International
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October 22, 2024
Brazil Eyes Shifting Talks On Wealth Taxation To UN
Brazil is campaigning for the United Nations to commit to creating a minimum tax on high-net-worth individuals in February during expected talks on the organization's burgeoning global tax convention, a Brazilian finance ministry official said Tuesday at the International Monetary Fund.
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October 22, 2024
Argentina President Dissolving, Replacing Tax Agency
Argentina's tax authority, the Federal Public Revenue Administration, will be dissolved and replaced with a new body, the country's president said, with the change causing a 34% reduction in jobs.
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October 22, 2024
Tax Court Says It Can't Rule On FBAR Challenge
The U.S. Tax Court said Tuesday that it lacks the authority to rule on a couple's claim that the Internal Revenue Service wrongly denied them a chance to challenge penalties for failing to report their foreign bank accounts.
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October 22, 2024
Wafer Factories Qualify For CHIPS Tax Credit In Final Regs
Semiconductor wafer production facilities will qualify for the 25% investment tax credit that incentivizes advanced chip manufacturing development projects under final regulations the U.S. Department of the Treasury released Tuesday.
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October 22, 2024
IRS Working On Proposed Spinoff Rules, Agency Official Says
The Internal Revenue Service is planning to propose regulations that may amend positions in an existing revenue procedure that narrowed the range of spinoff transactions the agency will approve as tax-free ahead of time, an IRS official said Tuesday.
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October 22, 2024
Winston & Strawn Boosts Transactions Team With NY Tax Atty
As Winston & Strawn LLP continues to build out its transactions team, the firm has hired a new attorney from Hunton Andrews Kurth LLP with a focus on the tax aspects of real estate financing.
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October 22, 2024
Ireland Deposits €4B In Fund Set Up For Tax Surplus
Ireland transferred €4.05 billion ($4.4 billion) from its Exchequer to one of the sovereign wealth funds it created to invest surplus revenue generated by what the country's Department of Finance has characterized as volatile corporate tax receipts, the department said Tuesday.
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October 22, 2024
Portuguese Parliament Passes Min. Tax After EU Pressure
Portugal would implement the global corporate minimum tax spearheaded by the Organization for Economic Cooperation and Development under legislation sent to the country's president for approval Tuesday after the European Union put the country on notice for not adopting the tax.
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October 22, 2024
How Law Firms Get And Keep Elite Status
For decades, a handful of New York-based law firms thoroughly dominated the national consciousness when it came to power, profitability and prestige. But in today's legal market, increased movement of partners and clients from one firm to the next has begun to shake things up and create opportunities for go-getters to ascend the ranks.
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October 22, 2024
The 2024 Prestige Leaders
Check out our Prestige Leaders ranking, analysis and interactive graphics to see which firms stand out for their financial performance, attractiveness to attorneys and law students, ability to secure accolades and positive legal news media representation.
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October 22, 2024
Director Imprisoned For Concealing £220K Tax Debt
The former director of a wholesale company has been jailed for 10 months after failing to deliver accounting records when his business went into liquidation owing more than £220,000 ($290,000), the Insolvency Service announced Tuesday.
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October 22, 2024
Germany's Sept. Tax Revenue Rises 6.9% Year-On-Year
Germany's total tax revenue for the month of September reached €86.2 billion ($93.2 billion) after a rise in tax receipts over the summer, an increase of 6.9% year-on-year, the German Ministry of Finance said Tuesday.
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October 22, 2024
MVP: Jones Day's Charles 'Chuck' Hodges
Chuck Hodges, a tax partner with Jones Day, led a gravel company to victory in May at the U.S. Tax Court in a case regarding an $11.1 million sale of a freeway pit, helping him earn a spot as one of the 2024 Law360 Tax MVPs.
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October 22, 2024
Budget Fears Spark Surge Of Savers Raiding Pensions
A third of financial advisers have seen an uptick in customers tapping into their pensions, an investment platform company said, amid speculation the government could reduce the amount that Britons can withdraw without being taxed.
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October 21, 2024
BDO Appoints Former HMRC Official, 3 Others To UK Offices
An HM Revenue & Customs official is among four tax professionals BDO LLP has appointed to its offices in the U.K., the firm announced.
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October 21, 2024
Foreign Currency Regs Need Flexibility, Biz Group Says
The U.S. Treasury Department should allow taxpayers with foreign personal holding companies to get automatic consent to revoke elections on the treatment of foreign currency gains or losses under proposed regulations to align such elections with rules on so-called mark-to-market accounting, the National Foreign Trade Council said.
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October 21, 2024
UK Director's Use Of Tax Planning Data Subject For Retrial
Whether a director of a U.K. company is liable for a breach of confidence over the misuse of information in marketing a complex tax structure is an issue to be retried, a London court ruled.
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October 21, 2024
MVP: Paul Weiss' Brian Krause
Brian Krause of Paul Weiss Rifkind Wharton & Garrison LLP's tax practice designed a novel tax approach for the merger of World Wrestling Entertainment and Ultimate Fighting Championship, raced to create a tax-free deal in the final days of a Texas "wildcatter" hoping to sell his oil company, and advised Chevron in its $60 billion acquisition of Hess Corp., earning him a spot as one of the 2024 Law360 Tax MVPs.
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October 21, 2024
Estonian Tax System Remains Most Competitive, Study Says
Estonia's tax system was ranked by a conservative think tank as the most competitive out of the Organization for Economic Cooperation and Development's 38 full members for the 11th year in a row, while the U.S. improved to 18th, according to a report Monday.
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October 21, 2024
14 Arrested In Poland For $10M VAT Fraud Involving Trucks
Polish authorities arrested 14 suspects in connection to a value-added tax fraud scheme involving the import of trucks from other European Union member countries that caused losses worth an estimated 40 million Polish zloty ($10 million), the country's revenue agency said Monday.
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October 21, 2024
Canada Offers Relief From Surtaxes On Chinese Imports
Canadian businesses can now apply under certain conditions for relief from surtaxes the country enacted on Chinese-made electric vehicles and some Chinese steel and aluminum products, the country's Department of Finance said.
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October 21, 2024
New ABA Tax Chair-Elect Aims To Expand Leadership Paths
The new chair-elect of the American Bar Association Section of Taxation told Law360 that she wants to broaden the pathways to leadership for members, including those early in their careers, as part of the section's diversity, equity and inclusion initiatives. Here, Megan Brackney shares more about her background and goals for the section.
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October 18, 2024
Law360 MVP Awards Go To Top Attys From 74 Firms
The attorneys chosen as Law360's 2024 MVPs have distinguished themselves from their peers by securing hard-earned successes in high-stakes litigation, complex global matters and record-breaking deals.
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October 18, 2024
Iceland, Brazil Agree To Double-Tax Treaty
Iceland and Brazil reached an agreement on a double-tax treaty that will go into effect once it is passed by their legislatures, Iceland's Foreign Affairs Ministry said.
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October 18, 2024
Ending Nonresident Tax Breaks Could Harm UK, Report Says
The U.K.'s plans to abolish nondomicile tax status for high-net-worth individuals could reduce the country's economic size by nearly £6.5 billion ($8 billion) by 2035, according to recent research.
Expert Analysis
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A Vision For Economic Clerkships In The Legal System
As courts handle increasingly complex damages analyses involving vast amounts of data, an economic clerkship program — integrating early-career economists into the judicial system — could improve legal outcomes and provide essential training to clerks, say Mona Birjandi at Data for Decisions and Matt Farber at Secretariat.
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A Look At New IRS Rules For Domestically Controlled REITs
The Internal Revenue Services' finalized Treasury Regulations addressing whether real estate investment trusts qualify as domestically controlled adopt the basic structure of previous proposals, but certain new and modified rules may mitigate the regulations' impact, say attorneys at Simpson Thacher.
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E-Discovery Quarterly: Recent Rulings On Text Message Data
Electronically stored information on cellphones, and in particular text messages, can present unique litigation challenges, and recent court decisions demonstrate that counsel must carefully balance what data should be preserved, collected, reviewed and produced, say attorneys at Sidley.
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Don't Use The Same Template For Every Client Alert
As the old marketing adage goes, consistency is key, but law firm style guides need consistency that contemplates variety when it comes to client alert formats, allowing attorneys to tailor alerts to best fit the audience and subject matter, says Jessica Kaplan at Legally Penned.
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Think Like A Lawyer: Follow The Iron Rule Of Trial Logic
Many diligent and eager attorneys include every good fact, point and rule in their trial narratives — spurred by the gnawing fear they’ll be second-guessed for leaving something out — but this approach ignores a fundamental principle of successful trial lawyering, says Luke Andrews at Poole Huffman.
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The Art Of Asking: Leveraging Your Contacts For Referrals
Though attorneys may hesitate to ask for referral recommendations to generate new business, research shows that people want to help others they know, like and trust, so consider who in your network you should approach and how to make the ask, says Rebecca Hnatowski at Edwards Advisory.
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Unpacking The Bill To Extend TCJA's Biz-Friendly Tax Breaks
Attorneys at Skadden examine how a bipartisan bill currently being considered by the U.S. Senate to save the Tax Cuts and Jobs Act's tax breaks for research and development costs, and other expiring business-friendly provisions, would affect taxpayers.
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Deciding What Comes At The End Of WTO's Digital Tariff Ban
Companies that feel empowered by the World Trade Organization’s recent two-year extension of the ban on e-commerce tariffs should pay attention to current negotiations over what comes after the moratorium expires, as these agreements will define standards in international e-commerce for years to come, say Jan Walter, Hannes Sigurgeirsson and Kulsum Gulamhusein at Akin Gump.
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4 Ways To Refresh Your Law Firm's Marketing Strategy
With many BigLaw firms relying on an increasingly obsolete marketing approach that prioritizes stiff professionalism over authentic connection, adopting a few key communications strategies to better connect with today's clients and prospects can make all the difference, say Eric Pacifici and Kevin Henderson at SMB Law.
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This Earth Day, Consider How Your Firm Can Go Greener
As Earth Day approaches, law firms and attorneys should consider adopting more sustainable practices to reduce their carbon footprint — from minimizing single-use plastics to purchasing carbon offsets for air travel — which ultimately can also reduce costs for clients, say M’Lynn Phillips and Lisa Walters at IMS Legal Strategies.
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Cum-Ex Prosecutions Storm Shows No Sign Of Abating
The ongoing trial of Sanjay Shah in Denmark is a clear indicator that efforts remain focused on holding to account the alleged architects and beneficiaries of cum-ex trading, and with these prosecutions making their way across Europe, it is a more turbulent time now than ever, says Niall Hearty at Rahman Ravelli.
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Practicing Law With Parkinson's Disease
This Parkinson’s Awareness Month, Adam Siegler at Greenberg Traurig discusses his experience working as a lawyer with Parkinson’s disease, sharing both lessons on how to cope with a diagnosis and advice for supporting colleagues who live with the disease.
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Why Supreme Court Should Allow Repatriation Tax To Stand
If the U.S. Supreme Court doesn't reject the taxpayers' misguided claims in Moore v. U.S. that the mandatory repatriation tax is unconstitutional, it could wreak havoc on our system of taxation and result in a catastrophic loss of revenue for the government, say Christina Mason and Theresa Balducci at Herrick Feinstein.