International
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July 25, 2024
Global Tax Revamp Continues To Progress, OECD Tells G20
Implementation of the Pillar Two minimum tax portion of the OECD's international plan to address tax base erosion and profit shifting is well underway, while an agreement is close on the Pillar One taxing rights overhaul, the organization told the Group of 20 nations Thursday.
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July 25, 2024
UK Telecom Co. Owes VAT For Phone Plans In £51M Dispute
A U.K. telecommunications provider will not recover £51.1 million ($65.7 million) in value-added tax payments after the First-tier Tribunal ruled that VAT is chargeable on phone plans from the point of sale, not when the services are used.
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July 25, 2024
Global Tax Police Unit Probes More Than 30 Cybercrime Cases
The Joint Chiefs of Global Tax Enforcement, an intergovernmental tax enforcement group, is investigating more than 30 active cybercrime cases tied to financial and tax criminal activities all over the world, the group announced Thursday in its first report.
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July 25, 2024
Income Inequality Calls For Stronger Tax Policies, OECD Says
More focus is being drawn to stronger tax policies as a way to solve persistent income inequality, especially in light of the continually increasing concentration of wealth by the top 0.001% of earners, the Organization for Economic Cooperation and Development said Thursday.
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July 25, 2024
Mixed Progress Made On Beneficial Ownership, OECD Says
The U.S., Japan and the European Union now have wide-reaching beneficial ownership registries in place, but many jurisdictions worldwide aren't effectively exchanging data on the owners of legal entities, the OECD said Thursday in a report based on peer reviews.
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July 25, 2024
Australian Officials Defend Basis for Tax Reporting Framework
Australia's public corporate tax disclosure legislation builds on global standards that could provide more insights into profit shifting risks than European Union reporting rules, Australian government officials said Thursday in response to calls for closer alignment between the two regimes.
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July 25, 2024
Billionaire Tax Not Fit For Global Agreement, Yellen Says
The U.S. government doesn't think it's appropriate to seek a global agreement on taxing billionaires, Treasury Secretary Janet Yellen said Thursday ahead of a discussion by the Group of 20 nations on coordinating wealth taxes.
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July 25, 2024
58 Jurisdictions Plan For Crypto Info Swaps By 2027
Fifty-eight tax jurisdictions have pledged to implement the Organization for Economic Cooperation and Development's crypto-asset information exchange system by 2027, the OECD said Thursday.
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July 25, 2024
Wyden Seeks Swiss Bank Info On Indicted Defense Contractor
Senate Finance Committee Chairman Ron Wyden asked Swiss bank UBS in a letter published Thursday for information about a former U.S. defense contractor who the Department of Justice says avoided taxes on more than $350 million in income.
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July 25, 2024
Clark Hill Adds Tax And Estate Atty From Plunk Smith In Texas
A former Plunk Smith PLLC senior associate jumped to Clark Hill in Collin County, Texas, to serve as a member in the tax and estate planning practice, the firm announced Thursday.
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July 25, 2024
GOP Control Could Muddle Tax Picture For Multinationals
Republican lawmakers and former President Donald Trump could create more confusion for multinationals with their tax and trade policies if they sweep the U.S. elections in November, because they are likely to pursue retaliatory measures in opposition to the OECD's global tax rewrite.
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July 25, 2024
Cyprus Consents To Pillar 2 Safe Harbor Rules
Cyprus has formally consented to the Organization for Economic Cooperation and Development's Pillar Two safe harbor rules, continuing its support for the organization's push against tax base erosion and profit shifting despite not being a full member, the Cypriot finance ministry said.
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July 25, 2024
Gov'ts Seek Info On Foreign Real Estate Holdings, OECD Says
Governments are keen to receive information on their residents' foreign real estate holdings, especially related to disposals and regular income from owning properties, which could be achieved with a new treaty under the existing tax transparency framework, the OECD said Thursday.
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July 25, 2024
Belgium Taken To EU Court Over Deposit Exemption Rules
The European Union's executive branch said Thursday that it is taking Belgium to court alleging that the country's system of exempting remuneration of savings deposits from tax violates EU law.
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July 24, 2024
Int'l Firm Garrigues Merges With Full-Service Mexican Firm
International legal and tax services firm Garrigues will create one of the largest law firms in Mexico by integrating a full-service Mexican firm into the group by the end of 2024, both firms announced.
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July 24, 2024
Nigerian Parliament Passes 70% Bank Windfall Levy
The upper house of Nigeria's Parliament passed an amendment to its finance bill that included a 70% one-time levy on banks' foreign exchange gains, an increase over the 50% rate originally proposed by the country's president.
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July 24, 2024
IRS' $15M Jeopardy Assessment OK'd In Offshore Tax Fight
A Florida federal court has upheld a $15 million immediate tax assessment against a man who transferred his father's estate into trusts for himself and his mother and refused to pay what the IRS claimed was tax debt on his father's undisclosed offshore accounts.
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July 24, 2024
Affordable Housing Pro Moves Practice To Nelson Mullins
An attorney who specializes in advising clients on completing affordable housing development projects has recently moved her practice to Nelson Mullins Riley & Scarborough's Pittsburgh office.
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July 24, 2024
HMRC Wins Battle Over Candy Maker's Holiday Fund Scheme
HM Revenue & Customs has convinced an appeals tribunal that a Scottish sweet maker must compensate its employees for salary deductions it put aside in "holiday funds," with the judge finding the scheme ran afoul of national minimum wage regulations.
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July 24, 2024
Germany Failing To Address Nonprofits' Tax Status, EU Says
Germany has failed to make any progress addressing uncertainty surrounding the tax-exempt status of nonprofit organizations a year after the European Commission recommended it do so, the commission said Wednesday.
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July 24, 2024
Dentons Brings On Former Big 4 Exec As New Global CEO
Global law firm Dentons, which has made a name for itself by aggressive growth through combinations, has tapped a new global chief executive officer with leadership experience at accounting giant EY, the firm's first change at the top in over a decade.
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July 24, 2024
Phillips Lytle Private Wealth Pro Joins Gunster In Florida
Gunster has announced that the firm picked up an of counsel for its private wealth services team in West Palm Beach, Florida, from Phillips Lytle LLP, as well as three associate attorneys.
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July 24, 2024
Can New Pensions Minister 'Serve Two Masters'?
A new British pensions minister with a foot in two competing government departments could help create a more coherent pensions reforms, although some analysts warn of a potential Treasury takeover of pensions policy to prioritize economic stimulus.
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July 23, 2024
Newell Says IRS Misapplied Pricing Law In $124M Dispute
Newell Brands told the U.S. Tax Court the Internal Revenue Service misapplied transfer pricing law to levy almost $124 million in additional taxes and penalties.
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July 23, 2024
IRS Notice Signals Direction On Corp. AMT Regs, Official Says
An Internal Revenue Service notice regarding the U.S. corporate alternative minimum tax can be read as a signal about how the agency will more broadly address the measure's potential for counting offshore income twice, an IRS official said Tuesday.
Expert Analysis
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Understanding Discovery Obligations In Era Of Generative AI
Excerpt from Practical Guidance
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.
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The Case For Post-Bar Clerk Training Programs At Law Firms
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.
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AI Can Help Lawyers Overcome The Programming Barrier
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.
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Preparing Law Students For A New, AI-Assisted Legal World
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.
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General Counsel Need Data Literacy To Keep Up With AI
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.
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Navigating Discovery Of Generative AI Information
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.
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Finding Focus: Strategies For Attorneys With ADHD
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.
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Attorneys, Law Schools Must Adapt To New Era Of Evidence
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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1st Tax Easement Convictions Will Likely Embolden DOJ, IRS
After recent convictions in the first criminal tax fraud trial over allegedly abusive syndicated conservation easements, the IRS and U.S. Department of Justice will likely pursue other promoters for similar alleged conspiracies — though one acquittal may help attorneys better evaluate their clients' exposure, say Bill Curtis and Lauren DeSantis-Then at Polsinelli.
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Tips For Litigating Against Pro Se Parties In Complex Disputes
Litigating against self-represented parties in complex cases can pose unique challenges for attorneys, but for the most part, it requires the same skills that are useful in other cases — from documenting everything to understanding one’s ethical duties, says Bryan Ketroser at Alto Litigation.
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Anticipating Intensified Partnership Enforcement From IRS
The Internal Revenue Service's decadeslong difficulties with partnership audits led to the recent announcement of a clear, well-funded, focused initiative, and businesses operating in the partnership form will feel the impact, with definite changes ahead, says Sharon Katz-Pearlman at Greenberg Traurig.
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Pro Bono Work Is Powerful Self-Help For Attorneys
Oct. 22-28 is Pro Bono Week, serving as a useful reminder that offering free legal help to the public can help attorneys expand their legal toolbox, forge community relationships and create human connections, despite the challenges of this kind of work, says Orlando Lopez at Culhane Meadows.
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The Pop Culture Docket: Judge Espinosa On 'Lincoln Lawyer'
The murder trials in Netflix’s “The Lincoln Lawyer” illustrate the stark contrast between the ethical high ground that fosters and maintains the criminal justice system's integrity, and the ethical abyss that can undermine it, with an important reminder for all legal practitioners, say Judge Adam Espinosa and Andrew Howard at the Colorado 2nd Judicial District Court.