International
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December 04, 2024
Retired Professor Says He Didn't Waive Rights In FBAR Fight
An 86-year-old former professor told a California federal court that he raised his Eighth Amendment rights against excessive fines when defending himself against a $545,000 penalty for failing to report foreign bank accounts, disputing arguments by the U.S. government that he had waived those rights.
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December 04, 2024
Estonia Plans To Implement Mandatory E-Invoicing By 2027
Estonia's Ministry of Finance announced Wednesday plans to require businesses to file all invoices electronically in order to enhance the country's collection of value-added taxes while limiting compliance burdens.
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December 04, 2024
Australia Floats Thin Capitalization Debt-Test Guidance
The Australian Taxation Office is seeking public comments on draft guidance related to its third-party debt test, one of three new tests created as part of the country's updated thin capitalization rules.
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December 04, 2024
Reed Smith Adds State Tax Partner To San Francisco Office
Reed Smith LLP added a partner to its national state tax practice who will work out of its San Francisco office, according to the firm.
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December 04, 2024
Ringleader Of €6M VAT Fraud Scheme Gets 4-Year Sentence
A German court issued a four-year prison sentence for a ringleader of a €6 million ($6.3 million) value-added tax fraud scheme involving wireless earbuds, as well as ordering that he pay €960,000, the European Public Prosecutor's Office said Wednesday.
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December 04, 2024
Pols Ask Why EU Blacklist Leaves Out 'Notorious Tax Havens'
Members of the European Parliament questioned the chair of the Code of Conduct Group on business taxation about its criteria for adding countries to the European Union's blacklist of uncooperative tax jurisdictions.
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December 03, 2024
Texas Judge Blocks 'Quasi-Orwellian' Anti-Laundering Law
A Texas federal judge on Tuesday halted the Biden administration's roll-out of new reporting requirements aimed at unmasking anonymous shell companies, granting a nationwide preliminary injunction sought by business interests challenging their constitutionality.
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December 03, 2024
Fried Frank Adds Goodwin Procter Tax Pro As Partner In NY
Fried Frank Harris Shriver & Jacobson LLP announced Tuesday that a Goodwin Procter LLP tax and business law partner has joined the firm and will serve as a partner in Fried Frank's tax department in New York.
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December 03, 2024
Exelon Asks For Corp. AMT To Account For Repairs Deduction
Power companies should be allowed to account for an industry-specific tax deduction on repair costs to determine whether they're subject to the corporate alternative minimum tax, utility giant Exelon said in a comment letter to the U.S. Treasury Department released Tuesday.
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December 03, 2024
Australia Expects Royalties, Reporting Guidance In Early 2025
The Australian Taxation Office said it expects to release draft guidance in February related to a ruling on when payment agreements for software are considered royalties, followed by guidance for exemptions from its new country-by-country reporting laws in March.
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December 03, 2024
Charity's Ex-Partner Gets 10 Years For £1.5M Gift Aid Fraud
A former finance business partner at national charity Save The Children UK has been jailed for 10 years for stealing £1.5 million ($1.9 million) through fraudulent Gift Aid claims, HM Revenue & Customs announced Tuesday.
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December 03, 2024
Comment Deadline Extended For Corp. Alternative Min. Tax
Treasury and the Internal Revenue Service said Tuesday that they will accept comments on proposed rules for the new 15% corporate alternative minimum tax on corporations with reported profits of $1 billion or more until Jan. 16, a roughly one-month extension from the previous deadline.
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December 02, 2024
Russia Looks To 4 FSIA Cases In Bid To Stay $5B Award Suit
Russia urged a D.C. federal judge to pause a case against it by a Yukos Oil Co. unit seeking to enforce $5 billion in arbitral awards, saying Monday that four parallel Foreign Sovereign Immunities Act cases are pending before the Supreme Court and the D.C. Circuit that could affect the suit.
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December 02, 2024
Texas Truck Co. Owes Chinese Tire Import Tax, 5th Circ. Says
A Houston truck company that sold tires made by a Chinese manufacturer is on the hook for excise taxes as the beneficial owner of the tires, the Fifth Circuit decided in an opinion Monday that reversed a ruling freeing the company from its nearly $2 million tax bill.
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December 02, 2024
'Harry Potter' Actor Must Pay £1.8M Tax Bill, Tribunal Says
Actor Rupert Grint, who portrayed Ron Weasley in the Harry Potter film series, faces a £1.8 million ($2.3 million) tax bill after the U.K.'s First-tier Tribunal ruled that tax avoidance was a primary purpose of an entity created to manage his career.
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December 02, 2024
IRS Floats Pooling, Annual Accounting In Offshore Profit Regs
U.S. multinational companies will be required to create annual shareholder accounts and adhere to new pooling concepts to properly account for previously taxed earnings and profits under proposed rules floated by the U.S. Treasury Department and Internal Revenue Service.
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December 02, 2024
A&O Shearman Tax Pro Jumps To Hogan Lovells In DC
Hogan Lovells said Monday that it has brought on a former Allen Overy Shearman Sterling tax partner who specializes in spinoffs, cross-border deals and other corporate transactions.
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December 02, 2024
IRS Finalizes Partnership Liability Regs After 11 Years
The Internal Revenue Service unveiled final regulations governing the allocation of partnership liabilities 11 years after releasing the proposed rules, saying no subsequent legislative and regulatory changes had taken place to compel the agency to otherwise renew the rulemaking process.
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December 02, 2024
Australia Passes Public Country-By-Country Reporting
Multinational businesses with large operations in Australia are required to publicly disclose information about their operations in tax havens as designated by the government under a country-by-country reporting law that lawmakers adopted following a two-year saga over concerns about the data's confidentiality.
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December 02, 2024
Skat Settles With Ex-Barclays Director In £1.4B Fraud Case
The Danish tax authority has settled its claim against a former Barclays Capital director and four companies that it sued alongside dozens of others over an alleged scheme to defraud it of £1.4 billion ($1.8 billion) in tax revenue.
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December 02, 2024
Sports Direct's Ashley Says HMRC Bungled His Data Request
Sports Direct International PLC founder Michael Ashley argued in a London court Monday that the U.K.'s tax agency improperly handled his data request related to its probe into his 2012 sale of real estate assets, calling its alleged failings "significant, wide-spread and persistent."
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December 02, 2024
Australia Seeks Input On Tax Treaty With Portugal
Australia's Treasury is looking for feedback on plans to implement a treaty with Portugal that would address concerns of double taxation and alleviate cross-border costs by establishing lower withholding rates, the agency said Monday.
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December 02, 2024
5 Convicted In €14M COVID Test VAT Fraud Scheme
A German court convicted five people for their roles in a value-added tax fraud scheme involving the sale of COVID-19 tests that caused about €14 million ($14.7 million) in VAT losses, the European Public Prosecutor's Office said.
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November 29, 2024
Audit Watchdog Urges EU To Curb Harmful Tax Practices
The European Union is still not doing enough to stop harmful corporate tax practices that are costing governments more than €100 billion ($105 billion) a year in revenue, the bloc's independent audit watchdog has warned.
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November 28, 2024
Police Detain 32 People In Raids On €297M VAT Fraud Network
Police have detained more than 30 people in raids on a €297 million ($313 million) value-added tax fraud network that spanned 16 EU countries, the European Public Prosecutor's Office said Thursday.
Expert Analysis
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3 Leadership Practices For A More Supportive Firm Culture
Traditional leadership styles frequently amplify the inherent pressures of legal work, but a few simple, time-neutral strategies can strengthen the skills and confidence of employees and foster a more collaborative culture, while supporting individual growth and contribution to organizational goals, says Benjamin Grimes at BKG Leadership.
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E-Discovery Quarterly: Rulings On Hyperlinked Documents
Recent rulings show that counsel should engage in early discussions with clients regarding the potential of hyperlinked documents in electronically stored information, which will allow for more deliberate negotiation of any agreements regarding the scope of discovery, say attorneys at Sidley.
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Loper Bright Limits Federal Agencies' Ability To Alter Course
The U.S. Supreme Court's recent decision to dismantle Chevron deference also effectively overrules its 2005 decision in National Cable & Telecommunications Association v. Brand X, greatly diminishing agencies' ability to change regulatory course from one administration to the next, says Steven Gordon at Holland & Knight.
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After Chevron: Delegation Of Authority And Tax Regulators
The U.S. Department of the Treasury and the Internal Revenue Service will face higher standards following Loper Bright’s finding that courts should determine whether agency rules meet the best possible interpretation of the tax code, as well as the scope of the authority delegated by Congress, says Edward Froelich at McDermott.
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Lawyers Can Take Action To Honor The Voting Rights Act
As the Voting Rights Act reaches its 59th anniversary Tuesday, it must urgently be reinforced against recent efforts to dismantle voter protections, and lawyers can pitch in immediately by volunteering and taking on pro bono work to directly help safeguard the right to vote, says Anna Chu at We The Action.
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How To Grow Marketing, Biz Dev Teams In A Tight Market
Faced with fierce competition and rising operating costs, firms are feeling the pressure to build a well-oiled marketing and business development team that supports strategic priorities, but they’ll need to be flexible and creative given a tight talent market, says Ben Curle at Ambition.
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Rock Climbing Makes Me A Better Lawyer
Rock climbing requires problem-solving, focus, risk management and resilience, skills that are also invaluable assets in my role as a finance lawyer, says Mei Zhang at Haynes and Boone.
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Contract Disputes Recap: Preserving Payment Rights
Stephanie Magnell and Zachary Jacobson at Seyfarth examine three recent decisions that together illustrate the importance of keeping accurate records and adhering to contractual procedures to avoid inadvertently waiving contractual rights to cost reimbursements or nonroutine payments.
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Think Like A Lawyer: Dance The Legal Standard Two-Step
From rookie brief writers to Chief Justice John Roberts, lawyers should master the legal standard two-step — framing the governing standard at the outset, and clarifying why they meet that standard — which has benefits for both the drafter and reader, says Luke Andrews at Poole Huffman.
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Lead Like 'Ted Lasso' By Embracing Cognitive Diversity
The Apple TV+ series “Ted Lasso” aptly illustrates how embracing cognitive diversity can be a winning strategy for teams, providing a useful lesson for law firms, which can benefit significantly from fresh, diverse perspectives and collaborative problem-solving, says Paul Manuele at PR Manuele Consulting.
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Now More Than Ever, Lawyers Must Exhibit Professionalism
As society becomes increasingly fractured and workplace incivility is on the rise, attorneys must champion professionalism and lead by example, demonstrating how lawyers can respectfully disagree without being disagreeable, says Edward Casmere at Norton Rose.
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Reading Between The Lines Of Justices' Moore Ruling
The U.S. Supreme Court's recent Moore v. U.S. decision, that the Internal Revenue Code Section 965 did not violate the 16th Amendment, was narrowly tailored to minimally disrupt existing tax regimes, but the justices' various opinions leave the door open to future tax challenges and provide clues for what the battles may look like, say Caroline Ngo and Le Chen at McDermott.
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A Midyear Forecast: Tailwinds Expected For Atty Hourly Rates
Hourly rates for partners, associates and support staff continued to rise in the first half of this year, and this growth shows no signs of slowing for the rest of 2024 and into next year, driven in part by the return of mergers and acquisitions and the widespread adoption of artificial intelligence, says Chuck Chandler at Valeo Partners.