International

Top Federal Tax Decisions Of 2024

Anna Scott Farrell

Over the past year, federal courts have issued decisions further delimiting the power of the Internal Revenue Service, with the First Circuit affirming a decision to allow agency summonses for cryptocurrency account records and an Arizona federal court rejecting a call to lift the agency's moratorium on processing pandemic-era worker credits. Here, Law360 reviews some of the most significant federal tax decisions of 2024.

Digital Taxes In Flux Amid Renewed US Tariff Threats

Kevin Pinner

Governments around the world revisited their approaches to digital services taxes this year by adopting broader versions, raising rates, carving out industries and analyzing the impacts of adopting unilateral measures as threats of U.S. tariffs materialize once again. Here, Law360 looks at how countries around the world are considering, adopting or changing their DSTs.

Countries Eye Certain Tax Credits To Get Leg Up Under Pillar 2

Natalie Olivo
Senior Tax Correspondent

The international minimum tax agreement known as Pillar Two is changing how countries compete for corporate investment, in part by prompting some governments to retool their tax credit systems in ways that could edge out jurisdictions with fewer resources.

Making The Pitch To Grow Your Company's Legal Team

In a compressed economy, convincing the C-suite to invest in additional legal talent can be a herculean task, but a convincing pitch — supported by metrics and cost analyses — may help in-house counsel justify the growth of their team, say Elizabeth Smith and Roger Garceau at Major Lindsey.

Tax Court Should Update Framework For Defining Insurance

​​​​​​​The U.S. Tax Court's unnecessary determination in Royalty Management Insurance v. Commissioner that a fraudulent transaction did not contain the hallmarks of a legitimate insurance transaction applies an outdated analysis that threatens the captive insurance sector and illustrates the need for a more modern framework to define true insurance, says Matthew Queen at the Queen Firm.

When US Privilege Law Applies To Docs Made Outside The US

As globalization manifests itself in disputes over foreign-created documents, a California federal court’s recent trademark decision illustrates nuances of both U.S. privilege frameworks and foreign evidentiary protections that attorneys must increasingly bear in mind, say attorneys at Hunton.

Impact Of Corporate Transparency Act Ambiguity On Banks

Even though banks generally needn't file beneficial ownership information reports, financial institutions must continue to monitor the status of the Corporate Transparency Act and understand its requirements in case the nationwide injunction that was issued against the CTA earlier this month is overturned, say attorneys at Armstrong Teasdale.

6 Changes I Would Make If I Ran A Law School

Reuben Guttman at Guttman Buschner identifies several key issues plaguing law schools and discusses potential solutions, such as opting out of the rankings game and mandating courses in basic writing skills.

Firms Still Have The Edge In Lateral Hiring, But Buyer Beware

Partner mobility data suggests that the third quarter of this year continued to be a buyer’s market, with the average candidate demanding less compensation for a larger book of business — but moving into the fourth quarter, firms should slow down their hiring process to minimize risks, say officers at Decipher Investigative Intelligence.

Think Like A Lawyer: 1 Type Of Case Complexity Stands Out

In contrast to some cases that appear complex due to voluminous evidence or esoteric subject matter, a different kind of complexity involves tangled legal and factual questions, each with a range of possible outcomes, which require a “sliding scale” approach instead of syllogistic reasoning, says Luke Andrews at Poole Huffman.

Think Like A Lawyer: Note 3 Simple Types Of Legal Complexity

Cases can appear complex for several reasons — due to the number of issues, the volume of factual and evidentiary sources, and the sophistication of those sources — but the same basic technique can help lawyers tame their arguments into a simple and persuasive message, says Luke Andrews at Poole Huffman.

Litigation Inspiration: Reframing Document Review

For attorneys — new ones especially — there is much fulfillment to find in document review by reflecting on how important, interesting and pleasant it can be, says Bennett Rawicki at Hilgers Graben.

3 Ways To Train Junior Lawyers In 30 Minutes Or Less

Today’s junior lawyers are experiencing a skills gap due to pandemic-era disruptions, but firms can help bring them up to speed by offering high-impact skill building content in bite-sized, interactive training sessions, say Stacey Schwartz at Katten, Diane Costigan at Winston & Strawn and Lauren Tierney at Freshfields.

The Bar Needs More Clarity On The Discovery Objection Rule

Almost 10 years after Federal Rule of Civil Procedure 34 was amended, attorneys still seem confused about what they should include in objections to discovery requests, and until the rules committee provides additional clarity, practitioners must beware the steep costs of noncompliance, says Tristan Ellis at Shanies Law Office.

So You Want To Move Your Law Practice To Canada, Eh?

Google searches for how to move to Canada have surged in the wake of the U.S. presidential election, and if you’re an attorney considering a move to the Great White North, you’ll need to understand how the practice of law differs across the border, says David Postel at Henein Hutchison.

Promoting Diversity In The Selection Of ADR Neutrals

Excerpt from Practical Guidance

Choosing neutrals from diverse backgrounds is an important step in promoting inclusion in the legal profession, and it can enhance the legitimacy and public perception of alternative dispute resolution proceedings, say attorneys at Lowenstein Sandler.