International
-
December 10, 2024
Treasury Finalizes Simplified Foreign Currency Rules
The U.S. Treasury Department finalized regulations Tuesday that aim to simplify aspects of how corporations determine taxable income or loss with respect to certain affiliates that conduct business in a foreign currency.
-
December 10, 2024
Jockey Frankie Dettori Named In HMRC Tax Avoidance Battle
Italian jockey Frankie Dettori has been named as the individual who attempted to maintain his anonymity to keep private his legal battle with HM Revenue and Customs over a tax avoidance scheme, according to a London court judgment.
-
December 09, 2024
US Investment Cos. Benefit In Updated Norway Tax Treaty
Regulated U.S. investment and holding companies should be able to reap Norwegian tax treaty benefits on dividends, royalties and capital gains without restriction under an updated agreement announced Monday by the Internal Revenue Service.
-
December 09, 2024
Microsoft Wrong On Foreign Earnings, Ore. Tells Tax Court
The Oregon Tax Court was correct to reject alternatives pitched by Microsoft for treatment of its repatriated foreign earnings when calculating Oregon taxable income, the state tax department told the court.
-
December 09, 2024
UN Tax Pact Should Include Climate Focus, Report Says
Coming negotiations for a global tax convention at the United Nations should include discussions about designing tax policies that could generate resources to help address climate change, according to a report published Monday by the advocacy group Tax Justice Network.
-
December 09, 2024
Woman Appeals Tax Court's Canadian Debt Ruling To 9th Circ.
A woman appealed to the Ninth Circuit a U.S. Tax Court decision that prevented her from challenging a federal tax lien issued by the Internal Revenue Service to secure her $200,000 tax debt to Canada on behalf of the Canadian government.
-
December 09, 2024
16 EU Members Call For Revamped Tobacco Taxation
The European Commission needs to prioritize an overhaul of the bloc's tobacco taxation rules in the upcoming term, a group of 16 member countries said Monday, arguing that major changes in the industry since the rules last updated have left countries to fend for themselves, fragmenting the tax regime.
-
December 09, 2024
Man Owed $264K Under US-Canada Tax Treaty, Court Says
A U.S. man living abroad is allowed under the U.S.-Canada tax treaty to claim a foreign tax credit for nearly $264,000 in payments of the Affordable Care Act's net investment income tax, the Federal Claims Court said.
-
December 09, 2024
Latin America Should Improve Tax Collection, OECD Says
Latin American and Caribbean countries' average tax-to-gross-domestic-product ratio falls well below the Organization for Economic Cooperation and Development average, and improvements will be key to the area's ability to meet sustainable development goals, the OECD said Monday.
-
December 09, 2024
UAE Implementing Global Minimum Tax In 2025
Large multinational businesses in the United Arab Emirates making at least €750 million ($792 million) annually will be subject to the OECD's 15% corporate global minimum tax starting in 2025, the country's Finance Ministry said Monday.
-
December 09, 2024
Proposed Canadian Tax Holiday Will Cost $1B, Office Says
Canada's proposed two-month goods-and-services tax holiday on certain goods would result in the loss of at least CA$1.46 billion ($1 billion) in federal tax revenues, a Canadian budget watchdog said Monday.
-
December 09, 2024
Germany Floats Plans To Adopt Additional Min. Tax Guidance
Germany's Federal Ministry of Finance is seeking feedback on additional proposed updates to its legislation under an international minimum tax agreement known as Pillar Two, including incorporating global guidance on how to approach deferred taxes.
-
December 09, 2024
Insurer Launches Estate Planning Cover After Tax Changes
Royal London said on Monday that it has launched an insurance product designed to help consumers with their end-of-life planning, as a growing number of estates are set to become subject to inheritance tax after recent government changes.
-
December 06, 2024
DC Circ. Affirms Man's $1.2M 'Seriously Delinquent' Tax Debt
A Florida man owes more than $1.2 million in federal taxes, the D.C. Circuit said Friday, affirming the Internal Revenue Service's certification of his liability under a law that allows those with a "seriously delinquent" tax debt to have their passport revoked.
-
December 06, 2024
NZ Considering Edits To 'Internationally Unusual' Tax Regime
New Zealand's government received feedback that its rules for taxing investments of 10% or less in foreign companies may be discouraging people who hold interests in such entities from moving to the country, and it is seeking feedback on possible solutions, its tax authority said Friday.
-
December 06, 2024
Gov't Appeals Texas Judge's Block On Anti-Laundering Law
The U.S. government has appealed a Texas federal judge's order that halted the rollout of new reporting requirements aimed at unmasking anonymous shell companies, setting the stage for the Fifth Circuit to weigh in on the nationwide preliminary injunction.
-
December 06, 2024
Simpson Thacher Adds Tax Pro From Ropes & Gray
Simpson Thacher & Bartlett LLP announced the firm has added a tax professional from Ropes & Gray LLP as a partner in its Washington, D.C., office.
-
December 06, 2024
Authorities Investigating Possible €200M German VAT Fraud
The European Public Prosecutor's Office carried out searches at a Munich bank as part of an investigation into a man who created a fictitious business to process more than €200 million ($211 million) in funds generated from a value-added tax fraud scheme, the EPPO said Friday.
-
December 06, 2024
Canada's Chinese Import Surtaxes Expected To Raise $334M
Canada's new surtaxes on Chinese electric vehicles and steel and aluminum products are estimated to generate CA$473 million ($334 million) over the next five years, though the EV surtax on its own is likely to cause a dip in revenue, a government analysis said.
-
December 06, 2024
Taxation With Representation: Skadden, Gibson Dunn
In this week's Taxation With Representation, BlackRock buys HPS Investment Partners, TreeHouse Foods Inc. buys Harris Tea, Aya Healthcare acquires Cross Country Healthcare, and Bruin Capital launches a soccer representation business.
-
December 05, 2024
11th Circ. Won't Rethink $100M Credit For John Hancock
The Eleventh Circuit won't reconsider its decision to let John Hancock Life Insurance Co. keep $100 million in foreign tax credits, leaving in place its October ruling against a Florida law firm retirement plan's trustees.
-
December 05, 2024
OECD Suggests Tax Shifts To Address Greece's Debt
Greece has a lot of work to do to reduce its nearly 164% public-debt-to-gross domestic product ratio, and one avenue to generate the kind of budget surplus needed is through a suite of tax changes, the Organization for Economic Cooperation and Development said Thursday.
-
December 05, 2024
OECD Removes Application Deadline For Int'l Pricing Program
The Organization for Economic Cooperation and Development said Thursday it has removed biannual deadlines for large multinational entities to apply for the International Compliance Assurance Program, a multilateral effort to resolve transfer pricing issues.
-
December 05, 2024
Australia Mulling More Country-By-Country Reporting Advice
While the Australian Taxation Office is already working on guidance for the country's newly adopted public country-by-country reporting rules, it is looking for input on what other areas of the provision businesses may need assistance in interpreting.
-
December 05, 2024
Authorities Say €38M Greece VAT Fraud Tied To Larger Ring
Authorities in Greece carried out searches in Athens as part of an investigation into a scheme estimated to have caused €38 million ($40 million) in value-added tax losses, which the European Public Prosecutor's Office said Thursday had connections to a larger €2.2 billion scheme.
Expert Analysis
-
Atty Well-Being Efforts Ignore Root Causes Of The Problem
The legal industry is engaged in a critical conversation about lawyers' mental health, but current attorney well-being programs primarily focus on helping lawyers cope with the stress of excessive workloads, instead of examining whether this work culture is even fundamentally compatible with lawyer well-being, says Jonathan Baum at Avenir Guild.
-
Unpacking The Circuit Split Over A Federal Atty Fee Rule
Federal circuit courts that have addressed Rule 41(d) of the Federal Rules of Civil Procedure are split as to whether attorney fees are included as part of the costs of a previously dismissed action, so practitioners aiming to recover or avoid fees should tailor arguments to the appropriate court, says Joseph Myles and Lionel Lavenue at Finnegan.
-
After A Brief Hiccup, The 'Rocket Docket' Soars Back To No. 1
The Eastern District of Virginia’s precipitous 2022 fall from its storied rocket docket status appears to have been a temporary aberration, as recent statistics reveal that the court is once again back on top as the fastest federal civil trial court in the nation, says Robert Tata at Hunton.
-
Recruitment Trends In Emerging Law Firm Frontiers
BigLaw firms are facing local recruitment challenges as they increasingly establish offices in cities outside of the major legal hubs, requiring them to weigh various strategies for attracting talent that present different risks and benefits, says Tom Hanlon at Buchanan Law.
-
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.
-
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.
-
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.
-
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.
-
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.
-
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.
-
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.
-
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.
-
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.