International
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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.
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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.
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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.
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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.
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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.
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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.
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October 02, 2024
Mongolia Ratifies OECD Tax Treaty Standards
Mongolia ratified the Organization for Economic Cooperation and Development's multilateral convention on base erosion and profit shifting, which updates bilateral tax treaties of its signatories with agreed-upon standards, the OECD said Wednesday.
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October 02, 2024
4 Arrested In €97M VAT Fraud Involving Phone Service
Four people were arrested in Italy for their suspected roles in a value-added tax fraud scheme involving services that let users make phone calls via the internet that sought to claim over €97 million ($107 million) in fraudulent refunds, the European Public Prosecutor's Office said Wednesday.
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October 02, 2024
Canada Finalizes Surtax List For Chinese Steel, Aluminum
Canada's Department of Finance issued its finalized list of Chinese-made steel and aluminum products that will be hit with a 25% surtax when imported into the country starting later this month.
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October 01, 2024
Tax Deadlines Extended For Victims Of Israel-Hamas War
The Internal Revenue Service said Tuesday that it will postpone tax return and payment deadlines to Sept. 30, 2025, for those affected by the Israel-Hamas war across 2023 and 2024.
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October 01, 2024
Amgen Must Face Suit It Misled Investors On $10.7B Tax Bill
Amgen lost an attempt to escape a potential class action claiming the pharmaceutical giant hid a $10.7 billion tax bill from investors after a New York federal court ruled there was sufficient evidence for the action to proceed.
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October 01, 2024
Ex-USTR Official Sees Possible Path Forward For Digital Taxes
The U.S. may withhold trade threats if it believes countries are having good-faith conversations about concerns that their digital services taxes discriminate against U.S. businesses, including in current talks with Canada, the former general counsel for the Office of the U.S. Trade Representative told Law360.
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October 01, 2024
Ireland Eyes Infrastructure With €14B From ECJ Apple Case
The Irish government is aiming to build infrastructure with the €14.1 billion ($15.6 billion) in corporate tax payments due from Apple Inc. following a European Court of Justice ruling that Ireland granted Apple illegal state aid, officials said Tuesday in announcing next year's budget.
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October 01, 2024
EU Chief Prosecutor Calls For Making Tax Fraud A Priority
As organized crime rings continue to affect the European Union budget through "massive" value-added tax and customs fraud schemes, more must be done to support the European Public Prosecutor's Office and its power to investigate such crimes, the European chief prosecutor said in remarks published Tuesday.
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October 01, 2024
Treasury Plans Final Direct Pay Partnership Regs By Year-End
The U.S. Treasury Department is eyeing the end of the year to finalize regulations for development projects to elect out of their partnership tax status to qualify for a direct cash payment of their clean energy tax credits, an official said Tuesday.
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October 01, 2024
EU General Court To Begin Hearing VAT Cases
The European Union General Court can make preliminary rulings in cases involving the EU's common system of value-added taxes, effective Tuesday, as part of an expansion of the court's jurisdiction.
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October 01, 2024
UK Tax Havens Tied To $84B In Lost Revenue, Group Says
The British Virgin Islands, Cayman Islands and Bermuda held on to their spots atop the Tax Justice Network's tax havens list, with the group saying Tuesday that the U.K.'s tax havens network is responsible for a third of global corporate tax abuse risks.
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October 01, 2024
Estate Exaggerating Value Of Exec's Tax Tipoff, DC Circ. Told
A Dutch bank executive's estate is "vastly" overstating the significance of his tips to the IRS in seeking a whistleblower award for his reporting of tax schemes, the U.S. government told the D.C. Circuit, urging it to uphold the U.S. Tax Court's denial of the award.
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September 30, 2024
Corporate Tax Rates Up In 2023, OECD Annual Report Finds
A global trend toward cutting taxes to address the economics of the COVID-19 pandemic began to wane in 2023, with more nations willing to raise taxes and broaden tax bases to fund social spending, the Organization of Economic Cooperation and Development said Monday.
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September 30, 2024
PwC Agrees To $63M Fine For Evergrande Audit, China Says
PwC's chairman agreed to the firm's six-month suspension in China and nearly $63 million in fines over its Chinese auditing arm's work for Evergrande Group, which until a court-ordered liquidation in January was the country's largest real estate firm, the country's Finance Ministry said Monday.
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September 30, 2024
IRS Seeks Input On Draft Partnership Basis-Shifting Form
The Internal Revenue Service asked for comments Monday on a draft form and instructions for partners to disclose all the property they receive from partnerships, part of upcoming regulations meant to target abusive tax avoidance that uses sophisticated partnership basis-shifting transactions.
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September 30, 2024
German Lawyer Charged Over €428M Cum-Ex Fraud
A lawyer has been charged in Germany with several counts of "serious tax evasion" over his alleged role in a €428 million ($477 million) so-called cum-ex dividend tax fraud, a German court confirmed Monday.
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September 30, 2024
Feds Seek Prison In Tax Case Linked To 'China Initiative'
Prosecutors have asked a Texas federal judge for an 18- to 24-month prison sentence for a Chinese-born engineer who pled guilty to tax crimes after being charged with export violations and fraud in a case the defense claims began as an espionage investigation under the U.S. Department of Justice's now-disbanded "China Initiative."
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September 30, 2024
IRS Appeals Office Tests Group Mailbox For Large Cos.
The Internal Revenue Service's Independent Office of Appeals announced Monday that it will test out a program intended to help enhance secure messaging for large businesses with multiple representatives by allowing them to request a group mailbox to communicate with their assigned Appeals employee.
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September 30, 2024
Aussie 2023-24 Budget Delivered Surplus Despite Tax Dip
Australia ended the 2023-24 fiscal year with an AU$15.8 billion ($11 billion) surplus, larger than what the government had projected and primarily due to spending cuts, not higher taxes, according to the country's annual report, published Monday.
Expert Analysis
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How Law Firms Can Avoid 'Collaboration Drag'
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.
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Litigation Funding Disclosure Key To Open, Impartial Process
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.
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What NFL Draft Picks Have In Common With Lateral Law Hires
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.
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Replacing The Stigma Of Menopause With Law Firm Support
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.
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Planning Law Firm Content Calendars: What, When, Where
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.
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Law Firms Should Move From Reactive To Proactive Marketing
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.
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The Big Issues A BigLaw Associates' Union Could Address
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.
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It's Time For A BigLaw Associates' Union
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.
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How Justices Upended The Administrative Procedure Act
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.
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Tips For Tax Equity-Tax Credit Transfers That Pass IRS Muster
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.
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Mirror, Mirror On The Wall, Is My Counterclaim Bound To Fall?
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.
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3 Leadership Practices For A More Supportive Firm Culture
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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E-Discovery Quarterly: Rulings On Hyperlinked Documents
Recent rulings show that counsel should engage in early discussions with clients regarding the potential of hyperlinked documents in electronically stored information, which will allow for more deliberate negotiation of any agreements regarding the scope of discovery, say attorneys at Sidley.