International
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July 17, 2024
Rising Star: Cravath's Kiran Sheffrin
Kiran Sheffrin of Cravath Swaine & Moore LLP has advised companies from Anheuser-Busch InBev to Valvoline on multibillion-dollar deals, including a $50 billion combination resulting in the formation of pharmaceutical giant Viatris, earning her a spot among the tax law practitioners under age 40 honored by Law360 as Rising Stars.
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July 17, 2024
Woman Can't Escape Suit Over Partner's $1.1M FBAR Debt
A woman whose late romantic partner owed $1.1 million in reporting penalties on hidden financial accounts in France and Switzerland can't stop the government from pursuing a suit against her for half the value of her home, a New York federal court ruled.
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July 17, 2024
Baker McKenzie Adds EY Partner To Mexico City Office
Baker McKenzie has appointed a new partner from EY Mexico to its North American tax practice group in Mexico City.
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July 17, 2024
Estonia Expects Solutions From EU Chair On VAT Law
Estonia said Wednesday that it expects "constructive solutions" from the current chair of European Union meetings regarding changes to value-added tax law, which Estonia blocked during meetings of EU finance ministers in May and June.
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July 17, 2024
Labour Gov't To Make Fiscal Rules Law, Empower OBR
The new Labour government will legislate to write into law the Treasury's long-held fiscal rules and grant new powers to the Office for Budget Responsibility to scrutinize policy, according to plans confirmed in the King's Speech on Wednesday.
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July 16, 2024
Intracompany Prices Should Reflect Acquired IP, Panelists Say
When one company buys another for its intellectual property, the subsequent pricing of that asset between the now-related entities should reflect the value of what was acquired, transfer pricing specialists said Tuesday at a conference in Washington, D.C.
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July 16, 2024
More Geographic Adjustments 'On The Table' For Amount B
Countries' ability to make further adjustments for geographic differences in the streamlined transfer pricing approach known as Amount B — part of the OECD's plan for reallocating taxing rights among jurisdictions — is "still on the table," an official from the organization said Tuesday.
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July 16, 2024
Va. Tax Head Nixes Assessment On Man For Work In India
A Virginia man was wrongly assessed income tax for services he conducted while living in India, the state's tax commissioner said in a letter ruling published Tuesday.
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July 16, 2024
Tax Transparency Neglected In Latin America, Ex-Officials Say
The international tax transparency system is failing to produce results for Latin American governments, whose scant information requests are too often met with resistance and whose prosecutions generally lack a cross-cutting approach to tax, former officials from the region said Tuesday.
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July 16, 2024
DC Circ. Upholds Dismissal Of Tax Whistleblower Award Case
The D.C. Circuit upheld Tuesday the U.S. Tax Court's dismissal of a Mississippi man's case seeking review of the denial of his whistleblower claim for 30% of the revenue collected by an Internal Revenue Service offshore voluntary disclosure program.
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July 16, 2024
EU Opposed Fast-Tracking Reforms Under UN Tax Convention
The European Union is concerned that a majority of countries want to create early protocols simultaneously with a United Nations framework convention on international tax cooperation, according to a statement endorsed Tuesday by the bloc's finance ministers.
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July 16, 2024
Australian Tax Pros Push Back On Updated Code Of Conduct
Ten groups representing tax professionals in Australia said the government should reconsider newly passed changes to the country's code of conduct for tax agent services, saying the rules have created inconsistencies and uncertainties.
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July 16, 2024
Rising Star: Skadden's Melinda Gammello
Melinda Gammello of Skadden Arps Slate Meagher & Flom LLP has advised numerous clients before the U.S. Tax Court and elsewhere on complex tax matters, including transfer pricing issues and the treatment of financial transactions within a company, earning her a spot among the tax law practitioners under 40 honored by Law360 as Rising Stars.
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July 16, 2024
The 2024 Diversity Snapshot: What You Need To Know
Law firms' ongoing initiatives to address diversity challenges have driven another year of progress, with the representation of minority attorneys continuing to improve across the board, albeit at a slower pace than in previous years. Here's our data dive into minority representation at law firms in 2023.
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July 16, 2024
These Firms Have The Most Diverse Equity Partnerships
Law360’s law firm survey shows that firms' efforts to diversify their equity partner ranks are lagging. But some have embraced a broader talent pool at the equity partner level. Here are the ones that stood out.
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July 16, 2024
Turkish Parliament Considering Global Minimum Tax
Turkey's Parliament is considering implementing the Organization for Economic Cooperation and Development's 15% global minimum tax on some large multinational corporations alongside other tax changes, according to news reports Tuesday.
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July 16, 2024
3 Tax Reg Groups That May Be Shaky After High Court Rulings
The U.S. Supreme Court issued two rulings that, when combined, open up long-standing federal regulations to challenges without judicial deference to agencies — a pairing that could weaken several categories of tax rules, including guidance issued under the 2017 federal overhaul. Here, Law360 looks at three batches of tax regulations that may be vulnerable in the aftermath of the high court's decisions.
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July 16, 2024
Labour Government Urged To Introduce Green Tax Credits
The new Labour government should introduce tax credits for businesses investing in green energy technology, according to a tax expert from the Confederation of British Industry.
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July 16, 2024
EU Leader Stresses Importance Of Digital VAT Law
The head of the European Union's council of members stressed on Tuesday the importance of an agreement on a change to EU VAT law that was blocked by one member country in consecutive meetings in May and June.
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July 16, 2024
Top UK Court Rules Deal Advice Fees Are Not Tax Deductible
Britain's Supreme Court ruled Tuesday that £2.5 million ($3.2 million) paid in advisory fees by an investment company to Deutsche Bank and others is not tax-deductible as the expenses were "capital in nature" spent trying to dispose of a Dutch business.
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July 15, 2024
CarMax Distorted SC Activity To Lower Taxes, Judge Says
CarMax Auto Superstores Inc. used intercompany transactions to distort an entity's business activity and thus its tax burden in South Carolina, an administrative law judge ruled, finding the company should have used an alternative apportionment method to properly calculate income.
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July 15, 2024
Distributions Were Not Dividends, Canada Tax Court Says
Distributions to shareholders after the sale of a Canadian video game company were properly taxed as employee benefits instead of dividends, the Tax Court of Canada ruled.
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July 15, 2024
Israeli Firm Seeks To Amend Suit Against GILTI Regs
The owner of an Israeli law firm asked a D.C. federal court to let him amend his challenge to regulations for the U.S. tax on global intangible low-taxed income after the D.C. Circuit determined parts of his arguments went unconsidered.
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July 15, 2024
Former Doctor Seeks Jail Release In FBAR Fight
An incarcerated former doctor asked a Michigan federal court Monday to lift its order of civil contempt for his failure to pay about $1 million in foreign account reporting penalties, saying he has done all he can to repatriate offshore securities.
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July 15, 2024
Widow To Pull $1.7M From Swiss Bank To Pay FBAR Penalties
A logger's widow agreed to pull about $1.7 million from her Swiss bank account to pay down penalties that her late husband's estate owes the IRS for his failure to report offshore accounts, according to a filing Monday in a Colorado federal court.
Expert Analysis
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What IRS Funding Increase Means For Taxpayers
The Internal Revenue Service will first use the influx of funding from the Inflation Reduction Act to address customer support and personnel issues, but with over half the money allocated to enforcement, corporations and high-net-worth individuals will face increased scrutiny, say Patrick McCann Jr. and Jasen Hanson at Chamberlain Hrdlicka.
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6 Tax Considerations For Life Sciences Collaboration Deals
Given recent IRS guidance and changes to certain tax rates and deductions, biotech and life sciences companies entering into collaboration agreements should assess several unique taxation issues affecting matters ranging from research and development expenditures to profit-sharing terms, say attorneys at Orrick and Andersen Tax.
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Rushed Multilateral Negotiations Caused Two-Pillar Tax Mess
Cracks appearing in the two pillars of the 2021 global tax plan stem from a multilateral tax policy process that rushed to issue rules without first resolving fundamental differences between countries or ensuring that the U.S., a key player, could implement them, says Jefferson VanderWolk at Squire Patton.
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Key Considerations For Seeking Relief From Double Taxation
Caroline Setliffe and E. Miller Williams at Eversheds Sutherland lay out the Organization for International Cooperation and Development’s mutual agreement procedure for settling double-taxation disputes, and discuss six factors U.S. taxpayers doing business in multiple countries should consider when determining the most advantageous form of relief.
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2 Tax Decisions Hold Key Transfer Pricing Takeaways
Richard Slowinski and Stefanie Kavanagh at Alston & Bird discuss two recent decisions in cases against the IRS — Eaton Corp. from the Sixth Circuit and Medtronic from the Tax Court — that may help clarify when the agency can cancel an advance pricing agreement, but leave unanswered questions about which pricing method applies to high-value intercompany licensing transactions.
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Digital Taxation Is Necessary, But Tough To Manage
The U.S. government has started to tackle complex new tax laws as the digital economy continues to grow, but this demands guidelines that will facilitate the growth while protecting investors and the government's finances, say attorneys at Cadwalader.
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Company Considerations For Cash Award Incentives: Part 2
Excerpt from Practical Guidance
Cash awards can help companies address some issues associated with equity awards to compensate employees, but due to potential downsides, they should be treated as a tool in a long-term incentive program rather than a panacea, say Denise Glagau and Kela Shang at Baker McKenzie.
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Company Considerations For Cash Award Incentives: Part 1
Excerpt from Practical Guidance
Denise Glagau and Kela Shang at Baker McKenzie discuss what companies must consider when offering cash awards outside of U.S. jurisdictions, and explain how some challenges associated with equity awards may be addressed with cash awards.
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What AML Bill Could Mean For Firms, Funds And FinCEN
If passed, an amendment within Congress’ annual defense bill would expand the list of institutions subject to anti-money laundering regulations, from law firms to investment funds, creating potential rulemaking and enforcement challenges for the Financial Crimes Enforcement Network, say attorneys at Arnold & Porter.
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Unpacking The New Stock Buyback Tax And Its Exceptions
Xenia Garofalo and Kyle Colonna at Eversheds Sutherland discuss provisions of the recently enacted tax on corporate stock repurchases, how its exceptions may be applied and what companies should consider when evaluating the cost of new or existing programs.
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Inside The OECD Transfer Pricing Documentation Guidance
Excerpt from Practical Guidance
The Organization for Economic Cooperation and Development's recently modified documentation guidelines can assist tax administrations in developing requirements for transfer pricing risk assessments and evaluations, and help multinational entity taxpayers demonstrate satisfaction of the arm's-length principle, says Neil Aragones at Lexis Tax.
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A Close Look At The Decentralized Effort To Tax Digital Assets
Clarity on taxation is one of the biggest hurdles to mass adoption of cryptocurrency, and although digital asset innovation has consistently outpaced worldwide government regulation, recent efforts in the U.S. and elsewhere hint at an emerging standard, says Joshua Smeltzer at Gray Reed.
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Key Takeaways From IRS Reversal On FDII Stance
The Internal Revenue Service's recent memo regarding allocation of deferred compensation expenses for purposes of foreign-derived intangible income is a departure from the agency's previous position and may have implications beyond the context of deferred compensation, say attorneys at Miller & Chevalier.