International

  • August 23, 2024

    Chamber Backs Doctor In Tax Court Economic Substance Suit

    The U.S. Chamber of Commerce lent its support to an eye doctor and his wife's U.S. Tax Court case disputing accuracy-related penalties that the Internal Revenue Service plans to impose on their microcaptive insurance arrangements for lacking economic substance.

  • August 23, 2024

    IRS Spinoff Guidance Sparks Worries About Short-Term Debt

    Companies that intend to give creditors equity tied to a spinoff transaction won't get early tax-free approval if the exchange involves recently acquired debt under IRS guidance that practitioners say draws an arbitrary line without accounting for ordinary business operations.

  • August 23, 2024

    Alvarez & Marsal Adds Transfer Pricing Expert From EY

    A former EY partner joined Alvarez & Marsal LLC to serve as managing director of its transfer pricing line of services in its New York office, the firm announced.

  • August 23, 2024

    45% Of US Biz Income Abroad In Tax Havens, Data Shows

    U.S. multinational corporations booked about 45% of their $1.33 trillion in net foreign income in 2022 in low-tax jurisdictions where around 1.7% of their employees are located, according to an analysis of data released Friday by the Bureau of Economic Analysis.

  • August 23, 2024

    German Official Backs Anti-Abuse Tax Rules Roll-Back Review

    A German Federal Ministry of Finance official agreed with tax experts' proposal to review the anti-abuse provisions of international tax law in order to potentially roll them back, especially with the global corporate minimum tax going into force across the European Union.

  • August 23, 2024

    Taxation With Representation: Latham, Wachtell, Paul Weiss

    In this week's Taxation With Representation, Arch Resources merges with Consol Energy in a deal worth $5.2 billion, Advanced Micro Devices agrees to purchase ZT Systems for $4.9 billion, and Japanese tobacco company JT Group inks a deal to buy Vector Group for $2.4 billion.

  • August 23, 2024

    HMRC Can Be Liable For Damage To Biz Shut Over £7.4M Debt

    The tax authority cannot lift a court order that requires it to repay a payroll business damages for losses suffered after it was put into provisional liquidation, as a court found on Friday that it had failed to pursue that action for law enforcement purposes.

  • August 22, 2024

    Switzerland Expects 3.2% Tax Receipt Increase In 2025

    Switzerland expects to generate 85.7 billion Swiss francs ($100.6 billion) in tax receipts in 2025, an increase of 3.2% over the 2024 budget, with the biggest growth projected to come from personal income taxes, the country's Federal Finance Administration said Thursday.

  • August 22, 2024

    Kenya's Justices May Ax Part Of Tax Act That Set Off Unrest

    The Supreme Court of Kenya agreed to stay a lower court's ruling declaring unconstitutional the government's entire 2023 tax package, which sparked deadly nationwide protests, but it looks likely to scrap at least part of the law next month, attorneys told Law360 on Thursday.

  • August 22, 2024

    Australian Legislators Advance Enactment Of Global Min. Tax

    Australia would enact the Organization for Economic Cooperation and Development's 15% global corporate minimum tax on large multinational entities, known as Pillar Two, under three bills passed Thursday by the country's House of Representatives.

  • August 22, 2024

    EU Decision Keeps Tax Relief For UK Investment Schemes

    The European Commission will allow U.K. government-backed programs that encourage private investment in small companies to continue offering favorable tax terms for investors, according to a decision published Thursday.

  • August 22, 2024

    Ryanair Threatens Service Cuts Over German Tax Increase

    Irish discount airline Ryanair said it will cut 10% of its German capacity next summer if the country doesn't reverse a recent 24% increase in its aviation tax, calling on Germany to ultimately abolish the tax altogether.

  • August 22, 2024

    Over 3M UK Pensioners To Be Dragged Into Higher Tax Rates

    Government data shows 3.1 million U.K. pensioners will be dragged into paying higher taxes in the next four years due to the freeze on income thresholds, financial firm Quilter PLC said Thursday.

  • August 21, 2024

    Ariz. Man Should Pay Full $2.7M FBAR Bill, Gov't Says

    An Arizona man who failed to report his foreign bank accounts in Switzerland owes approximately $2.7 million in recalculated penalties and interest to the Internal Revenue Service, the U.S. told an Arizona federal court.

  • August 21, 2024

    UK Tax Collection Rises 5% To £829B

    HM Revenue & Customs said Wednesday that the U.K. raised over £829 billion ($1.09 trillion) in taxes in fiscal year 2023-2024, up over 5% from the previous year.

  • August 21, 2024

    9th Circ. Upholds FBAR Penalty, Imposes Contested Interest

    A woman who operates a New Zealand winery must pay $238,000 in penalties and an extra $105,000 in interest and fees for failing to report her New Zealand financial accounts to the U.S. government, the Ninth Circuit ruled Wednesday.

  • August 21, 2024

    3 Questions Raised By Harris' Support For 28% Corp. Tax Rate

    Vice President Kamala Harris has proposed increasing the corporate tax rate to 28% to boost revenue if she's elected president, but the proposed hike raises questions about changes to the corporate tax base, the future of the OECD's global tax deal and the potential impact on workers.

  • August 21, 2024

    Pros Tell IRS To Ease Off Foreign Gift Reporting Penalties

    The Internal Revenue Service should take a more lenient approach when considering penalty abatements for certain individuals who fail to report large foreign gifts under proposed disclosure regulations, practitioners told the agency Wednesday.

  • August 21, 2024

    New Zealand Seeks Feedback On Future Of Tax System

    New Zealand's revenue agency is looking for feedback on plans for a potential broad restructuring of the country's tax system in order to address coming financial pressures, including possibly altering its income and consumption tax regimes, it said Wednesday.

  • August 21, 2024

    Swiss Council Approves Tax Treaty With Jordan

    Switzerland's Federal Council approved a treaty Wednesday to avoid double taxation with Jordan that it says largely follows the Organization for Economic Cooperation and Development's model convention for such agreements.

  • August 21, 2024

    Swiss Extend Tax Exemptions For 'Too Big To Fail' Instruments

    Switzerland's Federal Council decided Wednesday to extend temporary withholding tax exemptions on interest for what it calls too-big-to-fail instruments for banks, such as bail-in or write-off bonds.

  • August 21, 2024

    Germany Opens Consultation On Min. Tax Reporting Changes

    Germany's Federal Ministry of Finance is seeking feedback on a proposal to incorporate updated guidance from the Organization for Economic Cooperation and Development regarding reporting requirements associated with the global corporate minimum tax.

  • August 21, 2024

    VAT Fraudster Loses Bid To Escape Repaying £1.4M

    A man involved in a £40 million ($52 million) criminal tax fraud scheme has lost a bid to avoid repaying £1.4 million as a London court ruled on Wednesday that he had failed to prove he no longer had hidden assets.

  • August 20, 2024

    UN Dives Into Murky Waters Of Taxing Digital Services

    The United Nations has its sights set on cross-border services in the digital economy as its framework convention on tax takes shape, but it remains unclear how countries will define that broad and hotly contested topic as they work toward a treaty.

  • August 20, 2024

    Temple Law Prof, Kostelanetz Atty To Lead ABA Tax Section

    A longtime professor at the Temple University Beasley School of Law and a seasoned tax controversy partner at Kostelanetz LLP will together helm the American Bar Association Section of Taxation for the 2025-2026 term, the firm announced Tuesday.

Expert Analysis

  • Firms Must Rethink How They Train New Lawyers In AI Age

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    As law firms begin to use generative artificial intelligence to complete lower-level legal tasks, they’ll need to consider new ways to train summer associates and early-career attorneys, keeping in mind the five stages of skill acquisition, says Liisa Thomas at Sheppard Mullin.

  • Think Like A Lawyer: Always Be Closing

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    When a lawyer presents their case with the right propulsive structure throughout trial, there is little need for further argument after the close of evidence — and in fact, rehashing it all may test jurors’ patience — so attorneys should consider other strategies for closing arguments, says Luke Andrews at Poole Huffman.

  • Litigation Inspiration: Attys Can Be Heroic Like Olympians

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    Although litigation won’t earn anyone an Olympic medal in Paris this summer, it can be worthy of the same lasting honor if attorneys exercise focused restraint — seeking both their clients’ interests and those of the court — instead of merely pursuing every advantage short of sanctionable conduct, says Bennett Rawicki at Hilgers Graben.

  • Lean Into The 'Great Restoration' To Retain Legal Talent

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    As the “great resignation,” in which employees voluntarily left their jobs in droves, has largely dissipated, legal employers should now work toward the idea of a “great restoration,” adopting strategies to effectively hire, onboard and retain top legal talent, says Molly McGrath at Hiring & Empowering Solutions.

  • Fishing Makes Me A Better Lawyer

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    Atop the list of ways fishing makes me a better lawyer is the relief it offers from the chronic stress of a demanding caseload, but it has also improved my listening skills and patience, and has served as an exceptional setting for building earnest relationships, says Steven DeGeorge​​​​​​​ at Robinson Bradshaw.

  • A Healthier Legal Industry Starts With Emotional Intelligence

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    The legal profession has long been plagued by high rates of mental health issues, in part due to attorneys’ early training and broader societal stereotypes — but developing one’s emotional intelligence is one way to foster positive change, collectively and individually, says attorney Esperanza Franco.

  • To Make Your Legal Writing Clear, Emulate A Master Chef

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    To deliver clear and effective written advocacy, lawyers should follow the model of a fine dining chef — seasoning a foundation of pure facts with punchy descriptors, spicing it up with analogies, refining the recipe and trimming the fat — thus catering to a sophisticated audience of decision-makers, says Reuben Guttman at Guttman Buschner.

  • Circuit Judge Writes An Opinion, AI Helps: What Now?

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    Last week's Eleventh Circuit opinion in Snell v. United Specialty Insurance, notable for a concurrence outlining the use of artificial intelligence to evaluate a term's common meaning, is hopefully the first step toward developing a coherent basis for the judiciary's generative AI use, says David Zaslowsky at Baker McKenzie.

  • Trauma-Informed Legal Approaches For Pro Bono Attorneys

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    As National Trauma Awareness Month ends, pro bono attorneys should nevertheless continue to acknowledge the mental and physical effects of trauma, allowing them to better represent clients, and protect themselves from compassion fatigue and burnout, say Katherine Cronin at Stinson and Katharine Manning at Blackbird.

  • How Attys Can Avoid Pitfalls When Withdrawing From A Case

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    The Trump campaign's recent scuffle over its bid to replace its counsel in a pregnancy retaliation suit offers a chance to remind attorneys that many troubles inherent in withdrawing from a case can be mitigated or entirely avoided by communicating with clients openly and frequently, says Christopher Konneker at Orsinger Nelson.

  • Using A Children's Book Approach In Firm Marketing Content

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    From “The Giving Tree” to “Where the Wild Things Are,” most children’s books are easy to remember because they use simple words and numbers to tell stories with a human impact — a formula law firms should emulate in their marketing content to stay front of mind for potential clients, says Seema Desai Maglio at The Found Word.

  • New Crypto Reporting Will Require Rigorous Recordkeeping

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    The release of a form for reporting digital asset transactions is a pivotal moment in the Internal Revenue Service's efforts to track cryptocurrency activities that increases oversight by requiring brokers to report investor sales and exchanges, say Shaina Kamen and Max Angel at Holland & Knight.

  • Exploring An Alternative Model Of Litigation Finance

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    A new model of litigation finance, most aptly described as insurance-backed litigation funding, differs from traditional funding in two key ways, and the process of securing it involves three primary steps, say Bob Koneck, Christopher Le Neve Foster and Richard Butters at Atlantic Global Risk LLC.

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