International
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October 30, 2024
Pillar 2 Likely To Cast Shadow Over US Tax Bill Talks
The international minimum tax agreement known as Pillar Two won't officially factor into upcoming tax bill negotiations in the U.S. Congress, but the global regime's potential grab at U.S. tax revenue could informally influence policy choices.
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October 30, 2024
Tax Court Stands By Couple's Tax Liability After Remand
An investor couple whose case was remanded by the Sixth Circuit is still liable for over $603,000 in deficient taxes tied to $3 million in claimed losses from a complex foreign-exchange derivative arrangement since their actions were not made with legitimate intentions of turning a profit, the U.S. Tax Court said Wednesday.
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October 30, 2024
GOP Lawmakers Criticize Treasury's Start Of Taiwan Tax Talks
The top tax-writing Republicans in Congress said Wednesday that the U.S. Treasury Department's announcement that it would begin negotiations with Taiwan on a double-tax relief agreement risks undermining legislation to address the issue that is stalled in the Senate.
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October 30, 2024
Canadian Can't Claim $15.8M In Losses From Forex Trades
A Canadian businessman can't claim CA$22 million ($15.8 million) in losses as deductions because the foreign exchange trades generating them were not pursued for profit, the Tax Court of Canada ruled.
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October 30, 2024
South African Parliament To Consider Global Minimum Tax
Qualifying businesses in South Africa would be subject to two parts of the OECD's 15% global minimum tax on large multinational entities making more than €750 million ($815 million) annually under legislation sent to the country's Parliament on Wednesday.
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October 30, 2024
UK's VAT Gap Rises £1.4B In 2023-24, Initial Estimate Says
The gap between the amount of value-added tax the U.K. expected to collect in the 2023-24 tax year and the amount actually collected was an estimated £9.5 billion ($12.3 billion), a £1.4 billion increase over the final estimate for the year prior, HM Revenue & Customs said Wednesday.
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October 30, 2024
UK Capital Gains Hike Casts Shadow Over Gov't LSE Aims
The decision by Chancellor Rachel Reeves to raise the tax paid on gains made when shares are sold could hinder the government's work on making the London Stock Exchange more attractive for stock listings and investors, regulatory experts warn.
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October 30, 2024
Last UK Gov't 'Did Not Share' Spending Info With Watchdog
The independent fiscal watchdog said Wednesday that the last Conservative administration had failed to disclose public spending information, adding that it would have resulted in a "materially different" forecast for government spending if it had been given the data.
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October 30, 2024
Pension Pros Say Shutting Inheritance Tax Loophole Overdue
Retirement industry professionals said Wednesday that the budget announcement by the U.K. government that it would remove a loophole that allowed the transfer of more than £1 million ($1.3 million) of inherited pension wealth without paying inheritance tax was overdue.
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October 30, 2024
Labour Gov't Unveils £40B Tax Boost In First Budget
A £40 billion ($52 billion) tax package unveiled on Wednesday by Britain's new Labour government targets business and investors and aims to plug fiscal gaps with plans including higher levies on payrolls and capital gains.
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October 29, 2024
Rimon Adds International Tax Expert In Philadelphia
Rimon PC has added an expert in international tax and trusts and estates who joined the firm's Philadelphia office after working for his own practice.
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October 29, 2024
Croatia, Australia Reach Double Tax Treaty Agreement
Croatia and Australia have agreed on a treaty to avoid double taxation that will take effect when passed by the respective legislatures, the Croatian Ministry of Finance said.
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October 29, 2024
States Should Cede Profit-Shifting Fight To OECD, Atty Says
States should shy away from using mandatory worldwide combined reporting to address profit shifting and instead allow the Organization for Economic Cooperation and Development to police tax avoidance from multinational corporations, a business trade group attorney said Tuesday.
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October 29, 2024
Switzerland Amends Double Tax Treaty With Kuwait
Switzerland said Tuesday it has ratified changes to its double taxation treaty with Kuwait that are due to take effect early next year.
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October 29, 2024
US, Taiwan To Begin Talks On Double-Tax Agreement
The U.S. and Taiwan announced Tuesday that they will begin a first round of negotiations to craft a double-tax avoidance agreement that would provide certain treaty-like benefits.
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October 28, 2024
Russia Says High Court Case May Help Nix $5B Award Suit
Russia has told a D.C. federal court that a case recently accepted for review by the U.S. Supreme Court may provide it a path to argue that the court lacks jurisdiction to decide a case brought against the country by a Yukos Oil Co. unit.
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October 28, 2024
Latin America, Caribbean Must Up Tobacco Taxes, OECD Says
Latin American and Caribbean countries must increase their tobacco excise tax levels, among other changes, to reduce the overall affordability of tobacco products to drive people to quit using them, the Organization for Economic Cooperation and Development said Monday.
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October 28, 2024
UK Construction Co. Due £3.2M In R&D Credits, Refunds
A construction contractor is entitled to tax credits and refunds totaling over £3.2 million ($4.2 million) after the U.K.'s First-tier Tribunal ruled that its expenditures for research and development were not subsidized or contracted out by another party.
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October 28, 2024
European Commission Backs Simplified Minimum Tax Filing
Multinational corporations could file returns for the 15% global minimum tax with a single country in the European Union that they would share with the others only where necessary under a proposal approved Monday by the bloc's executive branch, according to officials.
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October 28, 2024
Labour Budget Expected To Target Taxes At Biz, Investors
The U.K. government is set to unveil its budget statement Wednesday after months of hinting at higher taxes, and experts say businesses and investors are bracing to bear the brunt of the possible tax changes, such as through increases to capital gains and payroll taxes.
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October 28, 2024
Chile Provides Guidance For Voluntary Disclosure Program
Chile's tax agency provided guidance Monday for taxpayers interested in voluntarily disclosing their previously undeclared foreign assets in order to take advantage of a temporarily available tax rate.
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October 28, 2024
IRS Extends Relief For FATCA Filings Without ID Numbers
Foreign financial institutions that report information on U.S. account holders to the Internal Revenue Service without including the taxpayer identification numbers associated with those accounts won't be flagged for noncompliance for the next three years, the agency said Monday.
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October 28, 2024
Wise Boss Hit With FCA Fine For Not Disclosing Tax Penalty
The finance regulator said on Monday that it has fined the chief executive of a money transfer company £350,000 ($454,500) for his failure to tell the watchdog he had been penalized by HM Revenues and Customs for not paying his taxes.
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October 28, 2024
US Expatriations Tick Up In 3rd Quarter, IRS Says
The number of people who expatriated from the U.S. rose during the third quarter of the year compared with the previous quarter, the Internal Revenue Service said Monday.
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October 25, 2024
German Drug Co. Due £21.5M VAT Refund, UK Tribunal Finds
A German pharmaceutical provider is entitled to a refund of almost £21.5 million ($27.9 million) for the value-added tax it paid on the rebated portion of products supplied to the U.K.'s National Health Service, the British First-tier Tribunal ruled.
Expert Analysis
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Practicing Law With Parkinson's Disease
This Parkinson’s Awareness Month, Adam Siegler at Greenberg Traurig discusses his experience working as a lawyer with Parkinson’s disease, sharing both lessons on how to cope with a diagnosis and advice for supporting colleagues who live with the disease.
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Why Supreme Court Should Allow Repatriation Tax To Stand
If the U.S. Supreme Court doesn't reject the taxpayers' misguided claims in Moore v. U.S. that the mandatory repatriation tax is unconstitutional, it could wreak havoc on our system of taxation and result in a catastrophic loss of revenue for the government, say Christina Mason and Theresa Balducci at Herrick Feinstein.
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For Lawyers, Pessimism Should Be A Job Skill, Not A Life Skill
A pessimistic mindset allows attorneys to be effective advocates for their clients, but it can come with serious costs for their personal well-being, so it’s crucial to exercise strategies that produce flexible optimism and connect lawyers with their core values, says Krista Larson at Stinson.
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Requiring Leave To File Amicus Briefs Is A Bad Idea
A proposal to amend the Federal Rules of Appellate Procedure that would require parties to get court permission before filing federal amicus briefs would eliminate the long-standing practice of consent filing and thereby make the process less open and democratic, says Lawrence Ebner at the Atlantic Legal Foundation and DRI Center.
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4 Ways To Motivate Junior Attorneys To Bring Their Best
As Gen Z and younger millennial attorneys increasingly express dissatisfaction with their work and head for the exits, the lawyers who manage them must understand and attend to their needs and priorities to boost engagement and increase retention, says Stacey Schwartz at Katten.
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Former Minn. Chief Justice Instructs On Writing Better Briefs
Former Minnesota Supreme Court Chief Justice Lorie Gildea, now at Greenberg Traurig, offers strategies on writing more effective appellate briefs from her time on the bench.
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Stay Interviews Are Key To Retaining Legal Talent
Even as the economy shifts and layoffs continue, law firms still want to retain their top attorneys, and so-called stay interviews — informal conversations with employees to identify potential issues before they lead to turnover — can be a crucial tool for improving retention and morale, say Tina Cohen Nicol and Kate Reder Sheikh at Major Lindsey.
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Neb. Justices Should Weigh IRC Terms In Dividend Tax Case
Nebraska’s highest court, which will hear oral arguments in Precision CastParts v. Department of Revenue on April 1, should recognize that the Internal Revenue Code provides key clues to defining “dividends received or deemed to be received,” and therefore limits Nebraska’s tax on foreign-sourced corporate income, says Joseph Schmidt at Ryan.
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Judicial Independence Is Imperative This Election Year
As the next election nears, the judges involved in the upcoming trials against former President Donald Trump increasingly face political pressures and threats of violence — revealing the urgent need to safeguard judicial independence and uphold the rule of law, says Benes Aldana at the National Judicial College.
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Spartan Arbitration Tactics Against Well-Funded Opponents
Like the ancient Spartans who held off a numerically superior Persian army at the Battle of Thermopylae, trial attorneys and clients faced with arbitration against an opponent with a bigger war chest can take a strategic approach to create a pass to victory, say Kostas Katsiris and Benjamin Argyle at Venable.
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What Recent Study Shows About AI's Promise For Legal Tasks
Amid both skepticism and excitement about the promise of generative artificial intelligence in legal contexts, the first randomized controlled trial studying its impact on basic lawyering tasks shows mixed but promising results, and underscores the need for attorneys to proactively engage with AI, says Daniel Schwarcz at University of Minnesota Law School.
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How FinCEN Proposal Expands RE Transaction Obligations
Against a regulatory backdrop foreshadowing anti-money laundering efforts in the real estate sector, the Financial Crimes Enforcement Network's proposed rule significantly expands reporting requirements for certain nonfinanced residential real estate transfers and necessitates careful review, say attorneys at Fried Frank.
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Litigation Inspiration: A Source Of Untapped Fulfillment
As increasing numbers of attorneys struggle with stress and mental health issues, business litigators can find protection against burnout by remembering their important role in society — because fulfillment in one’s work isn’t just reserved for public interest lawyers, say Bennett Rawicki and Peter Bigelow at Hilgers Graben.