International
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September 27, 2024
Ireland Seeks Input On Business Interest Tax Regime
Ireland has asked for comments on its business interest taxation and deduction regime, as well as whether the country should introduce a commercial business purposes test for deductions, its government said Friday.
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September 27, 2024
Taxation With Representation: Kirkland, Skadden, Cleary
In this week's Taxation With Representation, Blackstone and Vista Equity Partners acquire Smartsheet Inc., Macquarie Asset Management takes a stake in D.E. Shaw Renewables Investment Group, and Apogee Enterprises Inc. buys UW Interco LLC from Heartwood Partners.
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September 27, 2024
US Trade Group Pushes OECD On Compliance Burden
The Organization for Economic Cooperation and Development needs to do more work on the safe harbor provisions of its Pillar Two 15% global corporate minimum tax plan — including potentially making it permanent — among other compliance burden concerns, the National Foreign Trade Council said Friday.
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September 27, 2024
Gov't Could Target Pension Contributions In Tax Raid
The U.K. government could introduce a new levy on employer pension contributions as a means of plugging a £22 billion ($29.5 billion) black hole in public finances, experts said Friday.
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September 26, 2024
Belgian Co. Can't Keep Using Ad Space Rent-Free, ECJ Says
The European Court of Justice on Thursday upheld a 2019 European Commission ruling that a street furniture company's owed rent for Brussels bus shelter advertising space, agreeing with the commission that allowing the company to continue using the ad displays without paying rent or taxes constituted unlawful state aid.
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September 26, 2024
Tribunal Halts $52.8M German Tax Collection Against Oil Cos.
German tax authorities shouldn't collect a windfall profits tax totaling at least €47.2 million ($52.8 million) from two oil refineries before the dispute has been litigated, a tribunal of the International Centre for Settlement of Investment Disputes said.
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September 26, 2024
Montreal Exchange Is A Qualified Exchange, IRS Says
The Montreal Exchange is a qualified board or exchange for purposes of mark-to-market contracts under Internal Revenue Code Section 1256(g)(7)(C), the Internal Revenue Service said Thursday.
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September 26, 2024
Amazon Reports Paying £932M In UK Taxes In 2023
Amazon said Thursday that it paid a total of £932 million ($1.25 billion) in U.K. taxes last year, which the company said puts it among the 10 largest taxpayers in the country.
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September 26, 2024
Tariff Tax Base Too Small To Replace Income Tax, Report Says
Higher tariffs can't replace income tax revenue, as former President Donald Trump has suggested, since U.S. imports total $3 trillion annually while incomes top $20 trillion, but they would lower incomes by raising prices for U.S. consumers, a think tank reported Thursday.
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September 26, 2024
Irish Dividend Exemption Too Restrictive, Big 4 Say
The Big Four accounting firms raised concerns about wording in Ireland's planned tax exemption for foreign-sourced dividends, claiming in comments released Thursday that it would be overly restrictive to require dividends to come solely out of an offshore affiliate's profits.
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September 26, 2024
Harris' And Trump's Tax Plans Each Add To Deficit, Study Says
The U.S. federal deficit would grow by at least $2 trillion over the next decade from the tax policy plans of both major parties' candidates, former President Donald Trump and Vice President Kamala Harris, researchers said Thursday.
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September 26, 2024
UK Cos. Claimed Nearly £1.5B In Patent Box Relief In 2022-23
While there was a slight dip in the number of U.K. companies that elected to use the country's patent box tax regime in the 2022-23 tax year compared with the prior year, the estimated value of relief claimed jumped to nearly £1.47 billion ($1.97 billion) compared with around £1.33 billion, HM Revenue & Customs said Thursday.
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September 26, 2024
UK R&D Tax Credit Claims Down, But Total Relief Up £100M
While there was an over 20% dip in research and development tax credit claims in the U.K. in the 2022-23 tax year, the total relief claimed rose to £7.5 billion ($10.1 billion), a £100 million increase, HM Revenue & Customs said Thursday.
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September 26, 2024
UK Corp. Tax Receipts Up 10% To £93.3B, HMRC Says
The U.K. generated £93.3 billion ($125 billion) in corporate tax receipts in the 2023-24 tax year, a 10% increase over the prior year, HM Revenue & Customs said Thursday, pointing mainly to the increase in the country's corporation tax rate to 25% as the reason behind the bump.
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September 26, 2024
ECJ Backs Strong Protection For Lawyer-Client Discussions
Confidentiality of lawyer-client communications has enhanced protection under European Union law, including in cross-border tax disclosures, the European Court of Justice ruled Thursday.
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September 26, 2024
OECD Publishes Streamlined Amount B Model Agreement
The Organization for Economic Cooperation and Development published a model agreement Thursday for a simplified and streamlined approach to the Amount B portion of Pillar One, a transfer pricing plan for certain baseline marketing and distribution activities.
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September 25, 2024
IBM Urges Justices To Review NY Tax On Foreign Royalties
New York's system for taxing royalty payments would be unconstitutional if every other jurisdiction adopted it, violating an internal consistency test reaffirmed by a 2015 precedent, IBM told the U.S. Supreme Court in asking it to review and overturn New York's high court ruling that allowed the tax regime.
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September 25, 2024
Boosting Indirect Tax Revenues Can Tackle Debt, OECD Says
A number of countries should look to eliminate distortive tax expenses as well as increase their revenue from certain taxes to help manage debt sustainability and make their economies more supportive of growth, the Organization for Economic Cooperation and Development said Wednesday.
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September 25, 2024
Expect More R&D Guidance Before Regs, IRS Atty Says
The Internal Revenue Service plans to release more guidance governing the tax treatment of research and development expenses before it formally issues proposed regulations that implement the 2017 federal tax law's changes to the incentive, an agency attorney said Wednesday.
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September 25, 2024
EU States Must Unify Divergent Biz Rules, Majority Says
The European Union must double down on unifying its divergent rules for businesses in a policy proposal next year because the bloc's main competitive advantage is its single market, almost three-quarters of EU countries told the bloc's executive arm.
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September 25, 2024
Basis-Shifting Regs May Add Accounting Fixes, IRS Atty Says
The Internal Revenue Service may include in upcoming proposed regulations a solution for partnership basis-shifting for taxpayers that want to adjust accounting methods so prior transactions can be compliant with economic substance laws, an agency attorney said Wednesday.
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September 25, 2024
Wyden Calls On 2025 Tax Bill To Include Partnership Reform
Lawmakers should consider next year how to revise partnership tax laws to better collect on large businesses' income without harming smaller entities as Congress debates over how to address expiring tax provisions, Senate Finance Committee Chairman Ron Wyden said Wednesday.
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September 25, 2024
Australia Floats Updates To Amended Tax Pro Conduct Code
After repeated pushback against changes to Australia's tax agent code of conduct, the country's Treasury proposed two further amendments Wednesday that aim to address complaints regarding corrections of false or misleading statements and disclosures of information to clients.
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September 25, 2024
Hong Kong, Turkey Reach Double-Tax Agreement
Hong Kong and Turkey agreed to a treaty to prevent double taxation, which would take effect after approval by both jurisdictions' legislatures, Hong Kong's Inland Revenue Department said.
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September 25, 2024
French Finance Minister Signals Higher Taxes On Rich
The new French government is considering raising taxes on the wealthy and businesses to help reduce the country's budget deficit amid concerns over debt, according to remarks by the new finance minister.
Expert Analysis
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How Clients May Use AI To Monitor Attorneys
Excerpt from Practical Guidance
Artificial intelligence tools will increasingly enable clients to monitor and evaluate their counsel’s activities, so attorneys must clearly define the terms of engagement and likewise take advantage of the efficiencies offered by AI, says Ronald Levine at Herrick Feinstein.
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The Pop Culture Docket: Judge D'Emic On Moby Grape
The 1968 Moby Grape song "Murder in My Heart for the Judge" tells the tale of a fictional defendant treated with scorn by the judge, illustrating how much the legal system has evolved in the past 50 years, largely due to problem-solving courts and the principles of procedural justice, says Kings County Supreme Court Administrative Judge Matthew D'Emic.
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Breaking Down High Court's New Code Of Conduct
The U.S. Supreme Court recently adopted its first-ever code of conduct, and counsel will need to work closely with clients in navigating its provisions, from gift-giving to recusal bids, say Phillip Gordon and Mateo Forero at Holtzman Vogel.
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Legal Profession Gender Parity Requires Equal Parental Leave
To truly foster equity in the legal profession and to promote attorney retention, workplaces need to better support all parents, regardless of gender — starting by offering equal and robust parental leave to both birthing and non-birthing parents, says Ali Spindler at Irwin Fritchie.
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A Year-End Look At Florida's Capital Investment Tax Credit
Notwithstanding the Walt Disney Co.’s feud with Gov. Ron DeSantis this year, Florida's capital investment tax credit will continue to make the state a favored destination for large corporations, particularly in light of the new federal alternative minimum tax and the Pillar Two top-up tax, says Alan Lederman at Gunster.
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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.