International
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December 17, 2024
Cyprus, Facing EU Pressure, Passes Minimum Tax
Cyprus' unicameral legislature passed a bill implementing the Organization for Economic Cooperation and Development's global minimum tax on large multinational entities, according to a local news report, ending its holdout as the final country facing pressure from the European Union to do so.
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December 17, 2024
NY Urges Justices To Pass On IBM, Disney Royalty Tax Fight
The U.S. Supreme Court should decline to hear appeals by IBM and Disney that claim New York state's tax treatment of royalties received from foreign affiliates resulted in unconstitutional discrimination against interstate commerce, the state told the court Tuesday.
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December 17, 2024
Canadian Cabinet Official Takes Over Finance Minster Role
Canada's intergovernmental affairs minister is now also the country's finance minister following the sudden resignation of the previous official to hold the post, who cited conflicting views with Prime Minister Justin Trudeau about how to respond to U.S. tariff threats.
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December 17, 2024
Trinity International Adds Tax Expert To Paris Office
Trinity International LLP announced the addition of an experienced tax attorney from Dentons to serve as a partner in its Paris office.
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December 17, 2024
Japan Signs Double-Tax Treaty With Turkmenistan
Japan and Turkmenistan have reached an agreement on a double-tax treaty to replace the convention Japan had with the Soviet Union, Japan's Ministry of Finance said Tuesday.
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December 17, 2024
Ireland Could Lose €15B Due To Trump, Central Bank Warns
The Irish government could lose up to €15 billion ($15.7 billion) of this year's corporate tax surplus if the incoming U.S. administration changes policy, the Central Bank of Ireland warned Tuesday.
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December 16, 2024
Mich. Judge Troubled By Scope Of Feds' CTA Data Collection
A federal judge in Michigan said new disclosure requirements for small businesses seem burdensome and intrusive during a Monday hearing focused on the privacy implications of the currently blocked anti-money laundering law.
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December 16, 2024
Aussie R&D Scheme Promoters Hit With $8.7M In Penalties
The Federal Court of Australia ordered an Australian, his tax agent and his companies to pay a total of AU$13.6 million ($8.7 million) in penalties for promoting illegal research and development tax fraud schemes, the Australian Taxation Office announced.
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December 16, 2024
Canadian Finance Minister Resigns Amid Trump Tariff Threats
Canada's deputy prime minister and minister of finance announced Monday that she is resigning from her post, citing conflicting views with Prime Minister Justin Trudeau about how to respond to tariff threats under President-elect Donald Trump's incoming administration.
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December 16, 2024
Work Still Needed To Keep VAT In EU Effective, Group Says
Following the European Union's agreement on a value-added tax reform package, a group of EU VAT experts presented a wide-ranging suite of short- and long-term proposals Monday aimed at making sure the bloc's regime remains effective as the landscape continues to shift.
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December 16, 2024
Cos. Urge Judge To Maintain Injunction On Transparency Law
A Texas federal judge doesn't need to stay his preliminary injunction on the rollout of new corporate transparency rules while the U.S. government's appeal of his decision is pending at the Fifth Circuit, a business lobbying group and others said Monday.
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December 16, 2024
Wyden Bill Would Nix Tax Perks For Private Placement Plans
U.S. Senate Finance Committee Chairman Ron Wyden unveiled legislation Monday that would remove the tax benefits of a special type of private life insurance plan that he said high-net-worth individuals have been abusing to avoid paying taxes on their investments in the policies.
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December 16, 2024
HMRC Chief Defends Record On Fighting Tax Evasion
The chief executive of HM Revenue & Customs told Parliament on Monday that the British tax authority has reduced the level of tax noncompliance in response to claims it needs a better strategy on tax evasion.
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December 16, 2024
Info On Over 1,900 Tax Rulings Swapped In OECD Last Year
Tax jurisdictions within the Organization for Economic Cooperation and Development spontaneously shared information related to over 1,900 tax rulings involving foreign companies in 2023, the OECD said Monday, highlighting the widespread adoption of its transparency framework aimed at mitigating harmful tax practices.
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December 16, 2024
Hong Kong Commits To OECD Crypto Reporting Framework
Hong Kong plans to take part in the Organization for Economic Cooperation and Development's framework for automatically exchanging financial information regarding crypto-assets starting in 2028, the jurisdiction's Inland Revenue Department said.
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December 13, 2024
IRS Aims To Ramp Up Partnership Audits, Official Says
The Internal Revenue Service plans to ramp up partnership audits in the next couple of years to boost the current audit rate of 0.05% as the agency props up a new unit that solely focuses on examining large partnerships, an agency attorney said Friday.
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December 13, 2024
OECD Seeks Input On Ring-Fencing Mining Income Guidance
The Organization for Economic Cooperation and Development said Friday that it is looking for feedback on proposed guidance for tax administrations looking to set up ring-fencing measures for mining operations in order to limit investors' ability to offset expenditures and revenues between projects.
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December 13, 2024
Swiss Gov't Rejects Retroactive Tax On Gifts Above $56M
The Swiss federal government formally rejected a wealth tax proposal by the youth wing of the Social Democratic Party of Switzerland on Friday, saying a retroactive 50% tax on gifts and inheritances above 50 million Swiss francs ($56 million) was "politically questionable."
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December 13, 2024
Canada Must Reassess Tax Bills For Ex-Blue Jays, Court Says
Pension contributions made by two former Major League Baseball stars while they played for the Toronto Blue Jays should be counted in their annual income, the Tax Court of Canada ruled in a victory for the former players.
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December 13, 2024
CFC Tax Issues Can't Be Solved Via Treaties, Officials Say
Bilateral treaties between the U.S. and other countries where a controlled foreign corporation may face withholding tax issues aren't able to effectively resolve those disputes, Internal Revenue Service and Treasury officials said Friday.
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December 13, 2024
IRS Mulls Turning Off Foreign Currency Rules For CFCs
The Internal Revenue Service is in the early stages of considering whether foreign currency gain or loss recognition rules could be turned off in certain situations for controlled foreign corporations, an agency official said Friday.
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December 13, 2024
Halliburton Consistent On Claims For $35M Refund, Court Told
Halliburton has not changed its reasons for claiming a tax refund on a $35 million payment it made to a foreign government to protect its employees from harassment, the company told a Texas federal court, saying the U.S. wrongly accused it of a flip-flop.
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December 13, 2024
Taxation With Representation: Kirkland, Davis Polk, Wachtell
In this week's Taxation With Representation, Google and TPG Rise Climate partner with Intersect Power, Gen Digital Inc. acquires MoneyLion Inc., Patient Square Capital acquires Patterson Companies Inc., and the Buffalo Bills and Miami Dolphins sell minority ownership shares to private equity firms.
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December 13, 2024
Canada 2-Month Sales Tax Holiday Begins Saturday
A two-month goods-and-services tax holiday in Canada on certain goods such as gifts and restaurant meals will begin Saturday after having passed the Senate and receiving royal ascension.
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December 13, 2024
Contractor Loses Bail For Texting Alleged Tax Cheat Allies
A District of Columbia federal judge revoked bail for a former defense contractor accused of running a $350 million tax-evasion scheme that prosecutors call one of the largest in U.S. history, after the government said he'd been texting his alleged co-conspirators.
Expert Analysis
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A Post-Mortem Analysis Of Stroock's Demise
After the dissolution of 147-year-old firm Stroock late last year shook up the legal world, a post-mortem analysis of the data reveals a long list of warning signs preceding the firm’s collapse — and provides some insight into how other firms might avoid the same disastrous fate, says Craig Savitzky at Leopard Solutions.
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SG's Office Is Case Study To Help Close Legal Gender Gap
As women continue to be underrepresented in the upper echelons of the legal profession, law firms could learn from the example set by the Office of the Solicitor General, where culture and workplace policies have helped foster greater gender equality, say attorneys at Ocean Tomo.
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Reimagining Law Firm Culture To Break The Cycle Of Burnout
While attorney burnout remains a perennial issue in the legal profession, shifting post-pandemic expectations mean that law firms must adapt their office cultures to retain talent, say Kevin Henderson and Eric Pacifici at SMB Law Group.
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Cayman Islands Off AML Risk Lists, Signaling Robust Controls
As a world-leading jurisdiction for securitization special purpose entities, the removal of the Cayman Islands from increased anti-money laundering monitoring lists is a significant milestone that will benefit new and existing financial services customers conducting business in the territory, say lawyers at Walkers Global.
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The Legal Industry Needs A Cybersecurity Paradigm Shift
As law firms face ever-increasing risks of cyberattacks and ransomware incidents, the legal industry must implement robust cybersecurity measures and privacy-centric practices to preserve attorney-client privilege, safeguard client trust and uphold the profession’s integrity, says Ryan Paterson at Unplugged.
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As Promised, IRS Is Coming For Crypto Tax Evaders
The IRS is fulfilling its promise to crack down on those who have neglected to pay taxes on cryptocurrency earnings, as demonstrated by recently imposed prison sentences, enforcement initiatives and meetings with international counterparts — suggesting a few key takeaways for taxpayer compliance, say attorneys at BakerHostetler.
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5 Reasons Associates Shouldn't Take A Job Just For Money
As a number of BigLaw firms increase salary scales for early-career attorneys, law students and lateral associates considering new job offers should weigh several key factors that may matter more than financial compensation, say Albert Tawil at Lateral Hub and Ruvin Levavi at Power Forward.
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The Pop Culture Docket: Judge Djerassi On Super Bowl 52
Philadelphia Court of Common Pleas Judge Ramy Djerassi discusses how Super Bowl 52, in which the Philadelphia Eagles prevailed over the New England Patriots, provides an apt metaphor for alternative dispute resolution processes in commercial business cases.
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Employee Experience Strategy Can Boost Law Firm Success
Amid continuing business uncertainty, law firms should consider adopting a holistic employee experience strategy — prioritizing consistency, targeting signature moments and leveraging measurement tools — to maximize productivity and profitability, says Haley Revel at Calibrate Consulting.
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6 Practice Pointers For Pro Bono Immigration Practice
An attorney taking on their first pro bono immigration matter may find the law and procedures beguiling, but understanding key deadlines, the significance of individual immigration judges' rules and specialized aspects of the practice can help avoid common missteps, says Steven Malm at Haynes Boone.
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Lessons From Country Singer's Personal Service Saga
Recent reports that country singer Luke Combs won a judgment against a Florida woman who didn’t receive notice of the counterfeit suit against her should serve as a reminder for attorneys on best practices for effectuating service by electronic means, say attorneys at Jenner & Block.
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7 E-Discovery Predictions For 2024 And Beyond
The legal and technical issues of e-discovery now affect virtually every lawsuit, and in the year to come, practitioners can expect practices and policies to evolve in a number of ways, from the expanded use of relevancy redactions to mandated information security provisions in protective orders, say attorneys at Littler.
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5 Litigation Funding Trends To Note In 2024
Over the next year and beyond, litigation funding will continue to evolve in ways that affect attorneys and the larger litigation landscape, from the growth of a secondary market for funded claims, to rising interest rates restricting the availability of capital, says Jeffery Lula at GLS Capital.