International
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October 01, 2024
Ex-USTR Official Sees Possible Path Forward For Digital Taxes
The U.S. may withhold trade threats if it believes countries are having good-faith conversations about concerns that their digital services taxes discriminate against U.S. businesses, including in current talks with Canada, the former general counsel for the Office of the U.S. Trade Representative told Law360.
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October 01, 2024
Ireland Eyes Infrastructure With €14B From ECJ Apple Case
The Irish government is aiming to build infrastructure with the €14.1 billion ($15.6 billion) in corporate tax payments due from Apple Inc. following a European Court of Justice ruling that Ireland granted Apple illegal state aid, officials said Tuesday in announcing next year's budget.
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October 01, 2024
EU Chief Prosecutor Calls For Making Tax Fraud A Priority
As organized crime rings continue to affect the European Union budget through "massive" value-added tax and customs fraud schemes, more must be done to support the European Public Prosecutor's Office and its power to investigate such crimes, the European chief prosecutor said in remarks published Tuesday.
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October 01, 2024
Treasury Plans Final Direct Pay Partnership Regs By Year-End
The U.S. Treasury Department is eyeing the end of the year to finalize regulations for development projects to elect out of their partnership tax status to qualify for a direct cash payment of their clean energy tax credits, an official said Tuesday.
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October 01, 2024
EU General Court To Begin Hearing VAT Cases
The European Union General Court can make preliminary rulings in cases involving the EU's common system of value-added taxes, effective Tuesday, as part of an expansion of the court's jurisdiction.
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October 01, 2024
UK Tax Havens Tied To $84B In Lost Revenue, Group Says
The British Virgin Islands, Cayman Islands and Bermuda held on to their spots atop the Tax Justice Network's tax havens list, with the group saying Tuesday that the U.K.'s tax havens network is responsible for a third of global corporate tax abuse risks.
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October 01, 2024
Estate Exaggerating Value Of Exec's Tax Tipoff, DC Circ. Told
A Dutch bank executive's estate is "vastly" overstating the significance of his tips to the IRS in seeking a whistleblower award for his reporting of tax schemes, the U.S. government told the D.C. Circuit, urging it to uphold the U.S. Tax Court's denial of the award.
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September 30, 2024
Corporate Tax Rates Up In 2023, OECD Annual Report Finds
A global trend toward cutting taxes to address the economics of the COVID-19 pandemic began to wane in 2023, with more nations willing to raise taxes and broaden tax bases to fund social spending, the Organization of Economic Cooperation and Development said Monday.
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September 30, 2024
PwC Agrees To $63M Fine For Evergrande Audit, China Says
PwC's chairman agreed to the firm's six-month suspension in China and nearly $63 million in fines over its Chinese auditing arm's work for Evergrande Group, which until a court-ordered liquidation in January was the country's largest real estate firm, the country's Finance Ministry said Monday.
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September 30, 2024
IRS Seeks Input On Draft Partnership Basis-Shifting Form
The Internal Revenue Service asked for comments Monday on a draft form and instructions for partners to disclose all the property they receive from partnerships, part of upcoming regulations meant to target abusive tax avoidance that uses sophisticated partnership basis-shifting transactions.
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September 30, 2024
German Lawyer Charged Over €428M Cum-Ex Fraud
A lawyer has been charged in Germany with several counts of "serious tax evasion" over his alleged role in a €428 million ($477 million) so-called cum-ex dividend tax fraud, a German court confirmed Monday.
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September 30, 2024
Feds Seek Prison In Tax Case Linked To 'China Initiative'
Prosecutors have asked a Texas federal judge for an 18- to 24-month prison sentence for a Chinese-born engineer who pled guilty to tax crimes after being charged with export violations and fraud in a case the defense claims began as an espionage investigation under the U.S. Department of Justice's now-disbanded "China Initiative."
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September 30, 2024
IRS Appeals Office Tests Group Mailbox For Large Cos.
The Internal Revenue Service's Independent Office of Appeals announced Monday that it will test out a program intended to help enhance secure messaging for large businesses with multiple representatives by allowing them to request a group mailbox to communicate with their assigned Appeals employee.
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September 30, 2024
Aussie 2023-24 Budget Delivered Surplus Despite Tax Dip
Australia ended the 2023-24 fiscal year with an AU$15.8 billion ($11 billion) surplus, larger than what the government had projected and primarily due to spending cuts, not higher taxes, according to the country's annual report, published Monday.
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September 27, 2024
Ex-Citizens' Renunciation Fee Suit Shipped To Claims Court
A D.C. federal judge ruled that a lawsuit brought by former U.S. citizens seeking a refund on their $2,350 citizenship renunciation fee belongs in the Court of Federal Claims.
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September 27, 2024
Constitution Permits Blocked Anti-Laundering Law, Panel Told
The U.S. government urged the Eleventh Circuit on Friday to reinstate the Corporate Transparency Act passed in 2021, arguing that the anti-money laundering law is within Congress' powers to regulate economic activity and necessary to have businesses report beneficial ownership to combat crimes like tax evasion and terrorist financing.
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September 27, 2024
IRS Plans Transition Rules In Basis-Shifting Regs, Atty Says
The IRS plans to include transition rules in forthcoming proposed regulations that aim to clamp down on abusive tax avoidance practices through complex partnership transactions known as basis shifting, an agency attorney said Friday.
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September 27, 2024
Corp. AMT Rules Could Wrap In Smaller Partnerships
Recently proposed rules on the U.S. corporate alternative minimum tax create new concerns for partnerships of various sizes that could be forced to comply with complex reporting requirements unless the government introduces carveouts, tax observers said.
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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.
Expert Analysis
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6 Practice Pointers For Pro Bono Immigration Practice
An attorney taking on their first pro bono immigration matter may find the law and procedures beguiling, but understanding key deadlines, the significance of individual immigration judges' rules and specialized aspects of the practice can help avoid common missteps, says Steven Malm at Haynes Boone.
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Lessons From Country Singer's Personal Service Saga
Recent reports that country singer Luke Combs won a judgment against a Florida woman who didn’t receive notice of the counterfeit suit against her should serve as a reminder for attorneys on best practices for effectuating service by electronic means, say attorneys at Jenner & Block.
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7 E-Discovery Predictions For 2024 And Beyond
The legal and technical issues of e-discovery now affect virtually every lawsuit, and in the year to come, practitioners can expect practices and policies to evolve in a number of ways, from the expanded use of relevancy redactions to mandated information security provisions in protective orders, say attorneys at Littler.
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5 Litigation Funding Trends To Note In 2024
Over the next year and beyond, litigation funding will continue to evolve in ways that affect attorneys and the larger litigation landscape, from the growth of a secondary market for funded claims, to rising interest rates restricting the availability of capital, says Jeffery Lula at GLS Capital.
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4 Legal Ethics Considerations For The New Year
As attorneys and clients reset for a new year, now is a good time to take a step back and review some core ethical issues that attorneys should keep front of mind in 2024, including approaching generative artificial intelligence with caution and care, and avoiding pitfalls in outside counsel guidelines, say attorneys at HWG.
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What The Law Firm Of The Future Will Look Like
As the legal landscape shifts, it’s become increasingly clear that the BigLaw business model must adapt in four key ways to remain viable, from fostering workplace flexibility to embracing technology, say Kevin Henderson and Eric Pacifici at SMB Law Group.
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4 PR Pointers When Your Case Is In The News
Media coverage of new lawsuits exploded last year, demonstrating why defense attorneys should devise a public relations plan that complements their legal strategy, incorporating several objectives to balance ethical obligations and advocacy, say Nathan Burchfiel at Pinkston and Ryan June at Castañeda + Heidelman.
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Unpacking The Proposed Production Tax Credit Regulations
Recently proposed tax regulations for claiming the U.S. clean-energy manufacturers' production credit under Internal Revenue Code Section 45X are less stringent than many had feared but fail to define a fundamental eligibility requirement, say Casey August and Jared Sanders at Morgan Lewis.
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10 Considerations For Litigating A New York Tax Case
While some of New York’s recently adopted corporate tax regulations are likely to face legal challenges, aggrieved taxpayers should answer certain questions before deciding to embark on the tax litigation process, say Cyavash Ahmadi and Jeffrey Friedman at Eversheds Sutherland.
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Law Firm Strategies For Successfully Navigating 2024 Trends
Though law firms face the dual challenge of external and internal pressures as they enter 2024, firms willing to pivot will be able to stand out by adapting to stakeholder needs and reimagining their infrastructure, says Shireen Hilal at Maior Consultants.
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Attorneys' Busiest Times Can Be Business Opportunities
Attorneys who resolve to grow their revenue and client base in 2024 should be careful not to abandon their goals when they get too busy with client work, because these periods of zero bandwidth can actually be a catalyst for future growth, says Amy Drysdale at Alchemy Consulting.
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How Attorneys Can Be More Efficient This Holiday Season
Attorneys should consider a few key tips to speed up their work during the holidays so they can join the festivities — from streamlining the document review process to creating similar folder structures, says Bennett Rawicki at Hilgers Graben.
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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.