International

  • October 18, 2024

    Bahamas' Parliament To Consider Global Min. Tax Bill

    Qualifying businesses in the Bahamas would be subject to one portion of the OECD's 15% global corporate minimum income tax on large multinational entities making over €750 million ($815 million) annually, under legislation sent to the country's Parliament.

  • October 18, 2024

    IRS OKs Rules On Withholding For Pension Payments

    The Internal Revenue Service released final rules Friday covering certain retirement plans' obligation to withhold income tax when they make payments or distributions to taxpayers outside the U.S. starting in 2026.

  • October 18, 2024

    Taxation With Representation: Baker, Simpson, Ropes

    In this week's Taxation With Representation, Lundbeck inks a $2.6 billion cash deal for Longboard, Silver Lake agrees to buy Zuora for $1.7 billion, and PPG and American Industrial Partners reach a $550 million deal.

  • October 17, 2024

    Liberty Global Shouldn't Get $248M Tax Credit, 10th Circ. Told

    Liberty Global distorted the language and statutory scheme of the U.S. tax code's foreign tax credit regulations to falsely claim $248 million in credits, the U.S. government told the Tenth Circuit on Thursday.

  • October 17, 2024

    India's Top Court Allows Bank To Deduct 'Broken' Interest

    Interest that an Indian bank paid for government securities during what is known as the broken period between coupon payment dates is tax-deductible, the Supreme Court of India ruled, overturning a lower court.           

  • October 17, 2024

    Financial Crime Body To Focus On High-Income Countries

    An intergovernmental task force updated Thursday its criteria for placing countries on its list of those with deficiencies in their anti-money laundering and terrorist financing systems in order to focus on higher-income countries, which it said pose a higher risk than low-income countries.

  • October 17, 2024

    Swedish VAT Exemption Threshold Applies Cross-Border

    Sweden's coming increase in the country's threshold for when businesses must begin collecting value-added tax will apply to certain companies based in other European Union member countries for their Swedish operations and to Swedish companies operating in other EU member countries, Sweden's legislature said.

  • October 17, 2024

    Vestager Urges EU Politicians To Push Ahead With Pillar 1

    European Union competition chief Margrethe Vestager urged EU politicians Thursday to push ahead with work to finalize the Pillar One plan to redistribute taxing rights among countries.

  • October 17, 2024

    Polsinelli Hires McDermott Tax Counsel In DC

    Polsinelli PC has hired an attorney who joined the firm's tax group as a shareholder after 12 and a half years with McDermott Will & Emery LLP.

  • October 17, 2024

    EU Frequent Flyer Tax Could Raise €64B, Think Tank Says

    The European Union could raise an estimated €63.6 billion ($68.9 billion) in revenue by taxing frequent flyers, according to a think tank report published Thursday.

  • October 16, 2024

    Japan Signs Double-Tax Treaty With Armenia

    Japan and Armenia have reached an agreement on a double-tax treaty to replace the convention Japan had with the Soviet Union, Japan's Ministry of Finance said Wednesday.

  • October 16, 2024

    Spain's High Court Annuls Rulings Denying R&D Deductions

    Spain's Supreme Court overturned a lower court's ruling that sided with a decision from revenue officials to ignore a report from the country's science ministry when denying corporate tax deductions for research and development.

  • October 16, 2024

    Swedish Parliament To Consider Global Min. Tax Amendments

    Sweden's government sent draft amendments regarding the country's implementation of the Organization for Economic Cooperation and Development's 15% global corporate minimum tax to its Parliament for consideration, the country's Ministry of Finance said.

  • October 16, 2024

    Switzerland Enshrines Ability To Tax Certain Telecommuters

    Switzerland has ensured it will be able to tax employees' earned income if they telework in their country of residence for an employer based in Switzerland — under certain circumstances — starting in 2025, the country's executive body said Wednesday.

  • October 16, 2024

    Romania Suspends Double-Tax Treaty With Russia

    Romania has completely suspended its double-tax treaty with Russia in response to Russia's cessation of parts of the treaty last year, the Romanian Ministry of Finance said Wednesday.

  • October 15, 2024

    Irish Tax-To-GDP Ratio Expected To Drop In 2025

    Ireland's tax revenue as a share of its gross domestic product is projected to drop to 25.3% in 2025 as a result of tax measures included in the country's budget proposal, a drop of 3.1 percentage points compared with projections for this year, the country's Department of Finance said Tuesday.

  • October 15, 2024

    Israel-US Citizen Owes $1.1M In FBAR Penalties, US Says

    A dual Israeli-American citizen who owns a Chicago pub faces more than $1 million in penalties for failing to report bank accounts that he maintained in Israel, the U.S. government told an Illinois federal court.

  • October 15, 2024

    New ABA Tax Chair Wants To Revamp Practice's Dry Image

    The new chair of the American Bar Association Section of Taxation told Law360 she wants to boost the section's recent efforts to revamp the tax practice's image as a boring, numbers-intensive profession with limited opportunities to improve society and inspire more students to enter tax law. Here, she shares her background and goals for the tax section.

  • October 15, 2024

    Alvarez & Marsal Tax Brings On Restructuring Leader

    Alvarez & Marsal's tax affiliate added a restructuring professional from investment bank Houlihan Lokey to serve as its head of global restructuring tax services.

  • October 15, 2024

    Isle Of Man Could Generate £35M Annually From Min. Tax

    The Isle of Man's planned implementation of parts of the Organization for Economic Cooperation and Development's global corporate minimum tax on large multinational entities could generate as much as £35 million ($45 million) for the jurisdiction annually, its Treasury said Tuesday.

  • October 15, 2024

    V&E Adds Energy Tax Pro From Bracewell In Houston

    Vinson & Elkins LLP has bolstered its energy transition and tax practices with a partner in Houston who came aboard from Bracewell LLP and whose background includes substantial in-house experience advising on renewable projects.

  • October 15, 2024

    Starmer Hints At National Insurance Hike Over Capital Gains

    British Prime Minister Keir Starmer on Tuesday again refused to rule out raising employers' National Insurance, a payroll levy used to fund social programs, after downplaying claims that his government is planning to raise the capital gains tax.

  • October 15, 2024

    Law Firms Diverge As Anti-ESG Pushback Continues

    A continuing onslaught of legislation and litigation opposing corporate environmental, social and governance actions has created a fork in the road for law firms, with some choosing to scale back efforts and others pushing ahead with their internal ESG and diversity, equity and inclusion goals.

  • October 15, 2024

    The 2024 Law360 Pulse Social Impact Leaders

    Check out our Social Impact Leaders ranking, analysis and interactive graphics to see which firms stand out for their engagement with social responsibility and commitment to pro bono service.

  • October 11, 2024

    Danish Tax Agency Sniffs Out $367M In VAT Fraud

    The Danish Tax Agency said it has issued collections for roughly 2.5 billion Danish kroner ($367 million) since 2018 against companies it discovered were carrying out cross-border value-added tax fraud schemes known as VAT carousels.

Featured Stories

  • New ABA Tax Chair Wants To Revamp Practice's Dry Image

    Kat Lucero

    The new chair of the American Bar Association Section of Taxation told Law360 she wants to boost the section's recent efforts to revamp the tax practice's image as a boring, numbers-intensive profession with limited opportunities to improve society and inspire more students to enter tax law. Here, she shares her background and goals for the tax section.

  • Disputes May Loom Over Dividend Deductions For CFCs

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    U.S. multinational corporations are concerned that rulemakers' interpretation of a law allowing tax-free repatriation of certain overseas earnings could lead to controversy after the Internal Revenue Service published a memo indicating the break is unavailable for controlled foreign corporations.

  • Election Uncertainty Hampers Companies' Tax Planning

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    With the November election approaching, businesses are bracing for the potential impact of two very different sets of tax policies, with the resulting uncertainty making long-term tax planning increasingly difficult.

Expert Analysis

  • Use The Right Kind Of Feedback To Help Gen Z Attorneys

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    Generation Z associates bring unique perspectives and expectations to the workplace, so it’s imperative that supervising attorneys adapt their feedback approach in order to help young lawyers learn and grow — which is good for law firms, too, says Rachael Bosch at Fringe Professional Development.

  • Congress Can And Must Enact A Supreme Court Ethics Code

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    As public confidence in the U.S. Supreme Court dips to historic lows following reports raising conflict of interest concerns, Congress must exercise its constitutional power to enact a mandatory and enforceable code of ethics for the high court, says Muhammad Faridi, president of the New York City Bar Association.

  • What To Make Of Dueling Corporate Transparency Act Rulings

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    Although challenges to the Corporate Transparency Act abound — as highlighted by recent federal court decisions from Alabama and Oregon taking opposite positions on its constitutionality — the act is still law, so companies should comply with their filing requirements or face the potential consequences, say attorneys at Lowenstein Sandler.

  • Pop Culture Docket: Justice Lebovits On Gilbert And Sullivan

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    Characters in the 19th century comic operas of Gilbert and Sullivan break the rules of good lawyering by shamelessly throwing responsible critical thought to the wind, providing hilarious lessons for lawyers and judges on how to avoid a surfeit of traps and tribulations, say acting New York Supreme Court Justice Gerald Lebovits and law student Tara Scown.

  • State Of The States' AI Legal Ethics Landscape

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    Over the past year, several state bar associations, as well as the American Bar Association, have released guidance on the ethical use of artificial intelligence in legal practice, all of which share overarching themes and some nuanced differences, say Eric Pacifici and Kevin Henderson at SMB Law Group.

  • 8 Childhood Lessons That Can Help You Be A Better Attorney

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    A new school year is underway, marking a fitting time for attorneys to reflect on some fundamental life lessons from early childhood that offer a framework for problems that no legal textbook can solve, say Chris Gismondi and Chris Campbell at DLA Piper.

  • This Election, We Need To Talk About Court Process

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    In recent decades, the U.S. Supreme Court has markedly transformed judicial processes — from summary judgment standards to notice pleadings — which has, in turn, affected individuals’ substantive rights, and we need to consider how the upcoming presidential election may continue this pattern, says Reuben Guttman at Guttman Buschner.

  • Mental Health First Aid: A Brief Primer For Attorneys

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    Amid a growing body of research finding that attorneys face higher rates of mental illness than the general population, firms should consider setting up mental health first aid training programs to help lawyers assess mental health challenges in their colleagues and intervene with compassion, say psychologists Shawn Healy and Tracey Meyers.

  • The Trade And Tax Issues Behind US-Canada Digital Tax Clash

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    The new Canadian digital services tax recently went into effect despite objections from the U.S., a controversy that represents an unusual mix of trade and tax policy, and many companies have been pondering how it will affect their e-commerce businesses, says Damon Pike at BDO.

  • Litigation Inspiration: Honoring Your Learned Profession

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    About 30,000 people who took the bar exam in July will learn they passed this fall, marking a fitting time for all attorneys to remember that they are members in a specialty club of learned professionals — and the more they can keep this in mind, the more benefits they will see, says Bennett Rawicki at Hilgers Graben.

  • AI May Limit Key Learning Opportunities For Young Attorneys

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    The thing that’s so powerful about artificial intelligence is also what’s most scary about it — its ability to detect patterns may curtail young attorneys’ chance to practice the lower-level work of managing cases, preventing them from ever honing the pattern recognition skills that undergird creative lawyering, says Sarah Murray at Trialcraft.

  • Ruling On Foreign Dividend Break Offers 2 Tax Court Insights

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    In Varian v. Commissioner, the U.S. Tax Court allowed a taxpayer's deduction for dividends from foreign subsidiaries, providing clarity on how the U.S. Supreme Court’s Loper Bright decision may affect challenges to Treasury regulations, and revealing a potential disallowance of foreign tax credits, say attorneys at Davis Polk.

  • Why Now Is The Time For Law Firms To Hire Lateral Partners

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    Partner and associate mobility data from the second quarter of this year suggest that there's never been a better time in recent years for law firms to hire lateral candidates, particularly experienced partners — though this necessitates an understanding of potential red flags, say Julie Henson and Greg Hamman at Decipher Investigative Intelligence.