International
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August 28, 2024
IRS Declines Watchdog's Ask For Attys In Talks With Big Cos.
The IRS declined a recommendation by its internal watchdog to require the agency's counsel to attend talks held with large multinational corporations by its appellate division, which agents say thwarts their ability to correctly enforce the economic substance doctrine, according to a report.
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August 28, 2024
Feds Looks To Toss Ex-Citizens' Renunciation Fee Challenge
The federal government asked a D.C. federal judge to throw out a lawsuit brought by former U.S. citizens who want their $2,350 citizenship renunciation fee refunded, arguing during a Wednesday hearing that the United States is immune from the litigation and the plaintiffs can't relitigate claims that they already lost.
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August 28, 2024
IRS Corrects Proposed Foreign Currency Accounting Regs
The Internal Revenue Service issued corrections Wednesday to proposed rules that would adjust the timing for when companies could opt to use what is known as the mark-to-market accounting method for gains or losses that arise from foreign currency transactions.
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August 28, 2024
Jury Justified In Dismissing $2.2M FBAR Case, Court Rules
A financial adviser will not face a new trial after an Arizona federal court ruled there was sufficient evidence for a jury to clear him in January of failing to report foreign bank accounts, sparing him at least $2.2 million in penalties.
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August 28, 2024
Sysco, IRS Asked To Address Varian's Foreign Dividend Win
The U.S. Tax Court asked food services giant Sysco and the IRS to address how a tax dispute between them is affected by a recent ruling in a similar case that found medical device company Varian can claim a deduction for foreign dividends.
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August 28, 2024
Treasury To Require Reports On All-Cash Real Estate Deals
Anyone who transfers real estate to a legal entity in an all-cash transaction, including attorneys, will be required starting Dec. 1, 2025, to inform the U.S. Treasury Department about that entity's beneficial owners and their identification numbers under a final rule issued Wednesday.
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August 28, 2024
Greenberg Traurig Builds PE Team With Kirkland Hires
Greenberg Traurig LLP has brought on two fund formation partners from Kirkland & Ellis LLP to continue its growth into the private equity space, according to an announcement this week by the firm.
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August 28, 2024
Taiwan Considering OECD's Global Minimum Tax
Taiwan is looking to implement the Organization for Economic Cooperation and Development's 15% global corporate minimum tax on large multinational entities starting in 2026, the country's Ministry of Finance said Wednesday.
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August 28, 2024
Ireland May Add Timing Flexibility To Dividend Exemption
The Irish government floated more timing flexibility for companies seeking to opt into the country's planned tax exemption for foreign-sourced earnings, but it declined to widen the system's geographical scope.
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August 28, 2024
Atty Can't Escape Danish Tax Agency's $2.1B Tax Fraud Suit
An attorney in a $2.1 billion tax fraud case brought by the Danish tax authority cannot argue that a suit filed against him as an individual should be dismissed because it was filed late, a New York federal court ruled.
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August 27, 2024
Gov't Says Doctor Can't Escape Contempt Fine In FBAR Case
A doctor challenging his $20,000 civil contempt fine for failing to follow a court order to repatriate money from his foreign bank account to cover $1.1 million in tax liabilities shouldn't be allowed to escape the penalty, the U.S. government argued Tuesday.
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August 27, 2024
Canadian Grocery Giant's Bank Wins Appeal Over Tax Credits
The Tax Court of Canada incorrectly decided that a bank owned by the country's largest supermarket chain, Loblaw, couldn't claim tax credits aimed at exempting commercial purchases for payments the bank made in a customer rewards program, a Federal Court of Appeal panel ruled.
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August 27, 2024
OECD Says Malaysia Should Resume GST, End Fuel Subsidies
With spending pressures rising, Malaysia should look to increase its tax revenues through measures including a reintroduction of its goods and services tax, as well as push to minimize its climate impact by eliminating fuel subsidies, the Organization for Economic Cooperation and Development said Tuesday.
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August 27, 2024
Treasury Asked To Scrap Stock Buyback Tax's Funding Rule
Business groups urged the U.S. Treasury Department on Tuesday to remove what's known as the funding rule in forthcoming final regulations on the stock buyback tax, saying the provision would go beyond Congress' intentions for the levy, which aims to deter companies from giving outsize rewards to shareholders.
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August 27, 2024
Croatia, HK, Others Address Hurtful Tax Regimes, OECD Says
Five tax jurisdictions, including Croatia and Hong Kong, have made progress to address various harmful tax practices, the Organization for Economic Cooperation and Development said Tuesday.
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August 27, 2024
Germany Proposes Investment Tax Changes To Attract VC
Germany would adjust its tax laws in an attempt to better attract venture capital and investments into renewable energies under a proposal published Tuesday by the country's finance ministry as part of a planned "growth initiative."
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August 27, 2024
Starmer Warns Of 'Painful' Budget As UK Braces For Tax Hikes
U.K. Prime Minister Keir Starmer warned Tuesday of "painful" decisions to plug budget gaps, including tax increases and spending cuts, looming in the Oct. 30 budget statement.
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August 27, 2024
Gov't Urged To Reform Pension Tax To Fill Budget Gaps
The Labour government should reform £66 billion ($87 billion) worth of pension tax relief to raise extra revenue to help plug the black hole in public finances, a think tank affiliated to the party has said.
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August 26, 2024
Varian Entitled To Foreign Dividend Break, Tax Court Says
California-based medical device company Varian Medical Systems is entitled to a deduction for dividends received from its foreign subsidiaries, the U.S. Tax Court ruled Monday in a unanimous opinion.
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August 26, 2024
US Should Extend Expiring TCJA Tax Cuts, Chamber Says
The expiration of the 2017 Tax Cuts and Jobs Act in 2025 gives the next Congress an opportunity to pass pro-growth tax policies, the U.S. Chamber of Commerce said Monday.
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August 26, 2024
Kyocera's Gross-Up Doesn't Grant $143M Tax Break, US Says
Electronics maker Kyocera cannot be allowed to take a $143 million tax deduction for distributions received under a 2017 tax law based on a separate statute's gross-up for paid foreign tax credits, the government told a South Carolina federal court.
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August 26, 2024
New Zealand Considers OECD Crypto Reporting Framework
New Zealand would implement the Organization for Economic Cooperation and Development's framework for automatically exchanging financial information regarding crypto-assets under a proposal the country's revenue minister sent to its Legislature on Monday.
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August 26, 2024
Canada Planning 100% Surtax On Chinese EVs, 25% On Steel
Canada plans to implement a 100% surtax on imported Chinese electric vehicles and a 25% surtax on Chinese steel and aluminum as part of a package intended to protect Canadian industry from unfair competition, the country's Department of Finance said Monday.
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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.
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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.
Expert Analysis
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How Associates Can Build A Professional Image
As hybrid work arrangements become the norm in the legal industry, early-career attorneys must be proactive in building and maintaining a professional presence in both physical and digital settings, ensuring that their image aligns with their long-term career goals, say Lana Manganiello at Equinox Strategy Partners and Estelle Winsett at Estelle Winsett Professional Image Consulting.
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Firms Must Rethink How They Train New Lawyers In AI Age
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.
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Think Like A Lawyer: Always Be Closing
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.
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Litigation Inspiration: Attys Can Be Heroic Like Olympians
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.
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Lean Into The 'Great Restoration' To Retain Legal Talent
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.
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Fishing Makes Me A Better Lawyer
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.
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A Healthier Legal Industry Starts With Emotional Intelligence
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.
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To Make Your Legal Writing Clear, Emulate A Master Chef
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.
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Circuit Judge Writes An Opinion, AI Helps: What Now?
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.
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Trauma-Informed Legal Approaches For Pro Bono Attorneys
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.
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How Attys Can Avoid Pitfalls When Withdrawing From A Case
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.
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Using A Children's Book Approach In Firm Marketing Content
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.
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New Crypto Reporting Will Require Rigorous Recordkeeping
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.