International
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October 30, 2024
GOP Lawmakers Criticize Treasury's Start Of Taiwan Tax Talks
The top tax-writing Republicans in Congress said Wednesday that the U.S. Treasury Department's announcement that it would begin negotiations with Taiwan on a double-tax relief agreement risks undermining legislation to address the issue that is stalled in the Senate.
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October 30, 2024
Canadian Can't Claim $15.8M In Losses From Forex Trades
A Canadian businessman can't claim CA$22 million ($15.8 million) in losses as deductions because the foreign exchange trades generating them were not pursued for profit, the Tax Court of Canada ruled.
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October 30, 2024
South African Parliament To Consider Global Minimum Tax
Qualifying businesses in South Africa would be subject to two parts of the OECD's 15% global minimum tax on large multinational entities making more than €750 million ($815 million) annually under legislation sent to the country's Parliament on Wednesday.
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October 30, 2024
UK's VAT Gap Rises £1.4B In 2023-24, Initial Estimate Says
The gap between the amount of value-added tax the U.K. expected to collect in the 2023-24 tax year and the amount actually collected was an estimated £9.5 billion ($12.3 billion), a £1.4 billion increase over the final estimate for the year prior, HM Revenue & Customs said Wednesday.
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October 30, 2024
UK Capital Gains Hike Casts Shadow Over Gov't LSE Aims
The decision by Chancellor Rachel Reeves to raise the tax paid on gains made when shares are sold could hinder the government's work on making the London Stock Exchange more attractive for stock listings and investors, regulatory experts warn.
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October 30, 2024
Last UK Gov't 'Did Not Share' Spending Info With Watchdog
The independent fiscal watchdog said Wednesday that the last Conservative administration had failed to disclose public spending information, adding that it would have resulted in a "materially different" forecast for government spending if it had been given the data.
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October 30, 2024
Pension Pros Say Shutting Inheritance Tax Loophole Overdue
Retirement industry professionals said Wednesday that the budget announcement by the U.K. government that it would remove a loophole that allowed the transfer of more than £1 million ($1.3 million) of inherited pension wealth without paying inheritance tax was overdue.
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October 30, 2024
Labour Gov't Unveils £40B Tax Boost In First Budget
A £40 billion ($52 billion) tax package unveiled on Wednesday by Britain's new Labour government targets business and investors and aims to plug fiscal gaps with plans including higher levies on payrolls and capital gains.
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October 29, 2024
Rimon Adds International Tax Expert In Philadelphia
Rimon PC has added an expert in international tax and trusts and estates who joined the firm's Philadelphia office after working for his own practice.
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October 29, 2024
Croatia, Australia Reach Double Tax Treaty Agreement
Croatia and Australia have agreed on a treaty to avoid double taxation that will take effect when passed by the respective legislatures, the Croatian Ministry of Finance said.
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October 29, 2024
States Should Cede Profit-Shifting Fight To OECD, Atty Says
States should shy away from using mandatory worldwide combined reporting to address profit shifting and instead allow the Organization for Economic Cooperation and Development to police tax avoidance from multinational corporations, a business trade group attorney said Tuesday.
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October 29, 2024
Switzerland Amends Double Tax Treaty With Kuwait
Switzerland said Tuesday it has ratified changes to its double taxation treaty with Kuwait that are due to take effect early next year.
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October 29, 2024
US, Taiwan To Begin Talks On Double-Tax Agreement
The U.S. and Taiwan announced Tuesday that they will begin a first round of negotiations to craft a double-tax avoidance agreement that would provide certain treaty-like benefits.
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October 28, 2024
Russia Says High Court Case May Help Nix $5B Award Suit
Russia has told a D.C. federal court that a case recently accepted for review by the U.S. Supreme Court may provide it a path to argue that the court lacks jurisdiction to decide a case brought against the country by a Yukos Oil Co. unit.
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October 28, 2024
Latin America, Caribbean Must Up Tobacco Taxes, OECD Says
Latin American and Caribbean countries must increase their tobacco excise tax levels, among other changes, to reduce the overall affordability of tobacco products to drive people to quit using them, the Organization for Economic Cooperation and Development said Monday.
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October 28, 2024
UK Construction Co. Due £3.2M In R&D Credits, Refunds
A construction contractor is entitled to tax credits and refunds totaling over £3.2 million ($4.2 million) after the U.K.'s First-tier Tribunal ruled that its expenditures for research and development were not subsidized or contracted out by another party.
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October 28, 2024
European Commission Backs Simplified Minimum Tax Filing
Multinational corporations could file returns for the 15% global minimum tax with a single country in the European Union that they would share with the others only where necessary under a proposal approved Monday by the bloc's executive branch, according to officials.
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October 28, 2024
Labour Budget Expected To Target Taxes At Biz, Investors
The U.K. government is set to unveil its budget statement Wednesday after months of hinting at higher taxes, and experts say businesses and investors are bracing to bear the brunt of the possible tax changes, such as through increases to capital gains and payroll taxes.
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October 28, 2024
Chile Provides Guidance For Voluntary Disclosure Program
Chile's tax agency provided guidance Monday for taxpayers interested in voluntarily disclosing their previously undeclared foreign assets in order to take advantage of a temporarily available tax rate.
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October 28, 2024
IRS Extends Relief For FATCA Filings Without ID Numbers
Foreign financial institutions that report information on U.S. account holders to the Internal Revenue Service without including the taxpayer identification numbers associated with those accounts won't be flagged for noncompliance for the next three years, the agency said Monday.
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October 28, 2024
Wise Boss Hit With FCA Fine For Not Disclosing Tax Penalty
The finance regulator said on Monday that it has fined the chief executive of a money transfer company £350,000 ($454,500) for his failure to tell the watchdog he had been penalized by HM Revenues and Customs for not paying his taxes.
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October 28, 2024
US Expatriations Tick Up In 3rd Quarter, IRS Says
The number of people who expatriated from the U.S. rose during the third quarter of the year compared with the previous quarter, the Internal Revenue Service said Monday.
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October 25, 2024
German Drug Co. Due £21.5M VAT Refund, UK Tribunal Finds
A German pharmaceutical provider is entitled to a refund of almost £21.5 million ($27.9 million) for the value-added tax it paid on the rebated portion of products supplied to the U.K.'s National Health Service, the British First-tier Tribunal ruled.
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October 25, 2024
Lebanon, Angola, Others Added To Financial Crime Watch List
An intergovernmental task force on financial crimes added Lebanon, Angola, Algeria and the Ivory Coast to a watch list of countries with weak protections against money laundering and financing for armed groups, the group said Friday.
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October 25, 2024
Argentina Formally Shutters, Replaces Tax Agency
Argentina's president formally dissolved the country's tax agency, the Federal Public Revenue Administration, and established a new agency, following through on an announcement two days earlier to end what he characterized as an oversize entity.
Expert Analysis
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Anticipating Intensified Partnership Enforcement From IRS
The Internal Revenue Service's decadeslong difficulties with partnership audits led to the recent announcement of a clear, well-funded, focused initiative, and businesses operating in the partnership form will feel the impact, with definite changes ahead, says Sharon Katz-Pearlman at Greenberg Traurig.
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Pro Bono Work Is Powerful Self-Help For Attorneys
Oct. 22-28 is Pro Bono Week, serving as a useful reminder that offering free legal help to the public can help attorneys expand their legal toolbox, forge community relationships and create human connections, despite the challenges of this kind of work, says Orlando Lopez at Culhane Meadows.
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The Pop Culture Docket: Judge Espinosa On 'Lincoln Lawyer'
The murder trials in Netflix’s “The Lincoln Lawyer” illustrate the stark contrast between the ethical high ground that fosters and maintains the criminal justice system's integrity, and the ethical abyss that can undermine it, with an important reminder for all legal practitioners, say Judge Adam Espinosa and Andrew Howard at the Colorado 2nd Judicial District Court.
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How And Why Your Firm Should Implement Fixed-Fee Billing
Amid rising burnout in the legal industry and client efforts to curtail spending, pivoting to a fixed-fee billing model may improve client-attorney relationships and offer lawyers financial, logistical and stress relief — while still maintaining profit margins, say Kevin Henderson and Eric Pacifici at SMB Law Group.
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How Law Firms Can Use Account-Based Marketing Strategies
Amid several evolving legal industry trends, account-based marketing can help law firms uncover additional revenue-generating opportunities with existing clients, with key considerations ranging from data analytics to relationship building, say Jennifer Ramsey at stage LLC and consultant Gina Sponzilli.
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Strategic Succession Planning At Law Firms Is Crucial
Senior partners' reluctance to retire, the rise of the nonequity partner tier and generational differences in expectations are all contributing to an increasing number of departures from BigLaw, making it imperative for firms to encourage retirement among senior ranks and provide clearer leadership pathways to junior attorneys, says Laura Leopard at Leopard Solutions.
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Maximizing Law Firm Profitability In Uncertain Times
As threats of an economic downturn loom, firms can boost profits by embracing the power of bottom-line management and creating an ecosystem where strategic financial oversight and robust timekeeping practices meet evolved client relations, says Shireen Hilal at Maior Strategic Consulting.
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5th Circ. Ruling Reminds Attys That CBP Can Search Devices
The Fifth Circuit’s recent Malik v. Department of Homeland Security decision adds to the chorus of federal courts holding that border agents don’t need a warrant to search travelers’ electronic devices, so attorneys should consider certain special precautions to secure privileged information when reentering the U.S., says Jennifer Freel at Jackson Walker.
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Enforcement Of International Tax Reporting Is Heating Up
Since the U.S. Supreme Court’s February decision in Bittner v. U.S. changed how penalties for failure to report offshore accounts are calculated, recent developments suggest the government is preparing to step up enforcement and vigorously pursue the collection of resulting penalties, say Daniel Silva and Agustin Ceballos at Buchalter.
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IRS Notice Clarifies R&E Amortization, But Questions Remain
The IRS and Treasury Department’s recent notice clarifying the treatment of specified research and experimental expenditures under Section 174 provides taxpayers and practitioners with substantive guidance, but it misses the mark in delineating which expenditures are amortizable, say attorneys at Eversheds Sutherland.
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Preparing Your Legal Department For Pillar 2 Compliance
Multinational entities should familiarize themselves with Pillar Two of the Organization for Economic Cooperation and Development’s BEPs 2.0 project and prepare their internal legal tracking systems for related reporting requirements that may go into effect as early as January, says Daniel Robyn at Ernst & Young.
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What Large Language Models Mean For Document Review
Courts often subject parties using technology assisted review to greater scrutiny than parties conducting linear, manual document review, so parties using large language models for document review should expect even more attention, along with a corresponding need for quality control and validation, say attorneys at Sidley.
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Participating In Living History Makes Me A Better Lawyer
My role as a baron in a living history group, and my work as volunteer corporate counsel for a book series fan association, has provided me several opportunities to practice in unexpected areas of law — opening doors to experiences that have nurtured invaluable personal and professional skills, says Matthew Parker at the Nebraska Department of Health and Human Services.