involving fuels in Italy that has caused an estimated €14 million ($14.6 million) in damages, the European Public Prosecutor's Office said Thursday.
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January 29, 2025
Pension Plans Seek Trader's Testimony In $2B Tax Fraud Suit
Pension plans and individuals who Denmark's government alleges received fraudulent refunds have asked a New York federal court to allow U.K. court testimony into the record from a trader who Danish authorities say masterminded a $2.1 billion tax fraud, saying it shows he deceived other participants.
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January 29, 2025
EU Carbon Fee Could Have Large Impact On Leakage
Full implementation of the European Union's carbon border adjustment mechanism in conjunction with the bloc's other carbon tax measures could effectively eliminate businesses relocating their manufacturing to countries with looser and cheaper restrictions, the OECD said Wednesday.
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January 29, 2025
White & Case Adds Global Tax Pro From McDermott
White & Case LLP announced Wednesday that it is expanding its global tax practice by bringing in a former McDermott Will & Emery partner to its Washington, D.C., office.
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January 29, 2025
Tax Group Of The Year: Mayer Brown
Mayer Brown LLP's bench of tax talent is so deep that it can help its clients sell the Chicago Cubs one day and buy $646 million of Brazilian solar farms on another. The firm's ability to offer tax transaction and advisory services across industries, transaction types and specialty areas earned it a place among the 2024 Law360 Tax Groups of the Year.
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January 29, 2025
Lawyers, Ex-Tax Inspector Took £278M From Trust, Court Rules
A London appeals court has upheld a High Court ruling that two solicitors and a former senior tax manager devised a scheme to cut out beneficiaries from Jersey trusts in what they saw as a "huge commercial opportunity" to divert an estimated £278 million ($345 million) to themselves.
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January 29, 2025
Swiss Gov't Initiates Consultation On Pillar 2 Data Sharing
The Swiss government said Wednesday it has begun a consultation on approving a global framework for countries to exchange corporate taxpayer information under an international minimum tax agreement known as Pillar Two.
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January 29, 2025
EU Will Keep Minimum Tax Despite US, Commissioner Says
The European Union will maintain a 15% minimum corporate tax rate on large companies despite the U.S. government's opposition to the global tax deal, a European commissioner said Wednesday.
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January 29, 2025
HMRC Looking For Input On Pillar 2 Backstop Guidance
HM Revenue & Customs is looking for input on its guidance for how corporations would need to comply with the U.K.'s proposed adoption of the undertaxed profits rule, a backstop for its Pillar Two global minimum tax system.
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January 29, 2025
EU Tax Conduct Group Reelects Chair
The European Union's Code of Conduct Group reelected its chair for a second term to start next week, the Council of the EU said Wednesday.
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January 28, 2025
IRS Whistleblower Office Could Survive Trump Purge
As President Donald Trump pushes to slash federal spending and gut government agencies, the Internal Revenue Service Whistleblower Office may remain largely unscathed since its recent efforts to efficiently reward and protect those who report illicit tax activity could align with the administration's goals.
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.