International

  • June 25, 2024

    Global Tax Overhaul Won't Squash Competition, US Rep. Says

    The global tax overhaul designed by the Organization for Economic Cooperation and Development won't eliminate countries competing for companies' investments, a U.S. House lawmaker said Tuesday.

  • June 25, 2024

    EU Leaders To Include Tax Revamp In 5-Year Plan, Draft Says

    A targeted makeover of the tax systems in European Union countries will be part of the bloc's top priorities for the next five years as it aims to improve business financing to sharpen its competitiveness, a draft document suggested.

  • June 25, 2024

    New EU Chair Hungary Eyes Talks On Corp. Tax, But No Deals

    Hungary, the incoming chair of meetings of European Union countries, plans to discuss energy taxation and several proposals on corporate taxation during the next six months but doesn't expect to reach any agreements, according to meeting agendas.

  • June 24, 2024

    Miner Wins $9.6M In Royalty Fight With Colombia

    An international tribunal ordered Colombia to pay $9.56 million to a British mining and metals company following a dispute over royalties collected on a nickel mine, as the tribunal concluded that there had been "irregularities" in the way the country calculated the amount due.

  • June 24, 2024

    UN Tax Work Threatens OECD's Progress, EU Official Says

    The United Nations' efforts to consider international tax issues risk upending the early finished work of countries negotiating a global tax plan at the Organization for Economic Cooperation and Development, a top European Commission tax official said Monday.

  • June 24, 2024

    Better Digital Tax Ban In Pillar 1 Treaty, Treasury Official Says

    The final text of a multilateral convention to implement the OECD-designed taxing rights overhaul will include improved language to eliminate existing digital services tax and prohibit prospective ones, a U.S. Treasury Department official said Monday.

  • June 24, 2024

    Loss Guidance Will Cover Pillar 2, IRS Official Says

    Forthcoming guidance to address U.S. tax issues with dual consolidated losses will also include language advising taxpayers how to account for those losses under the Pillar Two global minimum tax, the IRS' top international tax counsel said Monday.

  • June 24, 2024

    UN Tax Convention Should Be Crafted Carefully, NFTC Says

    The United Nations' work toward a framework convention on international tax cooperation is welcome but should be done carefully and with continued input from stakeholders, the National Foreign Trade Council said, providing specific areas of feedback.

  • June 24, 2024

    German Banker's Cum-Ex Trial Dropped Due To Health

    The former chairman of M.M. Warburg & Co. KGaA will not face trial for alleged dividend-tax evasion linked to cum-ex transactions spanning from 2006 to 2019 after a German court halted the trial due to his health, according to a Monday court statement.

  • June 24, 2024

    Asia Tax Transparency Generated €1.8B In Revenue In 2023

    Tax transparency measures in 13 Asian jurisdictions collected at least €1.8 billion ($1.9 billion) in extra tax revenue in 2023 alone as such mechanisms continue to be adopted in the region, the Organization for Economic Cooperation and Development reported Monday.

  • June 24, 2024

    EU Dodges Hungary To Send Ukraine €1.4B In Russian Profits

    European Union foreign ministers agreed Monday to send €1.4 billion ($1.5 billion) of windfall profits from frozen and immobilized Russian state assets in military support to Ukraine next month, finding a legal loophole to bypass a potential veto from Hungary.

  • June 24, 2024

    OECD Tax Plan Issues Still Being Hashed Out, US Official Says

    Both the global minimum corporate tax and taxing rights overhaul plans designed by the Organization for Economic Cooperation and Development have outstanding issues that stakeholders are attempting to resolve, a U.S. Treasury Department official said at a conference Monday.

  • June 24, 2024

    EU States Turn Down Transfer Pricing Proposal, Report Says

    European Union countries have declined to accept a new law on transfer pricing that the EU's executive proposed last year, a report published by the body representing EU member states showed Monday.

  • June 24, 2024

    French PM Hopeful Sees VAT Stay As Anti-Inflation Tool

    A hopeful to become the next prime minister of France wants to use the suspension of value-added tax to counter the effects of inflation, an outline of policy proposals released Monday showed.

  • June 21, 2024

    UK Tax Fraud Cases Rose 49% Over One-Year Period

    The U.K. tax authority launched more criminal cases for tax fraud for the year ended June 30, 2023, increasing 49% from 63 cases for the previous year to 94, Pinsent Masons LLP said Monday.

  • June 21, 2024

    Supreme Court Leaves Lifeline For Billionaire Income Tax

    The U.S. Supreme Court narrowed but did not entirely block the path to billionaire income tax legislation when the majority's opinion declined to weigh constitutional questions about taxing unrealized gains in its decision to uphold a mandatory repatriation levy.

  • June 21, 2024

    USTR Warns Canada After Digital Services Tax Enactment

    The U.S. Trade Representative's Office remains concerned about Canada's enactment of its digital services tax and is weighing options in defense of potential discrimination against U.S. businesses, a USTR official told Law360 on Friday.

  • June 21, 2024

    Fed. Circ. Backs Subsidy Duties For Canadian Wind Towers

    A Canadian wind tower manufacturer can't get a break on countervailing duties despite being upfront about errors in its sales data, with the Federal Circuit ruling Friday that the errors raise the possibility of additional mistakes.

  • June 21, 2024

    US Formally Suspends Part Of Tax Treaty With Russia

    The U.S. government has provided formal notice to Russia suspending, via mutual agreement, parts of the countries' double-taxation treaty.

  • June 21, 2024

    Big 4 Continue Push For Broader Irish Dividend Exemption

    The Big Four accounting firms reiterated support for Ireland's plans to implement a corporate tax exemption for foreign-sourced dividends and foreign branch profits, but they found the latest proposal still too narrow and complicated to qualify for, according to comments released Friday.

  • June 21, 2024

    Norway Seeking Feedback On Undertaxed Profits Rule

    Norway is looking for feedback on a proposal that would implement the undertaxed profits rule, one component of the Organization for Economic Cooperation and Development's 15% corporate global minimum tax plan, the country's Finance Ministry said.

  • June 21, 2024

    OECD Official Sees Amount B Deal Helping With Amount A

    The Organization for Economic Cooperation and Development is close to a final deal on a key part of its efforts to establish new international taxing rights under Amounts A and B of its Pillar One plans, according to the organization's tax chief.

  • June 21, 2024

    Taxation With Representation: Travers Smith, Potamitis Vekris

    In this week's Taxation With Representation, RSK Group Ltd. gets a £500 million ($632 million) investment, Boston Scientific Corp. acquires Silk Road Medical Inc., Masdar takes a part of Terna Energy SA, and Tate & Lyle PLC buys CP Kelco from JM Huber Corp.

  • June 21, 2024

    EU Digital Tax Is Backup If Pillar 1 Stalls, French Official Says

    Finalizing the Pillar One agreement to reallocate corporate taxing rights globally should remain a paramount goal, but if the effort stalls, the European Union should revive its plan for a digital tax of mostly U.S.-based tech giants, French Finance Minister Bruno Le Maire said Friday.

  • June 21, 2024

    Estonia Again Blocks Agreement On VAT Deal

    For the second straight month, Estonia blocked agreement Friday on a European Union proposal for platform companies such as Airbnb, Uber and Estonia-based Bolt to collect value-added tax on behalf of service providers.

Expert Analysis

  • How Clients May Use AI To Monitor Attorneys

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    Artificial intelligence tools will increasingly enable clients to monitor and evaluate their counsel’s activities, so attorneys must clearly define the terms of engagement and likewise take advantage of the efficiencies offered by AI, says Ronald Levine at Herrick Feinstein.

  • The Pop Culture Docket: Judge D'Emic On Moby Grape

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    The 1968 Moby Grape song "Murder in My Heart for the Judge" tells the tale of a fictional defendant treated with scorn by the judge, illustrating how much the legal system has evolved in the past 50 years, largely due to problem-solving courts and the principles of procedural justice, says Kings County Supreme Court Administrative Judge Matthew D'Emic.

  • Breaking Down High Court's New Code Of Conduct

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    The U.S. Supreme Court recently adopted its first-ever code of conduct, and counsel will need to work closely with clients in navigating its provisions, from gift-giving to recusal bids, say Phillip Gordon and Mateo Forero at Holtzman Vogel.

  • Legal Profession Gender Parity Requires Equal Parental Leave

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    To truly foster equity in the legal profession and to promote attorney retention, workplaces need to better support all parents, regardless of gender — starting by offering equal and robust parental leave to both birthing and non-birthing parents, says Ali Spindler at Irwin Fritchie.

  • A Year-End Look At Florida's Capital Investment Tax Credit

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    Notwithstanding the Walt Disney Co.’s feud with Gov. Ron DeSantis this year, Florida's capital investment tax credit will continue to make the state a favored destination for large corporations, particularly in light of the new federal alternative minimum tax and the Pillar Two top-up tax, says Alan Lederman at Gunster.

  • Understanding Discovery Obligations In Era Of Generative AI

    Excerpt from Practical Guidance
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    Attorneys and businesses must adapt to the unique discovery challenges presented by generative artificial intelligence, such as chatbot content and prompts, while upholding the principles of fairness, transparency and compliance with legal obligations in federal civil litigation, say attorneys at King & Spalding.

  • The Case For Post-Bar Clerk Training Programs At Law Firms

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    In today's competitive legal hiring market, an intentionally designed training program for law school graduates awaiting bar admission can be an effective way of creating a pipeline of qualified candidates, says Brent Daub at Gilson Daub.

  • AI Can Help Lawyers Overcome The Programming Barrier

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    Legal professionals without programming expertise can use generative artificial intelligence to harness the power of automation and other technology solutions to streamline their work, without the steep learning curve traditionally associated with coding, says George Zalepa at Greenberg Traurig.

  • Preparing Law Students For A New, AI-Assisted Legal World

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    As artificial intelligence rapidly transforms the legal landscape, law schools must integrate technology and curricula that address AI’s innate challenges — from ethics to data security — to help students stay ahead of the curve, say Daniel Garrie at Law & Forensics, Ryan Abbott at JAMS and Karen Silverman at Cantellus Group.

  • General Counsel Need Data Literacy To Keep Up With AI

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    With the rise of accessible and powerful generative artificial intelligence solutions, it is imperative for general counsel to understand the use and application of data for myriad important activities, from evaluating the e-discovery process to monitoring compliance analytics and more, says Colin Levy at Malbek.

  • Navigating Discovery Of Generative AI Information

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    As generative artificial intelligence tools become increasingly ubiquitous, companies must make sure to preserve generative AI data when there is reasonable expectation of litigation, and to include transcripts in litigation hold notices, as they may be relevant to discovery requests, say Nick Peterson and Corey Hauser at Wiley.

  • Finding Focus: Strategies For Attorneys With ADHD

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    Given the prevalence of ADHD among attorneys, it is imperative that the legal community gain a better understanding of how ADHD affects well-being, and that resources and strategies exist for attorneys with this disability to manage their symptoms and achieve success, say Casey Dixon at Dixon Life Coaching and Krista Larson at Stinson.

  • Attorneys, Law Schools Must Adapt To New Era Of Evidence

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    Technological advancements mean more direct evidence is being created than ever before, and attorneys as well as law schools must modify their methods to account for new challenges in how this evidence is collected and used to try cases, says Reuben Guttman at Guttman Buschner.

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