International

  • December 10, 2024

    Morgan Lewis Gets DLA Piper Tax Pro With DOJ Experience

    Morgan Lewis & Bockius LLP announced that it has added to its Boston office a tax attorney from DLA Piper who served as an appellate attorney at the U.S. Department of Justice, Tax Division.

  • December 10, 2024

    FBAR Default Against Widow Should Be Vacated, Judge Says

    A New York federal magistrate judge recommended vacating a default judgment against a widow, which would give her a second chance to defend her dead husband's estate against U.S. government claims that it owes $275,000 for his failure to report his account at an Indian bank.

  • December 10, 2024

    African Tax Revenue Ratio Up, Still Well Behind OECD Average

    While the average ratio of total tax revenue to gross domestic product in 36 surveyed African countries rose in 2022, it still sits at just 16%, less than half of the 33.9% average for Organization for Economic Cooperation and Development countries, the OECD said Tuesday.

  • December 10, 2024

    Exxon's Tax Win Sets Path For Liberty Global, 10th Circ. Told

    A ruling allowing Exxon Mobil a U.S. tax deduction for interest expenses in its natural gas deal with Qatar confirms that Liberty Global is entitled to a deduction related to its sale of a Belgian affiliate, an attorney for the telecommunications company told the Tenth Circuit.

  • December 10, 2024

    EU Reaches Deal On Digital VAT Exemption Certificate

    The European Union reached an agreement Tuesday to replace the current paper version of certificates for value-added tax exemptions with a digital version, though the form itself will still need to be developed.

  • December 10, 2024

    EU To Introduce Digital Certificate For Withholding Tax Relief

    The Council of the European Union said Tuesday that it has agreed on new withholding rules that grant easy access to tax relief for cross-border investors through a common digital tax residence certificate.

  • December 10, 2024

    HMRC Staff Vote To Strike Over Sacking Of 3 Colleagues

    More than 200 staff members at an HM Revenue and Customs office have voted to strike for up to eight weeks in protest over the firing of three colleagues, allegedly for taking part in other industrial action.

  • December 10, 2024

    Treasury Finalizes Simplified Foreign Currency Rules

    The U.S. Treasury Department finalized regulations Tuesday that aim to simplify aspects of how corporations determine taxable income or loss with respect to certain affiliates that conduct business in a foreign currency.

  • December 10, 2024

    Jockey Frankie Dettori Named In HMRC Tax Avoidance Battle

    Italian jockey Frankie Dettori has been named as the individual who attempted to maintain his anonymity to keep private his legal battle with HM Revenue and Customs over a tax avoidance scheme, according to a London court judgment.

  • December 09, 2024

    US Investment Cos. Benefit In Updated Norway Tax Treaty

    Regulated U.S. investment and holding companies should be able to reap Norwegian tax treaty benefits on dividends, royalties and capital gains without restriction under an updated agreement announced Monday by the Internal Revenue Service.

  • December 09, 2024

    Microsoft Wrong On Foreign Earnings, Ore. Tells Tax Court

    The Oregon Tax Court was correct to reject alternatives pitched by Microsoft for treatment of its repatriated foreign earnings when calculating Oregon taxable income, the state tax department told the court.

  • December 09, 2024

    UN Tax Pact Should Include Climate Focus, Report Says

    Coming negotiations for a global tax convention at the United Nations should include discussions about designing tax policies that could generate resources to help address climate change, according to a report published Monday by the advocacy group Tax Justice Network.

  • December 09, 2024

    Woman Appeals Tax Court's Canadian Debt Ruling To 9th Circ.

    A woman appealed to the Ninth Circuit a U.S. Tax Court decision that prevented her from challenging a federal tax lien issued by the Internal Revenue Service to secure her $200,000 tax debt to Canada on behalf of the Canadian government. 

  • December 09, 2024

    16 EU Members Call For Revamped Tobacco Taxation

    The European Commission needs to prioritize an overhaul of the bloc's tobacco taxation rules in the upcoming term, a group of 16 member countries said Monday, arguing that major changes in the industry since the rules last updated have left countries to fend for themselves, fragmenting the tax regime.

  • December 09, 2024

    Man Owed $264K Under US-Canada Tax Treaty, Court Says

    A U.S. man living abroad is allowed under the U.S.-Canada tax treaty to claim a foreign tax credit for nearly $264,000 in payments of the Affordable Care Act's net investment income tax, the Federal Claims Court said.

  • December 09, 2024

    Latin America Should Improve Tax Collection, OECD Says

    Latin American and Caribbean countries' average tax-to-gross-domestic-product ratio falls well below the Organization for Economic Cooperation and Development average, and improvements will be key to the area's ability to meet sustainable development goals, the OECD said Monday.

  • December 09, 2024

    UAE Implementing Global Minimum Tax In 2025

    Large multinational businesses in the United Arab Emirates making at least €750 million ($792 million) annually will be subject to the OECD's 15% corporate global minimum tax starting in 2025, the country's Finance Ministry said Monday.

  • December 09, 2024

    Proposed Canadian Tax Holiday Will Cost $1B, Office Says

    Canada's proposed two-month goods-and-services tax holiday on certain goods would result in the loss of at least CA$1.46 billion ($1 billion) in federal tax revenues, a Canadian budget watchdog said Monday.

  • December 09, 2024

    Germany Floats Plans To Adopt Additional Min. Tax Guidance

    Germany's Federal Ministry of Finance is seeking feedback on additional proposed updates to its legislation under an international minimum tax agreement known as Pillar Two, including incorporating global guidance on how to approach deferred taxes.

  • December 09, 2024

    Insurer Launches Estate Planning Cover After Tax Changes

    Royal London said on Monday that it has launched an insurance product designed to help consumers with their end-of-life planning, as a growing number of estates are set to become subject to inheritance tax after recent government changes.

  • December 06, 2024

    DC Circ. Affirms Man's $1.2M 'Seriously Delinquent' Tax Debt

    A Florida man owes more than $1.2 million in federal taxes, the D.C. Circuit said Friday, affirming the Internal Revenue Service's certification of his liability under a law that allows those with a "seriously delinquent" tax debt to have their passport revoked.

  • December 06, 2024

    NZ Considering Edits To 'Internationally Unusual' Tax Regime

    New Zealand's government received feedback that its rules for taxing investments of 10% or less in foreign companies may be discouraging people who hold interests in such entities from moving to the country, and it is seeking feedback on possible solutions, its tax authority said Friday.

  • December 06, 2024

    Gov't Appeals Texas Judge's Block On Anti-Laundering Law

    The U.S. government has appealed a Texas federal judge's order that halted the rollout of new reporting requirements aimed at unmasking anonymous shell companies, setting the stage for the Fifth Circuit to weigh in on the nationwide preliminary injunction.

  • December 06, 2024

    Simpson Thacher Adds Tax Pro From Ropes & Gray

    Simpson Thacher & Bartlett LLP announced the firm has added a tax professional from Ropes & Gray LLP as a partner in its Washington, D.C., office.

  • December 06, 2024

    Authorities Investigating Possible €200M German VAT Fraud

    The European Public Prosecutor's Office carried out searches at a Munich bank as part of an investigation into a man who created a fictitious business to process more than €200 million ($211 million) in funds generated from a value-added tax fraud scheme, the EPPO said Friday.

Expert Analysis

  • Pro Bono Work Is Powerful Self-Help For Attorneys

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    Oct. 22-28 is Pro Bono Week, serving as a useful reminder that offering free legal help to the public can help attorneys expand their legal toolbox, forge community relationships and create human connections, despite the challenges of this kind of work, says Orlando Lopez at Culhane Meadows.

  • The Pop Culture Docket: Judge Espinosa On 'Lincoln Lawyer'

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    The murder trials in Netflix’s “The Lincoln Lawyer” illustrate the stark contrast between the ethical high ground that fosters and maintains the criminal justice system's integrity, and the ethical abyss that can undermine it, with an important reminder for all legal practitioners, say Judge Adam Espinosa and Andrew Howard at the Colorado 2nd Judicial District Court.

  • How And Why Your Firm Should Implement Fixed-Fee Billing

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    Amid rising burnout in the legal industry and client efforts to curtail spending, pivoting to a fixed-fee billing model may improve client-attorney relationships and offer lawyers financial, logistical and stress relief — while still maintaining profit margins, say Kevin Henderson and Eric Pacifici at SMB Law Group.

  • How Law Firms Can Use Account-Based Marketing Strategies

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    Amid several evolving legal industry trends, account-based marketing can help law firms uncover additional revenue-generating opportunities with existing clients, with key considerations ranging from data analytics to relationship building, say Jennifer Ramsey at stage LLC and consultant Gina Sponzilli.

  • Strategic Succession Planning At Law Firms Is Crucial

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    Senior partners' reluctance to retire, the rise of the nonequity partner tier and generational differences in expectations are all contributing to an increasing number of departures from BigLaw, making it imperative for firms to encourage retirement among senior ranks and provide clearer leadership pathways to junior attorneys, says Laura Leopard at Leopard Solutions.

  • Maximizing Law Firm Profitability In Uncertain Times

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    As threats of an economic downturn loom, firms can boost profits by embracing the power of bottom-line management and creating an ecosystem where strategic financial oversight and robust timekeeping practices meet evolved client relations, says Shireen Hilal at Maior Strategic Consulting.

  • 5th Circ. Ruling Reminds Attys That CBP Can Search Devices

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    The Fifth Circuit’s recent Malik v. Department of Homeland Security decision adds to the chorus of federal courts holding that border agents don’t need a warrant to search travelers’ electronic devices, so attorneys should consider certain special precautions to secure privileged information when reentering the U.S., says Jennifer Freel at Jackson Walker.

  • Enforcement Of International Tax Reporting Is Heating Up

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    Since the U.S. Supreme Court’s February decision in Bittner v. U.S. changed how penalties for failure to report offshore accounts are calculated, recent developments suggest the government is preparing to step up enforcement and vigorously pursue the collection of resulting penalties, say Daniel Silva and Agustin Ceballos at Buchalter.

  • IRS Notice Clarifies R&E Amortization, But Questions Remain

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    The IRS and Treasury Department’s recent notice clarifying the treatment of specified research and experimental expenditures under Section 174 provides taxpayers and practitioners with substantive guidance, but it misses the mark in delineating which expenditures are amortizable, say attorneys at Eversheds Sutherland.

  • Preparing Your Legal Department For Pillar 2 Compliance

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    Multinational entities should familiarize themselves with Pillar Two of the Organization for Economic Cooperation and Development’s BEPs 2.0 project and prepare their internal legal tracking systems for related reporting requirements that may go into effect as early as January, says Daniel Robyn at Ernst & Young.

  • What Large Language Models Mean For Document Review

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    Courts often subject parties using technology assisted review to greater scrutiny than parties conducting linear, manual document review, so parties using large language models for document review should expect even more attention, along with a corresponding need for quality control and validation, say attorneys at Sidley.

  • Participating In Living History Makes Me A Better Lawyer

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    My role as a baron in a living history group, and my work as volunteer corporate counsel for a book series fan association, has provided me several opportunities to practice in unexpected areas of law — opening doors to experiences that have nurtured invaluable personal and professional skills, says Matthew Parker at the Nebraska Department of Health and Human Services.

  • Private Equity Owners Can Remedy Law Firms' Agency Issues

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    Nonlawyer, private-equity ownership of law firms can benefit shareholders and others vulnerable to governance issues such as disparate interests, and can in turn help resolve agency problems, says Michael Di Gennaro at The Law Practice Exchange.

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